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CreditorWatch Pty Limited ACN (144 644 244) (“CreditorWatch” or “we”, “our” or “us”) is bound by the Privacy Act 1988 (as amended) (“Privacy Act”), including the Australian Privacy Principles. This Privacy Policy sets out how we treat the personal information that we collect, use and disclose and our procedures regarding the handling of personal and sensitive information, including the collection, use, disclosure and storage of information, as well as the right of individuals to access and correct that information.
From time to time, we may revise or update this Privacy Policy or our information handling practices. If we do so, the revised Privacy Policy will be published on our website www.creditorwatch.com.au
CreditorWatch may collect personal information in order to conduct our business, to provide and market our services and to meet our legal obligations. By using our website or our services, or by providing any personal information to us, you consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy.
The types of personal information we may collect and hold includes (but is not limited to) personal information about:
Personal information that we collect and may hold include:
You are not obliged to provide personal information to CreditorWatch. However in many cases, if you do not provide your personal information to us, we may not be able to supply the relevant product or service that you have requested from us.
In some circumstances, you may provide to us, and we may collect from you, personal information of a third party. Where you provide the personal information of a third party, you must ensure that the third party is aware of this Privacy Policy, understands it and agrees to accept it.
If it is necessary to provide specific services to you, we may collect sensitive information about you. Under the Privacy Act, “sensitive information” includes but is not limited to information or an opinion about an individual’s racial or ethnic origin, religious belief, or criminal record and also includes health information about an individual. However, we will only collect sensitive information from you if you agree to provide it to us, you authorise us to obtain it from a third party or where the collection of the information is required or authorised by or under an Australian law or a Court/Tribunal order or otherwise where the collection is not prohibited under the Privacy Act. We will only use sensitive information in accordance with the Privacy Act and for the purpose for which it is provided.
We collect personal information in the following ways:
We may also collect information about you from third party suppliers and government database services.
We store personal information in computer storage facilities and paper-based files. We take steps to protect your personal information against loss, unauthorised access, use modification or disclosure. Some examples of the steps we take to protect your personal information include:
Information that may identify you as a user may be gathered during your access with our website.
Our website includes pages that use ‘cookies’. A cookie is a unique identification number that allows the server to identify and interact more effectively with your computer. The cookie assists us in identifying what our users find interesting on our website.
A cookie will be allocated each time you use our website. The cookie does not identify you as an individual in our data collection process, however it does identify your Internet Service Provider.
You can configure your web browser to refuse cookies. If you do so, you may not be able to use all or part of our website.
CreditorWatch, or its related body corporates in the ATI Group, may collect some personal information that is a government related identifier.
Personal information from identity documents may be provided to the document issuer or official record holder via third party systems for the purpose of confirming your identity, for example, the Australian Government’s Document Verification Service (DVS). Where CreditorWatch does collect government related identifiers, they are maintained on a separate database for audit and compliance purposes.
CreditorWatch may use or disclose a government related identifier where:
We collect, hold, use and disclose personal information for a variety of business purposes including:
We also collect, hold, use and disclose your personal information to:
If you do not wish to disclose your personal information for the purpose of direct marketing or you would like to opt-out of receiving direct marketing communications, you can do so by contacting the CreditorWatch Privacy Officer using the contact details set out below, or by following the instructions to unsubscribe which are contained in a communication that you receive from us.
The ATI Group and Related Companies
The ATI Group includes our parent company Australian Technology Innovators Pty Ltd, LEAP Legal Software Pty Ltd, InfoTrack Group Pty Ltd and their subsidiaries, CNCNA Pty Ltd (trading as eCompanies), InfoTrack Limited (NZ), InfoTrack Group Limited (UK) and its subsidiaries, and LotSearch Pty Ltd. Different companies within the ATI Group provide different services.
The ATI Group may share information with our integration partners to ensure the smooth running of the services which we, and they, provide. These partners include Sympli Pty Ltd, Practice Evolve Group Pty Ltd and its subsidiaries, Legal Software Developments Pty Ltd and its subsidiaries, and other partners as mentioned on our website and updated from time to time. At times, we may need to provide personal information to them to help them run their businesses or for reporting purposes. We may also share your personal information within the wider Australian Technology Innovators Pty Ltd group companies (ATI Group) and with our service providers for the purposes outlined above.
Third Party Service Providers
We may disclose your personal information to third party service providers who assist us in providing the services you request, including public authorities and providers of information services.
We may also disclose your personal information to third parties who work with us in our business to promote, market or improve the services that we provide, including:
We may also combine your personal information with information available from other sources, including the entities mentioned above, to help us provide better services to you.
Where we do share information with third parties, we require that there are contracts in place that only allow use and disclosure of personal information to provide the service and that protect your personal information in accordance with the Privacy Act. Otherwise, we will disclose personal information to others if you’ve given us permission, or if the disclosure relates to the main purpose for which we collected the information and you would reasonably expect us to do so.
As a credit reporting agency, we may share your credit information in accordance with industry consumer credit reporting standards including:
These standards ensure that your personal information in relation to your consumer credit is managed regarding:
We do not presently disclose personal information to any organisations located overseas; however, we do disclose information in Australia, for the purposes described above, to some multinational organisations that are located both in Australia and overseas, including the United Kingdom, the United States and New Zealand.
If you are a resident of the European Union for the purposes of the GDPR, then in addition to what is set out above, the following applies to you.
CreditorWatch is a data controller and processor for the purposes of the GDPR and by your consenting to this Privacy Policy, CreditorWatch is able to process your Personal Information in accordance with this Privacy Policy.
In providing services to you, CreditorWatch may make use of a number of automated processes using your Personal Information and your activity on our site as tracked by us, in order to provide more tailored and relevant services to you.
In addition to your rights set out above, you may update or rectify any of your Personal Information that we hold about you, in the manner described in the “How you can access your personal information” paragraph above.
You have a right to request access to your personal information which we hold about you and to request its correction. You can make such a request by contacting the CreditorWatch Privacy Officer using the contact details set out in this policy.
We will respond to any such request for access as soon as reasonably practicable. Where access is to be given, we will provide you with a copy or details of your personal information in the manner requested by you where it is reasonable and practicable to do so.
We will not charge you a fee for making a request to access your personal information. However, we may charge you a reasonable fee for giving you access to your personal information.
In some cases, we may refuse to give you access to the information you have requested or only give you access to certain information. If we do this, we will provide you with a written statement setting out our reasons for refusal, except where it would be unreasonable to do so.
We will take such steps (if any) as are reasonable in the circumstances to make sure that the personal information we collect, use or disclose is accurate, complete, up to date and relevant.
If you believe the personal information we hold about you is inaccurate, irrelevant, out of date or incomplete, you can ask us to update or correct it. To do so, please contact us using the contact details listed below.
If we refuse your request to correct your personal information, we will let you know why. You also have the right to request that a statement be associated with your personal information that says you believe it is inaccurate, incomplete, irrelevant, misleading or out of date.
If you have any questions about this Privacy Policy, if you wish to correct or update information we hold about you or if you wish to request access or correction of your personal information or make a complaint about a breach by CreditorWatch of the Australian Privacy Principles (including the way we have collected, disclosed or used your personal information), please contact:
CreditorWatch Privacy Officer GPO Box 4029 Sydney NSW 2001 privacy@creditorwatch.com.au 1800 738 524
We will acknowledge and investigate any complaint about the way we manage personal information as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations. If you are unhappy with our handling of the complaint, you may contact the Australian Information Commissioner.
Last update: 29 May 2019
Moffat Group Pty Ltd (ACN 069 691 407) and its subsidiaries, related entities and affiliates (together, “Moffat”, “we”, “our” or “us”) respect your privacy and we are committed to compliance with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (‘APP’s’). This Privacy Policy has been issued under APP 1. It describes what happens to Personal Information we collect in respect of:
?Please take a moment to read this Privacy Policy as it sets out our information handling practices, what information we hold about you and how we collect, use, disclose, keep secure and ultimately destroy that information, through our websites at:
1. What Personal Information we collect from you For the purpose of this Privacy Policy, “Personal Information” is information or an opinion about you, whether true or not, which identifies you or from which your identity can reasonably be ascertained. The type of Personal Information collected by us may differ depending on whether you are or would like to become a client, supplier, employee or independent contractor. The type of Personal Information we may collect includes (but is not limited to) your name, date of birth, address, mobile and telephone numbers, facsimile number and email address. If applicable, we may also require details of your company’s ABN and/or ACN, financial information including bank account and credit card details, profit and loss statements, balance sheets, your employer details and your occupation. The Personal Information we collect is what is required for us to be able to provide you with our products and services, to manage and administer the product and service, to assess your application for credit and for incidental purposes. Where you do not wish to provide us with your Personal Information, we may not be able to provide you with requested products or services. However, where it is unnecessary to collect Personal Information for the purposes of certain activities (for example when taking a survey), you have the option of not identifying yourself or using a pseudonym. We will collect your Personal Information in a fair and lawful manner, and not in an unreasonably intrusive way. All Personal Information that is collected will be stored on our electronic server, internal computers and in hard copy files. Where practical, we collect Personal Information directly from you. There may be circumstances in which we collect Personal Information about you from publically available sources and from third parties, including from financial institutions and credit reporting agencies when you apply for credit. We destroy or permanently de-identify your Personal Information when it is no longer necessary for its purpose and we are not required by law to keep it. 2. How do we collect your Personal Information? We will collect your Personal Information in a number of ways including:
Through our websites we can obtain your Personal Information if you send such information in an email or when you complete an on-line enquiry. When you look at our websites, we may make a record of your visit. The following information may be logged for statistical purposes:
Tracking technologies such as cookies may be used on our website to recognise a user’s browser each time that user visits our websites. Cookies are pieces of information that a website transfers to a computer’s hard disk for record keep purposes. Most web browsers are set to accept tracking technologies such as cookies. These tracking technologies do not purposefully identify the user. If you do not wish receive any cookies you may set your browser to refuse them. However, your use of our websites may be affected. Please note that our website does not provide systems for secure transmission of Personal Information across the Internet except where otherwise indicated. You should be aware that there are inherent risks in transferring Personal Information over the Internet and that we accept no responsibility for Personal Information provided in unsecured websites. 3. Use and disclosure of your Personal Information We collect and use your Personal Information for purposes that relate to:
We will not use or disclose your Personal Information for any other purpose unless you have consent to that use or disclosure. Your Personal Information may be shared between Moffat and its related entities. If you do not wish to receive marketing information you can opt out by contacting our Privacy Officer. Normally we will not disclose your Personal Information to third parties unless:
We will not sell, rent or trade your Personal Information without your prior consent where that consent is required by law. However, by trading and communicating with us, you consent to our use and disclosure of your Personal Information incidental to a sale of our business to a third party or where we outsource duties including database management to an external service provider for the purpose of rendering the required services. We, and our agents, will only use and disclose your Personal Information in accordance with our purposes listed above and as permitted by the APP’s and the Privacy Act. 4. Your consent You consent to your Personal Information being used in accordance with this Privacy Policy by requesting our services or those of our sub-contractors by making enquiries via telephone or by visiting our websites or participating in an on-line enquiry. We will endeavour not to use or disclose your Personal Information in a way, which is unreasonable contrary to your expectations. If you would prefer that we not use your Personal Information in any way set out in this Privacy Policy please contact us. However, you should be aware that if you do not consent to certain uses and disclosures of your Personal Information, we may not be able to provide our products and services to you. 5. Quality of your Personal Information We rely upon the accuracy of your Personal Information to provide our products and services to you. To assist us with this, please contact us immediately if any of your Personal Information ceases to be current. Similarly, if for any reason you believe that the information we have about you is not accurate and complete, contact us and we will make the appropriate correction. If we believe that the information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will make the appropriate correction. If your Personal Information that we have previously disclosed to another APP Entity is corrected on our records, at your request we will notify that other APP Entity of the correction. We will endeavour to respond to your request within a reasonable period after the request is made and may, if permitted by law, refuse to change our records of your Personal Information. If this occurs, we will provide you with reasons why this has occurred. 6. Access to Personal Information You may access the Personal Information that we hold about you upon request and on reasonable notice. However there are some circumstances in which we may refuse to provide access or only provide partial access to this information. If your request for access is not granted, we will explain our reasons to you. A nominal fee may apply to enable us to recover the reasonable costs of making such information available to you. 7. Security of your Personal Information We regard the security of your Personal Information as paramount. To this end, we take all reasonable steps to protect your Personal Information from loss, interference, misuse, unauthorised access, modification or disclosure. Only authorised people within our organisation are entitled to access your Personal Information for approved purposes. All our employees and agents are requires to sign a confidentiality agreement as a condition of their employment. 8. Changes to our Privacy Policy From time to time we may decide to amend or update this Privacy Policy. When this occurs we will post the new version of the Privacy Policy on our website. We encourage you to periodically view this Privacy Policy so that you remain informed as to how we are protecting your Personal Information. 9. Transfers of Personal Information overseas As the internet is a global environment, using the internet to collect and process Personal Information necessarily involves the transmission of that information worldwide. We will also share your Personal Information with the members of Moffat which are located in Australia, New Zealand, the United Kingdom and the United States of America. By trading and communicating with us, you acknowledge and agree to us using and disclosing your Personal Information in this way. 10. How to contact us Should you have any queries or concerns in relation to our information handling practices, or if you wish to discuss any aspect of this policy, please do not hesitate to contact our Privacy Compliance Officer Peter R Barnes on +61 3 9518 3888 or fax us on +61 3 9518 3818. You may also write to us at: Moffat Pty Limited 740-742 Springvale Road Mulgrave VIC 3170 Attn: Peter R Barnes E-mail: peter.barnes@moffat.com.au 11. How we handle complaints Any complaint made to us in connection with this privacy policy and our information handling practices will be directed to our General Manager - Finance where it will be assessed giving due regard to the nature of your complaint, your circumstances and our ability to address the issue in question. Irrespective of our decision, we will respond to your complaint within a reasonable period of time.