Privacy Policy

ABN : 51 137 847 495

Introduction

This is the Privacy Policy of Cunnington & Co Holdings Pty Ltd. Cunnington & Co is committed to ensuring the privacy of your personal information and is bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

This Privacy Policy details how we collect, handle and deal with personal information that we collect about individuals, whether for our own purposes, or when acting as the agent of a financier.

In this Privacy Policy, a reference to "we" is a reference to Cunnington & Co acting in its own capacity, as well as a reference to Cunnington & Co where it is acting as the agent of a financier to whom an credit application has or may be made with the assistance of Cunnington & Co.

If you have any questions relating to this Privacy Policy, you may contact our Privacy Officer on the telephone number provided below (in connection with "Access and correction").

What kinds of personal information do we collect and hold?

The personal information that we collect about you will usually depend upon the products or services that are being provided, or that may be provided, to you or to another person with whom you are connected. The information we collect about you may include some or all of the following:

  • your name, address, date of birth and contact details;

  • your e-mail address;

  • your tax file number;

  • information from personal identification documents;

  • information required for identity verification purposes;

  • details about your financial position, which may include information about your assets, expenses and any debts you may have;

  • details of any securities you have given to us or another person; and

  • details of specified transactions.

Before a financier provides a product or service to you, or a person connected with you, we may be required to collect your full name, residential address and date of birth. We may be required to do this in order for the financier to comply with its customer identification obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. As a part of such process we may need to take copies of your personal identification documents in order to verify your identity in accordance with the requirements of that Act.

We will not collect sensitive information about you without your consent.

How do we collect personal information?

In most instances, we will collect information about you:

  • from an application form completed by you or a person with whom you are connected;

  • from information you otherwise provide to us, or our agents;

  • by our accessing public databases maintained by the Australian Securities and Investment Commission;

  • by us seeking verification information in relation to your identity from a third party such as Veda Advantage Ltd;

  • by our obtaining other information from third party commercial and business information providers;

  • by email request to you; and/or

  • by telephone contact with you.

Who do we disclose your personal information to, and why?

We will only use or disclose the information collected about you:

  • for the purpose for which it was collected;

  • for related purposes for which you would reasonably expect us to use or disclose the information;

  • where you have consented to us using or disclosing the information; or

  • where we are required or otherwise permitted to do so by law.

We may use your personal information to:

  • identify you, or establish your tax status under any Australian or foreign legislation, regulation or treaty or pursuant to an agreement with any tax authority;

  • assess and process your request for a financial product or service;

  • assess and process a request for the provision of a financial product or service to a person or entity connected with you;

  • assess your suitability as a guarantor or potential guarantor;

  • provide a financial product or service to you, or a person or entity connected with you;

  • open and maintain an account for you, or the account of a person or entity connected with you;

  • manage our relationship with you, or a person or entity connected with you;

  • help us to assess products that may suit your financial needs or the needs of a person or entity connected with you;

  • notify you of any products that may be of interest to you or a person or entity connected with you;

  • audit and monitor the services we provide to you or a person or entity connected with you;

  • assist us to perform administrative or operational task (including risk management, systems development and testing, credit scoring, staff training and customer research);

  • investigate, identify or prevent any actual or suspected fraud or unlawful activity;

  • update the personal information we hold about you or the files of a person or entity connected with you; and/or

  • enable us to meet our obligations under law, for example, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or under Australian taxation laws.

We may disclose your personal information to:

  • our service providers who assist in the review or processing of a credit application with which you are connected;

  • our related companies (if any);

  • our agents, the person who introduced you to us, contractors or other third party service providers, to enable them to provide administrative and other services to us;

  • credit reporting bodies;

  • one or more of the financiers;

  • other financial institutions in connection with a credit application with which you are connected or your dealings with us;

  • your authorised agents or your executor, administrator or legal representative; and to

  • government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes.

We may use third party service providers to maintain some of our data systems and provide auxiliary services. We require any party that has access to personal information to conform to our privacy standards.

Do we disclose personal information overseas?

Will not disclose your personal information to a recipient overseas. However, where we are acting as the agent of a financier when we collect your personnel information, and where that personnel information is collected by that financier from us or from you, the financier (where it is permitted to do so) may disclose your personal information to an overseas recipient.

Access to and correction of personal information

We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date. You may at any time request access to personal information that we hold about you and, if there is an error (or our information about you is incomplete, inaccurate or out of date), you can advise us about this matter and we will, if needed, correct, amend or add to the information we hold about you.

We will not charge you a fee for your access request (unless we have separately advised you that such a fee will apply), but may charge you the reasonable cost of processing your request, including so as to allow us to provide you with access to your personal information.

If you would like to request access to the information that Cunnington & Co hold about you, please contact our Privacy Officer by calling us at: 02 9321 3100.

Resolving your privacy concerns and complaints - your rights

If you have a complaint about our treatment or our records of your personal information, please contact our Privacy Officer (using the contact details provided above). Our Privacy Officer will investigate your complaint and endeavour to resolve any issue to your satisfaction.

If we do not adequately answer your concerns, you have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC). Complaints to the OAIC must be made in writing.

Further information about making a complaint to the OAIC can be found at: http://www.oaic.gov.au/privacy/making-a-privacy-complaint

Financiers

The Financiers are one or more of the following to whom your credit application is or may be submitted by Cunnington & Co Limited:

  • Altitude Trustservices Pty Ltd ABN 65 083 409 429, as trustee for: Altitude Trustservices Pty Ltd ABN 65 083 409 429, as trustee for: the SME Asset Finance Trust ABN 25 849 110 237; the SME Auto Finance Trust ABN 84 642 236 831; the SME Cashflow Finance Trust ABN 24 533 567 177; the SME PremiumPay Trust ABN 66 926 262 656; or the SME Loans Receivables Trust ABN 93 949 512 230.

Other contact details

Cunnington & Co can also be contacted:

  • by email: privacy@smecash.com.au

  • by mail: GPO Box 3259, Sydney, NSW,2001.

Version: July 2014