Fingo Finance (Fingo) is a Registered Business Name of Automotive Lease Packaging Pty Ltd (ALP)- Australian Credit Licensee (ACL) Number: 422 347
(“Fingo“) will ensure that personal information held about you is handled in accordance with the Privacy Act 1988 (Cth) (“Privacy Act“), including the Australian Privacy Principles (“APPs“), Part IIIA of the Privacy Act and the Credit Reporting Privacy Code (“CR Code“). The personal information we collect about you, and how we use or disclose that personal information, depends largely on the products and services that you have selected.
This Privacy and Credit Reporting Policy (“Policy“) applies to the personal information of both our current and former customers, individuals we may deal with such as guarantors, directors and shareholders of our customers and other individuals we may deal with as part of our business. This Policy tells you how your personal information is collected, held, used, disclosed and protected by us.
Unless stated otherwise in this Policy, a reference to the words “we”, “our” or “us” in this Policy is a reference to Fingo Finance.
What is personal information?
“Personal information” includes any information or opinion about an identified individual, or an individual who can be reasonably identified from their information. The information or opinion will still be personal information whether it is true or not and regardless of whether we have kept a record of it.
In this Policy, “personal information” is also a reference to consumer credit-related information, including:
- “credit information”, which is information that has a bearing on credit that has been provided to you or that you have applied for, including credit for personal, domestic or household purposes and credit in connection with a business (such as your identification details, information about your account, whether it is open or closed and the relevant dates, the type (such as a lease or loan) and amount of credit, and your repayment history information, such as whether you have made, or missed, a payment on your credit facility); and
- “credit eligibility information”, which is information disclosed to us by a credit reporting body about you or information we derive from it about you.
- Using personal information for market research to enhance the quality of Fingo Finance’s products and customer satisfaction.
Information we may collect, use and disclose about you
The types of personal information we collect, hold, use and disclose about you include:
- identity and contact details of you and your referees (such as your residential and business address), your employment and occupation details;
- your date of birth, marital status and number of dependents;
- your financial circumstances and credit history details;
- details of your assets and liabilities;
- products and transactions you may have with us;
- your product or service preferences;
- other details relating to your relationship with us, including if we deal with you in a capacity other than a customer; and
- government identifiers such as your Australian Business Number, Medicare card number, pension card number, your driver’s licence number and tax file number. (We will not adopt government identifiers as our own. If we do collect these, we will use them only for identification purposes.) If you deal with us in circumstances that involve the provision of credit, we may also collect and hold various types of credit-related information about you, including:
- that you have applied for consumer or commercial credit (including the name of each relevant credit provider), the type and amount of that credit and that we have accessed your consumer credit information to assess a relevant application;
- that we and other credit providers are or have been a provider of credit to you and the type, characteristics and maximum amount of credit that we have provided or will provide;
- the date that any credit contract we or other credit providers have or had with you was entered into and the date that it is terminated or otherwise ceased;
- your repayment history in relation to credit facilities provided by us or other credit providers (for example, if you have made payments when due and if not, when overdue payments have been made);
- payments owed to us or another credit provider, in connection with credit provided to you or in relation to which you are a guarantor, overdue for more than 60 days (and if you subsequently repay any such overdue payment, the fact of that repayment);
- whether in our or another credit provider’s opinion you have committed a serious credit infringement;
- whether you have entered into arrangements with us or other credit providers in connection with credit provided to you;
- court proceedings information, personal insolvency information and credit-related publicly available information;
- scores, ratings, summaries, evaluations and other information relating to your credit worthiness which is derived by us or by credit reporting bodies wholly or partly on the basis of the information above; and
- certain administrative information relating to credit, such as account and customer numbers.
How personal information is collected
In many circumstances we will collect your personal information directly from you, including when you talk to us on the phone, fill out one of our applications or other form and when you send us an email using one of the links or forms from our website.
The personal information we collect about you from our website depends on how you use our website, but is generally limited to the detail you enter within the form on our website, your email address and the contents of any electronic message you may send to us. Personal information collected from our website will only be used for the purpose for which you have provided it and it will not be added to a mailing list or used for any other purpose without your consent.
However in some circumstances, in order to provide the products and services you have selected or for other purposes noted in this Policy, we may need to obtain personal information about you from others. This may happen without your direct involvement. The circumstances when we may need to do this might include where we need further information to assist us to process your application, or to verify the information you have provided to us or to assist us with locating or getting in contact with you. For example, we may collect personal information about you from:
- publicly available sources of information, such as public registers;
- your representatives (including your legal advisor, accountant, mortgage broker, financial advisor, executor, administrator, guardian, trustee, or attorney);
- your employer (for example, to confirm your employment and income details);
- your real estate agent (for example, to confirm your income received on an investment property);
- other organisations, who jointly with us, provide products or services to you;
- commercial information service providers, such as companies that provide fraud prevention reports; and
- insurers, re-insurers and health care providers.
Where relevant, we may also contact credit reporting bodies and other credit providers to obtain information about you relevant to us providing products or services to you or to our relationship with you. We may also collect information that is derived by us from your usage and (if applicable) repayment of any account held with us or other credit provider associated with us.
Purposes for which we may collect, hold, use and disclose your personal information
We collect, hold, use and disclose personal information about you to the extent reasonably necessary for the purposes of your dealings with us, conducting our business or as permitted by law.
Our collection, use and disclosure of personal information about you depend on:
- which of our products or services you use or have used;
- your relationship with our business (as a customer or in any other capacity); and
- our obligations at law.
The purposes for which we may collect, use and disclose your personal information may include:
- deciding whether to provide you, or an entity associated with you, with credit or to accept you as a guarantor;
- providing products or services that you have selected;
- servicing and managing products and services that are provided to you or other relationships and arrangements in relation to:
- those products and services that we provide (including managing credit we may provide and assisting you to meet your credit-related obligations); or
- our business;
- assessing, establishing and administering any credit related insurance product (including, if applicable, assessing your application for insurance);
- determining whether the products or services we are providing to you are suitable for your purposes;
- deriving scores, ratings and evaluations relating to your credit worthiness which we use in our decision-making processes;
- processing payments and invoices as well as attending to our internal accounting and administration requirements;
- dealing with complaints;
- administering any other arrangements or dealings that you have with us (not only as a customer but also where we deal with you in any other capacity);
- meeting domestic or foreign legal and regulatory reporting and compliance requirements; and
- undertaking debt recovery and enforcement activities, including in relation to guarantors, and to deal with serious credit infringements as well as assisting other credit providers to do the same.
If you do not provide us with your personal information, we may not be able to provide you with the products or services you are seeking or assist you with other inquiries or matters.
We will not use or disclose your personal information for a purpose unrelated to the matters referred to in this Policy unless:
- we are required or authorised to do so by law or where we have a public duty to do so; or
- you have expressly consented to us disclosing the personal information which we hold about you or your consent may be reasonably inferred from the circumstances.
Australian laws which require or authorise us to collect personal information
Various Australian laws may require or authorise us to obtain information about you, such as:
- the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No.1) (Cth) and other anti-money laundering legislation (for example, for identity verification);
- the National Consumer Credit Protection Act 2009 (Cth) (for example, if you have applied for banks, credit unions, building societies, finance companies and vendors offering sales contracts by instalment such as commercial hire purchase agreements.
- the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1936and 1997 (Cth) and other taxation laws and regulations (for example, to comply with information requests issued by the Commissioner of Taxation).
Marketing and disclosure to automotive lease packaging and business partners
In addition to the above, the purposes for which we may collect, use and disclose your personal information may include:
- keeping you informed of other products or services (including third party products and services, webinars, special offers and promotions) that we think may be of interest to you;
- determining whether the products or services we may provide to you are suitable for your purposes; and
- allowing other members of Fingo Finance and our third party service providers to more efficiently provide or manage the products and services that have been made available to you.
We may send you marketing communications (including by phone, electronic message, e-mail or other electronic means, such as through social media or targeted advertising through the Fingo Finance website(s)) for these purposes. You may ask us at any time to stop sending you marketing communications by contacting us on 1300 134 646 and we will comply with your request within a reasonable time period.
We may also share your Personal Information with the other members of Fingo Finance and our business partners for their marketing purposes. You may ask us at any time to stop doing this by contacting us on 1300 134 646 and we will comply with your request within a reasonable period.
Disclosure of personal information to third parties
If permitted under the Privacy Act, your personal information may be shared with the other members of Fingo Finance and other external entities for the purposes set out in this Policy.
To provide our products and services to you or otherwise manage dealings we have with you, we may need to interact with third parties or disclose your personal information to them. In addition, if you have been introduced to us by a third party (e.g. the broker or dealer), that party will also have access to some personal information about you. For example, we may share your personal information with:
- in addition to the initial broker or dealer that introduced you to us, other brokers or dealers;
- your representatives (including your legal advisor, mortgage broker, financial advisor, accountant, executor, administrator, guardian, trustee, or attorney);
- solicitors, financial advisors and accountants;
- data processing, storage and other technology service providers;
- call centre operators;
- payment systems operators;
- direct mailing companies;
- security registration bodies;
- record microfilming and archiving services;
- authorised representatives and credit representatives who sell products and services on our behalf;
- other organisations, who jointly with us, provide products or services to you;
- other persons who have an interest in any property offered to us as security;
- other financial services organisations (including banks, superannuation funds, stockbrokers, custodians, funds managers and portfolio service providers);
- debt collection agencies and mercantile agents;
- fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
- external dispute resolution schemes; and
- regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.
In addition, where the Privacy Act permits it, we may disclose your personal information to credit reporting bodies for the purposes contemplated by this Policy (for example, when obtaining credit reporting information about you).
Do we disclose your personal information overseas?
Some of our technology and service providers may be located overseas. This means that when we use these provider’s services, it may involve disclosing your personal information overseas. We only disclose personal information to our overseas service providers when it is necessary for the services they provide to us.
Access to personal information
You are welcome to request access to the personal information (including credit eligibility information) we hold about you by contacting us on 1300 134 646. If we deny your request for access to the personal information we hold about you, we will give you a notice explaining our reasons except where it would be unreasonable to do so.
We will respond to your request to correct or access the personal information that we hold about you within a reasonable time, usually within 30 days.
You may not be able to access all information we hold about you. There are some exemptions at law which will impact our ability to provide you with access to all of the personal information we hold about you all of the time. For example:
- where access to the personal information would have an unreasonable impact on the privacy of others;
- if the request is frivolous or vexatious;
- where there are existing or anticipated legal proceedings and the information is “privileged”;
- in some instances the access can be denied under law or by a law enforcement agency; or
- where the information would reveal evaluative information in connection with a commercially sensitive decision-making process.
Complaints and dispute resolution
If you believe that we have not complied with our obligations under the Privacy Act (including those under Part IIIA of the Privacy Act) or the CR Code in relation to the way in which we manage personal information about you, you can make a complaint to the Privacy Officer via the contact details listed below.
You will receive an acknowledgement of receipt of your complaint from us as soon as reasonably practicable after we receive it and in any case within 7 days after receipt. We will let you know if we need any further information from you to resolve your complaint.
We investigate all complaints and will respond to you as soon as reasonably practicable. We aim to resolve your complaint within 30 days after we receive your notice. If we cannot resolve your complaint within this period we will write to you notifying you as to the reasons why, specifying when we expect the matter to be resolved and seeking your agreement to extend the 30 day period. If you do not agree with this extension of time we may not be able to resolve your complaint.
If you are not happy with the way we deal with your complaint, you may refer the complaint to:
- our external dispute resolution service:
- Australian Financial Complaints Authority (AFCA)
GPO Box 3
Melbourne VIC 3001
Phone: 1800 931 678
- the Office of the Australian Information Commissioner
PO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
If you would like to find out more information about our Policy and practices, please contact our Privacy Officer:
10-14 Cochranes Road
Moorabbin VIC 3189
Phone: 1300 134 646