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Growth Point Capital Pty Ltd (“Growth Point Capital”) recognises the importance of ensuring that its clients have confidence in the way Growth Point Capital handles personal information.
Growth Point Capital is bound by, and committed to, the terms of the Privacy Act 1988 and the Australian Privacy Principles which govern the way in which Growth Point Capital manages personal information. This policy sets out how Growth Point Capital collects, uses, discloses and otherwise manages personal information about its clients and other third parties from whom personal information is collected.
Unless a client states otherwise, Growth Point Capital may use the personal information that a client has provided, so that Growth Point Capital’s related entities, dealers and other business partners can promote and market products, services and special offers that may be of interest to Growth Point Capital clients. In addition, this policy also applies to Growth Point Capital with respect to how Growth Point Capital handles the personal information of its employees and contractors.
2. What is Personal Information?
Personal information is any information about an identified individual, or an individual who is reasonably identifiable. Common examples of personal information are names, addresses, telephone numbers, dates of birth and bank account details.
- Growth Point Capital will only collect information about a client that is reasonably necessary in order to adequately provide the services the client has requested.
- The use or disclosure of personal information collected by Growth Point Capital is subject to either consent being provided by the individual or use and disclosure permitted by law.
- Growth Point Capital may be requested by regulators to provide certain personal information about clients, and is by law obligated to provide such information.
- Clients can request to review personal information held by Growth Point Capital by contacting the Growth Point Capital Compliance Department.
3. What Kinds of Personal Information does Growth Point Capital Collect and Retain?
Growth Point Capital only collects personal information that is necessary for one or more of its functions or activities.
Growth Point Capital is subject to certain legislative and regulatory requirements which necessitate it obtaining and holding detailed and accurate information which personally identifies its customers and/or contains information or an opinion about customers (“Personal Information”).
Growth Point Capital will not collect any Personal Information about a customer except when the information provided to Growth Point Capital is authorised by a customer or a third party to provide that information. Generally, collection of personal information will be obtained by the following methods:
- in face-to-face interviews;
- over the telephone; and
- by completion of Know your Customer Forms or Customer Details Form.
We may also collect personal information about you when you contact us via a contact form or visit our website.
The type of information collected by Growth Point Capital may include:
- personal identification details including your full name, date of birth, contact details, address, gender and marital status;
- your Tax File Number for tax residency status;
- financial and transaction information;
- employment status and details; and
- how the customer will use the products and services being provided.
This is not an exhaustive list and Growth Point Capital may need to collect additional information in order to assist Growth Point Capital in providing services to its customers.
When you visit our website your location information, IP address and any third party sites you access may be collected.
In order to provide clients with a comprehensive lending and debt funding products service, and to have a reasonable basis for recommendations made, Growth Point Capital may request personal information to:
- confirm your identity;
- determine credit worthiness;
- assist the customer in gaining an understanding of a financial product;
- assess your application for a product or a service;
- make financial products recommendations;
- execute financial products transactions on behalf of a client;
- clear and settle financial products transactions on a client’s behalf;
- minimise the risk of fraudulent activity;
- contact you in relation to the services being provided to you; and
- manage our relationship with you.
4. How is Personal Information Collected?
Most information we hold about clients is collected from the Client Agreement Form and through the Know Your Client (KYC) process. Information may also be collected over the phone or via the internet. Sometimes, information about an individual is collected from other people or organisations. For example, information about a director of a corporate customer may be obtained from a public record relating to the company. We may also collect information from other third parties including employers, accountants, referees, other professional advisers and relatives. We may ask a credit reporting body for your credit report. We may also collect information about you that is publicly available (for example in public registers or on social media).
Unless otherwise permitted by law, or unless it is obvious from the circumstances that you would know or expect the information to be collected, Growth Point Capital will take reasonable steps to ensure that you are aware that Growth Point Capital is collecting the information, the reason why the information is being collected and how the information will be used.
Sensitive Information is protected under the Privacy Act and we will not collect this information without your consent, unless otherwise allowed by law. Sensitive information includes such information as your religion, ethnicity, health information and biometrics.
5. Who Do We Share your Information with?
We may share your information with others for the reasons mentioned in clause 3. We may also share your information with third parties for the reasons in clause 3 or where the law otherwise provides. These third parties can include:
- Service providers, including, but not limited to, mortgage insurers, settlement representatives, legal representatives, product distributors and contractors;
- Businesses who do some of our work for us including direct marketing, statement production, debt recovery and IT services;
- Brokers, agents, advisers and people who may act on your behalf;
- Organisations involved in our funding arrangements like loan purchasers, investors, researchers, valuers;
- People who help process our loans like assessors and aggregators;
- Other lending institutions;
- Auditors, insurers and re-insurers;
- Government and law enforcement agencies or regulators;
- Credit reporting bodies and credit providers; and
- Other people like business partners or associates who are also a party to the relevant transaction.
We are required under the Corporations Act to make certain information available for inspection, on request to ensure ongoing compliance with licensing and regulatory requirements. This may involve the disclosure of Personal Information. Growth Point Capital may also collect personal information from its suppliers in order to complete business transactions and purchase products and services.
External service providers are only authorised to use personal information for the purpose for which we supplied it. Those organisations are not authorised to use that personal information for their own purposes.
If Growth Point Capital is unable to collect personal information from or about an individual, it may not be able to do business with that individual or the organisation with which the individual is connected.
If the personal information provided to Growth Point Capital is incomplete or inaccurate, Growth Point Capital may be unable to provide that individual or the organisation with the services that they are seeking.
Growth Point Capital may use the Personal Information collected from clients for the purpose of providing them with direct marketing material such as research that may be of interest, to inform them about new products and services or special offers from time to time. However, clients may, by contacting Growth Point Capital by any of the methods detailed in clause 12, request not to receive such information and we will give effect to that request. Please allow 2 weeks for the request to be actioned. Please note that personal information will not be used for marketing purposes where the Do Not Call Register Act 2006 or the Spam Act 2003 applies or where it is contrary to any other Australian legislation or regulations.
6. Checking your Credit History
If you ask us for credit or for assistance in obtaining credit, we may check your credit history. We obtain credit reports from external credit reporting bodies. We also share your credit information with them so that they can provide credit reports to others.
A credit report gives us information about your credit worthiness and history.
The Privacy Act limits the information that we can give to credit reporting bodies and the information that they can give us. The Act also limits how we can use these credit reports. The information that we are permitted to share includes:
- Your identity;
- Type and amount of credit that you have – like personal and home loans and other credit facilities;
- How much you have borrowed;
- If you have made all of your repayments;
- If you have committed fraud or another serious credit infringement.
Credit reporting bodies include this information in their reports to assist other credit providers to assess your credit worthiness. We also ask credit reporting bodies to give us your overall credit score and may use credit information from credit reporting bodies together with other information to arrive at our own scoring of your ability to manage credit.
The credit reporting bodies that we use include Equifax (formerly known as Veda Advantage Information Services and Solutions Ltd) and Dun & Bradstreet (Australia) Pty Ltd. For more information on these bodies please visit their websites at:
What do we do with the credit information?
We use the information from credit reporting bodies to:
- Confirm your identity;
- Assess your credit applications;
- Assess your ability to manage credit; Manage our relationship with you;
- Collect overdue payments.
We keep your credit information with your other information. You can view this information or ask us to correct it if it’s wrong (section ) or make a complaint to us (see Section ).
7. Document Storage and Security
Growth Point Capital will at all times seek to ensure that your Personal Information collected and held is protected from misuse, interference, loss, unauthorised access, modification or disclosure. At all times personal information is treated as confidential and any sensitive information is treated as highly confidential and stored accordingly.
Building and Premises Security
Access to Growth Point Capital’s premises is controlled by only allowing employees and authorised contractors with security passes to access the premises. Unauthorised persons are strictly prohibited from entering our premises. The building has a mix of alarms, cameras and foyer security to prevent unauthorised access.
Electronic System Security
All electronic information is stored on password protected segregated drive. We have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorised users accessing our systems.
When we send your electronic data to other organisations we use secure networks or encryption.
Destroying or De-Identifying Data when no longer required
We aim to keep personal information only for as long as we need it, that is for business or legal reasons. When we no longer need or required to keep the information, we take all reasonable steps to destroy or de-identify the information.
8. Access to your personal information
You can contact us and ask to view the personal information that we hold. You can ask us for a copy of the information, like your transaction history, by going online or calling us. To get a copy of the credit information which we hold on you, you will need to call us.
If you require access to more detailed information, for example, the information that we have included in your loan file or your loan assistance file, you will need to fill out a Request for Access to Information form. You will need to send that to us by following the procedure set out in clause 12.
Is there a Fee for Accessing Information
There is no fee for asking for information, however we may charge an access fee to cover the administrative time spent in collating the information that you want to access. If there is a fee we will advise you of this prior to incurring the costs. Generally the fee that will be charged will be an hourly rate plus photocopying and postage costs or other reasonable expenses incurred. You will need to pay the fee prior to us commencing the retrieval process.
How long will it take?
We always try to make the information available within 30 days of your request. However, this may extend beyond 30 days where there are circumstances outside of our control. In this situation we will advise you of any extended time frame. Before you are provided with the information we will also need to confirm your identity.
Can we refuse to give you access to your personal information?
Yes, we will not provide you access if:
- Providing access would pose a serious and imminent threat to the life or health of a person;
- Providing access would have an unreasonable impact upon the privacy of others;
- The request being made is vexatious or frivolous;
- The information relates to existing or anticipated legal proceedings between you and us and would not be discoverable in those proceedings;
- Providing access would reveal commercially sensitive or evaluative information generated by
Growth Point Capital during a commercial decision making process;
- Providing access would be unlawful;
- Denying access is required by law;
- Providing access would prejudice certain operations by or on behalf of a law enforcement body or agency or an enforcement body requests that access not be provided on the grounds of national security; or
- Providing access could prejudice the prevention, detection or investigation of seriously improper conduct or fraud either within or external to Growth Point Capital’s operations.
In the event that access if refused we will advise you in writing of the reasons for that refusal.
9. Updating or Correcting your Information
Growth Point Capital will endeavor to ensure that, at all times, your personal information is up to date and accurate. If you believe that the information that we hold is inaccurate or incomplete or outdated then you may contact us and provide evidence of the inaccuracy or incompleteness. See section for ways to contact us. If we have given the incorrect information to another party, you can ask us to let them know that the information is incorrect. We will not charge a fee for doing this.
If the incorrect information was given to us by a credit reporting body, we may need to check with them or the relevant credit provider before we can change it. We will try to do this within 20 days. If we cannot do that within the time frame then we will advise you and agree on a new timeframe with you. We will also tell you when the information has been corrected.
If we believe that the information does not need to be updated or corrected then we will advise you of this in writing and provide you with reasons why.
It is important that we do have your correct details such as your current home and email address and contact numbers.
Growth Point Capital has implemented procedures and installed equipment to safeguard the security and confidentiality of personal information collected via our website. While it is not necessary to register a customer’s personal details to use our website (unless using our online credit provider services) we do offer a registration enquiry service which enables potential customers to obtain product information and existing customers to receive additional services and information. In the event that you do register with Growth Point Capital, personal information including your name and email address and contact phone number will be collected.
Growth Point Capital continually reviews these arrangements to ensure that we are doing all that is reasonably and technically feasible at the time to protect your information. Due to the nature of the internet, Growth Point Capital cannot guarantee that it is totally protected from hackers or misuse.
If customers or potential customers have registered with Growth Point Capital’s online registration service and decide, at any time, that they do not wish to receive further information from any company within Growth Point Capital or JB Financial Group Ltd, they can send an email to the address listed in clause 12 requesting to be removed from the online registration database. Please allow two weeks for the request to be actioned.
11. Transborder Data Flows
Growth Point Capital will not transfer data internationally unless:
- We believe that the recipient is governed by laws or rules that would uphold the Australian
Privacy Principles similar to the privacy guidelines in the Privacy Act 1988 (Cth);
- We have taken reasonable steps to assure us that the information transferred will not be collected, held, used or disclosed inconsistently with the Privacy Act 1988 (Cth); and
- The transfer is necessary to disclose information for the purpose for which it was obtained and for any reasonable secondary purpose arising out of the primary purpose.
12. Making a Privacy Complaint
If you have a concern or complaint about your privacy, please let us know and we will try to resolve it. To make a complaint please contact our Privacy Officer on 0400 224 615.
If a complaint is made we will:
- Keep a record of the complaint and log it in our Complaints Register;
- Give you a reference number;
- Respond to the complaint within 5 business days;
- Keep you updated as to the progress of the investigation of your complaint; and
- Provide you with a final response within 45 days. If we are unable to provide a final response within this timeframe then we will advise you in writing and provide you with an expected timeframe for a final response.
If your complaint is about your credit information, we may need to contact the credit reporting body we may need to check with the body or another credit provider. We will acknowledge receipt of your complaint in writing within 7 days and will aim to provide you with a resolution or formal response within 30 days of receiving your complaint. If we are unable to resolve it within that timeframe then we will advise you in writing and provide an expected time frame for resolution.
What if I am not satisfied with the response?
If you are not satisfied with our response to your complaint you can complain to the Office of the Australian Information Commissioner online at www.oaic.gov.au or call 1300 363 992.