Express Commission Australia Pty Ltd
ACN 127 295 176
This Policy describes how we comply with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), (together, the Privacy Act).
Words which are defined in the Privacy Act have the same meaning in this Policy. The words “information” and “personal information” are used interchangeably in this Policy.
This Policy also sets out how we manage personal information and credit-related personal information about individuals. Individuals include clients to whom we may provide or may have provided our services, guarantors of both individual and company clients and individuals who are or become customers of our clients.
As part of our Standard Terms of Service, we require all our clients to acknowledge this Policy.
We may make alterations or additions to this Policy from time to time. Should we do so, we will update the Policy on our website (https://expresscommission.com.au/privacy-policy/).
Protecting your privacy
Your privacy is important to us. As our client, or a guarantor, or someone in a business relationship with our client, we respect your right to be aware of who has information about you. We will act to protect the privacy, accuracy and security of your information in accordance with the APPs.
You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific or relates to your personal information we will need to identify you.
Personal information we collect
We may collect and hold information about you such as:
- name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and email) and financial information;
- government identifiers such as driver licence numbers and tax file numbers;
- the type of commercial credit and the amount of credit sought in an application;
- court proceedings information (other than criminal proceedings) that relate to any credit provided;
- personal insolvency information;
- sensitive information;
- any dealings with other credit providers;
- consumer credit liability information, default information, payment information, new arrangement information and publicly available information concerning consumer credit; and
- credit-related personal information/credit worthiness information that credit reporting bodies provide (this could include credit scores, risk ratings and other evaluations).
Unsolicited personal information
If we receive unsolicited personal information about you, we will as soon as practicable, but only if it is lawful, securely destroy it or assure it is de-identified.
How we collect personal information
We collect personal information in a variety of ways. We will collect information from you when you knowingly provide it to us by telephone, in person or in documentation such as an application (which may be an on-line application). We may also obtain information from another credit provider, a referee, an employer or a government body or from persons acting on your behalf (such as a broker, agent, accountant or lawyer), or from a person selling your debt to us.
We only obtain credit reporting information from credit reporting bodies to the extent we are entitled to obtain it under the Privacy Act. We might, for example, need to obtain your prior authorisation.
We will only collect sensitive information with your consent or when permissible under Australian law.
Why we collect personal information
We collect, hold, use and disclose information for purposes which are reasonably necessary for our business activities (including the management and administration of the services we provide and to assess credit applications), or to comply with laws (as they may be amended and including any associated regulations).
Disclosure of personal information
We may disclose information to comply with the law.
We may disclose personal information to the following credit reporting body:
Equifax Australia Information Services and Solutions Pty Ltd (Equifax)
In order to provide, manage and administer our services we may disclose information (before, during or after the provision of our services) to:
- related companies of ours;
- credit reporting bodies (to the extent allowed under the Privacy Act);
- other credit providers, underwriters and insurers;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- any contractor or service provider engaged by us (who will be required to comply with the APPs);
- persons who may act as guarantors for you;
- persons acting on your behalf (such as a broker, agent, accountant or lawyer), or to a person selling your debt to us;
- debt collectors and assignees of your debts;
- external dispute resolution schemes;
- our professional advisors including lawyers, bankers, accountants and auditors (including when we deem necessary to protect, defend and enforce our rights under any agreement entered into);
- other third parties to meet the purpose for which it was submitted or where we have your consent;
Disclosure of personal information to overseas recipients
We do not generally disclose information to overseas recipients or to persons that do not have an Australian link. However, we may do so. For example, we may use service providers located overseas. Any overseas service provider that we may use will be required to have systems and procedures that are equivalent to the APPs.
We may use personal information to tell you about our products or services. If you do not want your information used for these direct marketing purposes you should tell us. You can “opt-out” of our direct marketing by contacting us at the “Contact us” address provided below.
Security and how we store personal information
We take all reasonable steps to ensure that information we hold is protected from misuse, interference or loss and from unauthorised access, modification or disclosure. We do this by having physical, electronic and procedural safeguards which protect the information we hold. Information on our computer servers is maintained by an Australian service provider (in a controlled secure environment) who also adheres to the APPs. Our staff are required to maintain the confidentiality of personal information. We securely destroy or permanently de-identify information once it is no longer needed.
Storage and security of uploaded files
Your personal profile and Advance requests will require certain files to be uploaded (whether by you or Express Commission Australia). These files are uploaded and stored in our private and secure cloud file storage service hosted by Google Cloud. To mitigate any risk of access by unauthorised parties we do not store these files at our website hosting service.
Access to and correction of personal information we hold
You are entitled to access the information which we hold about you, and if you consider that any such information is incorrect in any way, you may ask us to correct it. We will need to verify your identity before giving you access. We will usually provide the information requested within 30 days of receiving your request. If there is a reason we are unable to agree to a request for access or a correction we will advise you in writing.
There is no charge to make a request for access but we may apply an administration fee for providing access in accordance with your request.
To seek access or a correction please use the “contact us” address provided below.
If you believe that we have failed to comply with this Policy, please contact us and we will then follow our internal Dispute Resolution Policy. We will attempt to resolve any complaint within 5 working days of receipt. If resolution is not possible within this time-frame we will advise you in writing.
To lodge a complaint please write to us at the “Contact us” address provided below.
If the complaint remains unresolved, you may refer the matter to the Office of the Australian Information Commissioner (OAIC).
The contact details for the OAIC are:
When you visit our website, we or agencies on our behalf and/or our internet service provider may monitor and log your visit. Any data so obtained is kept strictly confidential.
Copies of this Policy
You may ask us to provide you with a copy of this Policy, including a hard copy. To do so please use the “Contact us” address provided below. We will happily provide you a copy at no charge.
For all privacy related matters please contact Express Commission at:
The Privacy Officer
Express Commission Australia Pty Ltd
P.O. Box 2087
Wattletree Road Post Office
Malvern East, Victoria 3145
Phone: 1300 738211