Privacy Policy

OUR COMMITMENT TO PROTECT YOUR PRIVACY

Grenwich Pty Ltd ACN 631 869 817 Australian Credit Licence 518739 (Grenwich, we, us, our) has purchased the book of loans made by portfolio of loans advanced by Membo Finance Pty Ltd ACN 159 693 464 Australian Credit Licence 428415 trading as ‘ClearLoans’ (ClearLoans). 

In this Privacy Policy references to ‘Grenwich’, ‘we’, ‘us’ or ‘our’ refer to Grenwich and its related bodies corporate.   

In this Privacy Policy references to:

  • ‘Personal Information’ refers to ‘personal information’ as defined in Privacy Act (including ‘sensitive information’;

  • ‘Privacy Act’ refers to the Privacy Act, 1988 (Cth) (including the Australian Privacy Principles (APPs)) and any applicable APP Code and any other relevant law; and

  • ‘Privacy Policy’ refers to this document. 

 

PERSONAL INFORMATION

When we refer to Personal Information we mean information or an opinion about an individual, from which that individual is, or may reasonably be, identified.  Such information may be collected directly from the individual or may be collected indirectly. 

This information may include the individual's name, date of birth, driver's licence number, marital status, number and age of your dependants, phone number, email address, address, nationality and employment history. 

The Personal Information we collect about you may also include credit information about you.  Credit Information is information which is used to assess your eligibility for a loan and may include information about your income, assets, liabilities and repayment history information.  The kinds of Credit Information that we may collect about you include

  • information about consumer credit loans that you currently have applied for including:

    • repayment history information,

    • the type and amount of credit sought in each application;

    • default and payment information,

    • information about any court proceedings; and

    • information about your personal insolvency; and

    • information about loans which you may have applied for. 

Personal information also includes sensitive information.  Sensitive Information includes information about an individual's health, medical history, race or ethnic background, their religion, trade union membership, political opinion, sexual preference or criminal record.  It also includes biomentic and genetic information (such as copies of face, fingerprints, iris, palm, signature or voice). 

 

WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies to all products and services provided to you by Grenwich.  It also includes all Personal Information that we may collect about you when you access our website. 

Any Personal Information that we collect about you will only be collected, used or disclosed as set out in this Privacy Policy, where we have your consent to do so, or as otherwise required or authorised by law.

However, our website may also contain links to third party websites.  A link to another website does not mean that we endorse or approve the information on that website.  If you link to a third party’s website through our website, this Privacy Policy does not apply to the collection, use or disclosure of your Personal Information by that third party.  You should contact that third party to obtain relevant information about how they use and disclose Personal Information about you that they collect. 

 

WHY WE COLLECT YOUR PERSONAL INFORMATION

We collect and receive Personal Information about you in order to conduct our business and to provide our services, including managing and making our loans.  We also collect Personal Information about you to enable us to directly marketing of our products and services.  If you apply for employment with us we may also collect Personal Information about you.

 

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Personal Information may be collected by us in a number of circumstances, including when you:

  • apply to become a customer of Grenwich or apply for one of our products or services; or

  • we undertake a credit check on you in response to your application for a loan; or

  • communicate with us via our website, email or phone calls; or

  • attend an event hosted by us; or

  • apply for employment with us; or

  • provide us with feedback or make a complaint;

Where reasonable and practical we will collect Personal Information about you directly from you or one of your representatives or from publicly available information.  However, we will also collect Personal Information about you from third parties, such as a partner or spouse who contacts us on your behalf, from our contractors who supply services to us, from advisers such as accountants or lawyers or other organisations authorised by you. 

Further, when you access our website, we may also collect Personal Information about you using ‘cookies’.  ‘Cookies’ are files that are implanted in your hard drive or device to collect, store and receive identifiers and information about your usage of our websites as well as information about where you are located at the time you access our websites (using GPS, Bluetooth, or WiFi signals, depending on the permissions that you have granted). By using ‘cookies’ we are able to enhance and personalise our websites to better suit your needs. 

Generally, we will not collect Sensitive Information about you, unless such information is required in order to process an application for a product or service provided by us.  We will only collect Sensitive Information about you with your consent.

If you provide Personal Information to us about another individual or about an entity with which you are associated, you must ensure that you are entitled to disclose that Personal Information to us and that, without us taking any further steps required by privacy laws or by our general duty of confidentiality, we may collect, use and disclose such Personal Information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure any individual concerned is aware of the various matters detailed in this Privacy Policy. Any such individual or entity must also provide the consents set out in this Privacy Policy in respect of how we will deal with their Personal Information.

If you do not provide any Personal Information requested by us, we may not be able to provide you with our services.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use Personal Information provided to us for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your Personal Information for the following purposes:

  • to improve our website;

  • to provide you with the products or services you requested;

  • to verify your identity;

  • to provide you with information about our products and services;

  • to assess, process and manage your application for a product or service offered by us, including to verify your details and assess our risk;

  • to assess, process and manage your application for employment; or

  • for complaints handling or data analytics purposes; or

  • for security, quality assurance and training purposes.

 

In particular, when assessing an application to be a borrower or guarantor, we may use your Credit- Information for the purposes of assessing the application, assessing your credit-worthiness or managing the finance provided to you. 

You agree that we may use your Personal Information for any of these purposes.

TO WHOM WILL WE DISCLOSE YOUR PERSONAL INFORMATION?

To enable us to maintain a successful business relationship with you, we may disclose Personal Information about you to:

  • organisations that provide products or services used or marketed by us, including:

    • other credit providers and financial institutions;

    • valuers;

    • surveyors,

    • credit reporting bodies,

    • rating agencies; and

    • debt collectors;

    • your employer/s or referees, your guarantors, your professional advisors, your bank and any other organisation that may have or is considering having an interest in our business or a product provided by us;

    • companies and contractors who we retain to provide services for us, such as IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your Personal Information to provide those services;

    • people considering acquiring an interest in our business or assets; and

    • other individuals or companies authorised by you

 

By providing us with your Personal Information, you consent to us disclosing your Personal Information to such entities without obtaining your consent on a case by case basis.

With your consent, we may also disclose your Personal Information to organisations which may assist us to electronically verify your identity (including credit reporting bodies and Document Verification Services (DVS)). 

Sometimes we are required or authorised by law to disclose your Personal Information to a Court, Tribunal, law enforcement agency, a regulator (such as ASIC or AUSTRAC) or to the Australian Taxation Office.  From time to time, we may also be required to provide Personal Information about you to a foreign law enforcement agency or foreign regulator.  We do not need to obtain your consent to provide your Personal Information to such official bodies. 

Some of our third party service providers (including our information technology service providers) may located in countries outside of Australia, including New Zealand and countries in North America, South America, Asia, the United Kingdom or Europe.  Our contracts with our third party suppliers generally include an obligation for the supplier to comply with the Privacy Act and with this Privacy Policy.

However, not all countries have the same high standards for the protection of your ‘personal information’ as Australia and some of our third party service providers are located in countries that do not have laws that provide the same level of protection as the laws of Australia.  By providing us with your Personal Information, by using our website or by asking us to provide you with our products or services, you specifically consent to us sending your data out of Australia to other countries which may include New Zealand and countries located in North America, South America, Asia, the United Kingdom or Europe and to the cloud.

NOTIFIABLE MATTERS

We may provide your Credit Information to a credit reporting body.  The credit reporting body may provide the information that we report about you to other credit providers to assist them to assess your credit worthiness.  We may also obtain information that other credit providers have provided to the credit reporting body to use in our assessments of your credit-worthiness.

If you fail to meet your payment obligations in relation to any loan that we have provided to you, or any loan that we have arranged for you, or if you commit a serious credit infringement, we may report this to the credit reporting body. 

You may access the Credit Information that we hold about you. Please refer to the section titled ‘Access to your Personal Information’ below.  You may also request that we correct any Credit Information that we hold about you if you believe the information is incorrect.  Please refer to the section titled ‘Updating your Personal Information’ below. 

The information that we provide to a credit reporting body may sometimes be used for ‘pre-screening’ of direct marketing offers to be made by another credit provider.  You may contact the credit reporting body to request that your Credit Information is not used in this way. 

You may also contact the credit reporting body to request that they not use or disclose the credit-reporting information they hold about you if you consider that you may have been a victim of fraud or if you believe on reasonable grounds that the information they hold about you is incorrect.  The credit reporting body must not use or disclose your Credit Information for a period of 21 days after receiving your notice. 

For further information, contact the following credit reporting bodies at:

 

DIRECT MARKETING

From time to time we may use your Personal Information to provide you with current information about products and services, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your Personal Information, you consent to us using your Personal Information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.

If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Officer on the contact details below. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

UPDATING YOUR PERSONAL INFORMATION

It is important to our relationship that the Personal Information we hold about you is accurate and up to date. During the course of our relationship with you we will ask you to inform us if any of your Information has changed.

If you wish to make any changes to your Personal Information (including your credit related Personal Information) that we hold about you, or if you think any such Personal Information we hold about you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the Personal Information we hold about you is inaccurate or incomplete.

ACCESS TO YOUR PERSONAL INFORMATION

We will provide you with access to the Personal Information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the Personal Information we hold about you, including any credit-related Personal Information or phone recordings we hold about you, at any time.

To access Personal Information that we hold about you, use the contact details specified below.  We may charge a fee for our reasonable costs in retrieving and supplying the information to you.

DENIED ACCESS TO PERSONAL INFORMATION

There may be situations where we are not required to provide you with access to your Personal Information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.

An explanation will be provided to you if we deny you access to your Personal Information we hold.

BUSINESS WITHOUT IDENTIFYING YOU

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where, it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with Personal Information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.

FOR HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will only keep Personal Information that we hold about you while we need it or while we are required by law to keep it.  Once we no longer need your Personal Information, we will take all reasonable steps to destroy it or to de-identify it.  

At any time we hold your Personal Information, we will only use and disclose as set out in this Privacy Policy. 

HOW SAFE AND SECURE IS THE PERSONAL INFORMATION THAT WE HOLD?

We will take reasonable steps to protect your Personal Information, by storing it in a secure environment, and when the Personal Information is no longer needed for any purpose for which the Personal Information may be used or disclosed, it will be destroyed or permanently de-identified.

We will also take reasonable steps to protect any Personal Information we hold about you from misuse, loss and unauthorised access, modification or disclosure.

If a data breach involving your Personal Information occurs, or we suspect that a data breach has occurred, whether the entity experiencing the data breach is Grenwich or third parties we use, such as contractors or subcontractors, we will expeditiously conduct an investigation and assessment.

Based on this assessment, we will determine whether any steps need to be taken by us to ensure your Personal Information is not accessed by unauthorised persons or whether we need to notify you with recommendations about the steps that you should take in response to the data breach.

If there is a serious data breach we will tell you about any action we have taken, or we are intending to take, to prevent reoccurrence.

FURTHER INFORMATION AND COMPLAINTS

You may request further information about the way we manage your Personal Information or lodge a complaint by contacting our Privacy Officer(s) on the contact details below:

CONTACT DETAILS

You can contact us by calling us on 0485 866 236 or by emailing our Privacy Officer on help@grenwichloans-au.com.

We will deal with the complaint by investigating the complaint, and providing a response to the complainant within 15 business days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree alternative time frames with you.

ALTERNATIVE FORMS OF OUR PRIVACY POLICY

If you would prefer to receive a copy of our Privacy Policy, including the ‘Notifiable Matters’ in an alternative form (such as in hard copy or via email), please contact us on the phone number or email address provided under the section titled ‘Contact Details’ above.  We will be pleased to comply with your request.  

CHANGE IN OUR PRIVACY POLICY

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.

As a consequence we may change this Privacy Policy from time to time or as the need arises.

This Privacy Policy was last updated in February 2022.