Credit Reporting Policy

Introduction 

We may provide business or commercial credit (including but not limited to extended payment terms) to our customers in connection with our services.  As a result, we may collect credit information and credit eligibility information (credit-related information) about you as referred to in the Privacy Act 1988 (Cth) (“Act”).  This Credit Reporting Policy relates to us and to our related entities that are deemed to be credit providers for the purposes of the Privacy Act, and sets out how we manage credit-related information about individuals.  It does not apply to the collection or use of credit-related information about corporations.

How we collect and hold credit-related information about you

Primarily, we collect credit-related information about you directly from you, and from your business dealings with us (including but not limited to any credit-related information provided to or derived by us in the normal course of operation of your Account).

We may also collect credit-related information about you in any of the circumstances relating to other personal information described in our Privacy Policy under the heading “Kinds and Collection of Personal Information”, if such collection is permitted under the Act, the Credit Reporting Privacy Code, and any other regulations or instruments made under the Act (collectively “Privacy Laws”).

Since we only provide business or commercial credit (rather than consumer credit) as part of our business, we do not hold an Australian Credit Licence (“ACL”) under the National Consumer Credit Protection Act 2009 (Cth).  We are also not a member of a recognised external dispute resolution scheme (“EDR”).  As such, we will only collect credit-related information about you from third parties if such collection is permitted by the Privacy Laws and with your consent, if such consent is required under the Privacy Laws).

We store and safeguard your credit-related information in the ways described in our Privacy Policy under the heading “Storage of Collected Information”.

How we use and when we disclose your credit-related information

As a provider of business or commercial credit only, a non-holder of an ACL and a non-member of an EDR, we will not use your credit-related information or disclose any such information (including any disclosure to any credit reporting body) if such use or disclosure is prohibited by the Privacy Laws.

We may, however, use or disclose your credit-related information for other purposes and in other circumstances as described in our Privacy Policy under the heading “Use and Disclosure of Personal Information”, when permitted to do so by the Privacy Laws.

Our use and disclosure of credit-related information is regulated by Part IIIA of the Act and the Credit Reporting Privacy Code.  We will only use or disclose such information for purposes permitted by these laws, such as:

  • processing credit-related applications and managing credit that we provide;
  • assisting you to avoid defaults;
  • collecting amounts you may owe us in relation to such credit and dealing with serious credit infringements;
  • assigning our debts;
  • dealing with complaints or regulatory matters relating to credit or credit reporting; and
  • as required or authorised by another law.

We generally do not disclose any credit-related information about you to persons outside Australia.  However where you pay for services using a personal credit card, we may disclose your credit-related information to Stripe.com located in the USA for one or more of the purposes listed above.

How to access or correct your credit-related information

If you wish to access or correct errors in any of your credit-related information that we hold, please contact us using the contact details in our Privacy Policy under the heading “Access to and Correction of Personal Information”.

We may apply an administrative charge for providing access to your credit-related information, depending on the request.

How to make a complaint regarding our compliance with Part IIIA of the Privacy Act and the Credit Reporting Privacy Code

If you think that we have not complied with Part IIIA of the Privacy Act or with the Credit Reporting Privacy Code (which regulates credit reporting), you can make a complaint by using the contact details in our Privacy Policy under the heading “Complaints and Further Information”.

We will acknowledge your complaint in writing as soon as practicable within 7 days.  We will aim to investigate and resolve your complaint within 30 days of receiving it.  If we need more time, we will notify you about the reasons for the delay and ask for your agreement to extend this 30 day period (if you do not agree, we may not be able to resolve your complaint).

While we hope that we will be able to resolve any complaint without the need to involve third parties, if you are not satisfied with the outcome of your complaint you can make a complaint to the Australian Information Commissioner (www.oaic.gov.au).

Changes to Credit Reporting Policy

We reserve the right to modify this Credit Reporting Policy at any time, so please review it frequently.  If we make material changes to it, we will notify you by email or by means of a notice on our homepage.