Privacy Policy

General

As part of C1 Finance Pty Ltd’s (“C1 Finance”) commitment to maintaining the highest levels of professional integrity and ethical conduct, C1 Finance has adopted this Privacy Policy (“Policy”) to manage Personal Information in an open and transparent manner.

This Policy assists C1 Finance in complying with the requirements of the Privacy Act 1988 (Cth), the Australian Privacy Principles (“APPs”), Part IIIA of the Privacy Act (credit reporting), and the Credit Reporting Privacy Code (“CR Code”) in protecting the Personal Information C1 Finance holds about its clients.

This Policy applies to all representatives and employees of C1 Finance at all times and the requirements remain in force on an ongoing basis.

What We Collect

Personal Information

The Personal Information C1 Finance collects may include any information from which your identity is reasonably apparent (such as your name, address, date of birth and contact details). C1 Finance will only collect Personal Information where it is reasonably necessary for one or more of its functions or activities.

Sensitive Information

Sensitive Information may include racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, and health information. C1 Finance must not collect Sensitive Information about you unless:

• a) you consent to the collection and the information is reasonably necessary for one or more of C1 Finance’s functions or activities;
• b) the collection is required or authorised by or under an Australian law or a Court/Tribunal Order; or
• c) a permitted health situation exists in relation to the collection.

Credit-Related Information

Where C1 Finance receives a request for credit, you will be required to provide Credit Information. Under Australia’s comprehensive credit reporting regime, this may include:

• Identification information (name, date of birth, address, driver’s licence, marital status, dependents);
• Details of current and previous credit accounts, including credit limits;
• Repayment history information and records of whether you meet your scheduled repayments on time;
• Bank account details, transactional and trading history;
• Default information, payment clearances and new arrangement information;
• Court judgments and serious credit infringement information;
• Credit enquiry information.

Refer to C1 Finance’s Credit Reporting Policy (available at www.c1carloans.com.au) and the Comprehensive Credit Reporting section below for further information.

How We Collect

C1 Finance will only collect Personal Information by lawful and fair means, and generally only directly from you unless it is unreasonable or impracticable to do so, or you have asked us to liaise with someone else on your behalf.

C1 Finance will collect Personal Information from you when:

• a) you complete C1 Finance’s Application Form;
• b) you provide supporting or additional information to our representatives — over the telephone, by email or text, or by submitting information through the C1 Finance website;
• c) you provide information in connection with a complaint or enquiry.

Collecting information about you from someone else: We may also collect personal information about you from third parties, including credit reporting bodies, credit providers, employers or other organisations, when assessing your credit application or collecting a debt you owe.

If C1 Finance determines it should not have collected certain Personal Information and that information is not contained in a Commonwealth record, C1 Finance will, as soon as practicable, destroy or de-identify that information where it is lawful and reasonable to do so.

Why We Collect

If you are acquiring or have acquired a product or service from C1 Finance, your Personal Information will be collected and held for the purposes of:

• a) checking whether you are eligible for C1 Finance’s products or services;
• b) disclosing your Credit Information to any of C1 Finance’s related companies assisting in providing credit;
• c) providing you with C1 Finance’s products or services;
• d) managing and administering C1 Finance’s products or services;
• e) assessing your application and managing your account with us;
• f) assessing your creditworthiness;
• g) engaging a credit reporting body to conduct a credit and reference check;
• h) disclosing repayment history information and other credit information to credit reporting bodies under Australia’s comprehensive credit reporting regime (see Comprehensive Credit Reporting section below);
• i) collecting payments owed to C1 Finance in respect of credit previously provided to you;
• j) research purposes to improve our website, products or services;
• k) any other customer support purposes;
• l) notifying credit providers of a default by you of your agreement with us;
• m) protecting against fraud, crime or other activity which may cause harm;
• n) responding to a complaint;
• o) where you otherwise expressly consent to the use or disclosure;
• p) complying with legislative and regulatory requirements in any jurisdiction;
• q) statistical purposes.

C1 Finance may also use Personal Information to let you know about products or services that might better serve your needs or other opportunities that may interest you (see Direct Marketing section below).

Collection required by law: Collection of some personal information may also be required or authorised by Australian law, including:

• the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) — which requires us to collect personal information about you when verifying your identity;
• the National Consumer Credit Protection Act 2009 (Cth) — which requires us to make inquiries about you when assessing a credit application; and
• the Personal Property Securities Act 2009 (Cth) — under which we may need to collect personal information to record a security interest on the Personal Property Securities Register.

When Do We Disclose Information?

• C1 Finance will not use or disclose your Personal Information unless:
  • a) you have consented to the use or disclosure;
  • b) you would reasonably expect C1 Finance to use or disclose the information for a related secondary purpose;
  • c) the use or disclosure is required or authorised by or under an Australian law or a Court/Tribunal Order;
  • d) a Permitted General Situation exists in relation to the use or disclosure; or
  • e) C1 Finance reasonably believes the use or disclosure is reasonably necessary for one or more enforcement-related activities conducted by or on behalf of an enforcement body.

Where C1 Finance discloses Personal Information under paragraph (e) above, it will keep a written record of that disclosure.

Who Do We Disclose Information To?

• C1 Finance may disclose Personal Information collected from clients and prospective clients to:
  • a) organisations involved in maintaining, reviewing and developing C1 Finance’s business systems, procedures and infrastructure, including testing or upgrading computer systems;
  • b) organisations involved in a corporate reorganisation;
  • c) organisations involved in the payments system, including financial institutions, merchants and payment organisations;
  • d) organisations involved in product planning and development;
  • e) other organisations who jointly with C1 Finance provide its products or services;
  • f) authorised representatives who provide C1 Finance’s products or services on its behalf;
  • g) your representatives, including your legal advisers;
  • h) debt collectors and assignees of your debts;
  • i) C1 Finance’s financial advisers, legal advisers or auditors; fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
  • j) external dispute resolution schemes;
  • k) regulatory bodies, government agencies and law enforcement bodies in any jurisdiction;
  • l) credit reporting bodies (see Comprehensive Credit Reporting section below);
  • m) persons who act as your guarantor or who provide security for credit to you; and
  • n) our professional advisors, including lawyers, auditors and accountants.

Credit Reporting Bodies

The credit reporting bodies to which C1 Finance is likely to disclose your personal information include, but are not limited to:

• Equifax — www.equifax.com.au
• illion — www.illion.com.au
• Experian — www.experian.com.au

Each of these credit reporting bodies has its own credit reporting policy explaining how it manages creditrelated personal information. You may contact them directly to request that they not use your information for pre-screening of direct marketing, or to request a credit file freeze if you believe you have been or are likely to be a victim of fraud.

Comprehensive Credit Reporting

Australia’s comprehensive credit reporting regime allows credit providers and credit reporting bodies to share a broader range of credit information than was previously permitted. This includes both positive information (such as your on-time repayment history) and negative information (such as defaults).

C1 Finance participates in the CCR regime as both a contributor of credit information to credit reporting bodies, and a recipient of credit information from credit reporting bodies.

What We May Report to Credit Reporting Bodies

Where you have provided your consent, C1 Finance may disclose the following types of credit information about you to credit reporting bodies:

• Repayment history information — a monthly record of whether you meet your scheduled repayment obligations on time (positive CCR reporting);
• Default information — details of overdue amounts that remain unpaid (negative reporting);
• Credit account information — the type of credit, the date your account was opened and closed, and your credit limit;
• Payment clearance information — when a previously reported default has been paid;
• New arrangement information — where a new arrangement has been made for a previously defaulted debt or hardship;
• Court pending or judgment information — judgments entered against you in relation to credit; and
• Serious credit infringement information.

What We May Receive from Credit Reporting Bodies

C1 Finance may receive credit information about you from credit reporting bodies for the following purposes only:

• Assessing your application for consumer or commercial credit;
• Collecting overdue payments in relation to credit we have provided to you; and
• Assessing whether to accept you as a borrower, co-borrower or guarantor.

Your Rights in Relation to Credit Reporting

You have the right to:

• Access the credit information C1 Finance holds about you;
• Request correction of any credit information that is inaccurate, out of date, incomplete, irrelevant or misleading;
• Complain to C1 Finance about a breach of the credit reporting provisions of the Privacy Act or the Credit Reporting Privacy Code; and
• Request that a credit reporting body not use your credit information for pre-screening of direct marketing by a credit provider.

Please refer to C1 Finance’s Credit Reporting Policy available at www.c1carloans.com.au for full details of how credit information is handled and your rights under Part IIIA of the Privacy Act 1988 (Cth) and the Credit Reporting Privacy Code.

Direct Marketing

C1 Finance will not use or disclose Personal Information for direct marketing purposes unless an exception applies.

Personal Information (Other Than Sensitive Information)

C1 Finance may use or disclose your Personal Information (other than Sensitive Information) for direct marketing if:

• a) C1 Finance collected the information from you and you would reasonably expect it to be used for direct marketing; or
• b) C1 Finance collected the information from a third party and has obtained your consent, or it is impracticable to obtain your consent;
• c) C1 Finance provides you with a simple means to opt out of receiving direct marketing communications;
• d) each direct marketing communication includes a prominent statement about your right to opt out, or draws your attention to the fact that you may opt out; and
• e) you have not requested to opt out.

To opt out of receiving direct marketing communications from C1 Finance at any time, please contact us at info@c1finance.com.au or call 1300 732 520.

Sensitive Information

C1 Finance will not use or disclose Sensitive Information for direct marketing purposes unless you have given direct (express) permission.

Government Related Identifiers

C1 Finance will not adopt, use or disclose a government-related identifier (such as your tax file number or Medicare number) unless required under Australian law or where reasonably necessary to verify your identity for the purposes of C1 Finance’s activities.

Security and Storage of Information

C1 Finance will take reasonable steps to protect Personal Information it holds from misuse, interference, loss, unauthorised access, modification and disclosure.

• C1 Finance will take reasonable steps to destroy or de-identify Personal Information it holds where:
  • a) C1 Finance no longer needs the information for any purpose for which it may be used or disclosed;
  • b) the information is not contained in a Commonwealth record; and
  • c) C1 Finance is not required to retain the information under an Australian law or Court/Tribunal Order.
• C1 Finance stores Personal Information in different ways, including:
  • a) hard copy on site at C1 Finance’s head office; and
  • b) electronically using secure data centres on and offshore.

Where personal information is held by offshore service providers, C1 Finance takes reasonable steps to ensure those providers handle your information in a manner consistent with the Australian Privacy Principles.

Access to and Correction of Your Personal Information

You have the right to request access to the Personal Information C1 Finance holds about you, and to request that inaccurate, out-of-date, incomplete, irrelevant or misleading information be corrected.

To make an access or correction request, please contact us using the details in the Complaints section below. C1 Finance will respond to your request within a reasonable time. In some circumstances, we may be required to decline access or limit the information provided — where this occurs, we will give you written reasons for the decision.

Notifiable Matters

C1 Finance may disclose notifiable matters to a credit reporting body — for example, a loan default. Before disclosing a default, C1 Finance will provide you with prior written notice giving you an opportunity to repay the overdue amount or enter into a payment arrangement.

Please refer to C1 Finance’s Credit Reporting Policy on our website at www.c1carloans.com.au for more information.

Notifiable Data Breaches (NDB)

C1 Finance complies with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). In the event of an eligible data breach:

• Assessment: If a suspected breach occurs, C1 Finance will assess whether it is notifiable within 30 days of becoming aware of the suspected breach (s.26WH, Privacy Act 1988).
• What triggers notification: A breach is eligible where unauthorised access, disclosure or loss of your personal information is likely to result in serious harm — including financial harm, identity theft or reputational damage.
• Notifying you: Affected individuals will be notified as soon as practicable, with details of the breach, the kinds of information involved, and recommended steps to protect yourself.
• Notifying the OAIC: C1 Finance will notify the Office of the Australian Information Commissioner (OAIC) simultaneously with, or prior to, notifying affected individuals.
• Overseas recipients: Where an offshore service provider suffers a breach involving your personal information, C1 Finance treats this as its own breach and fulfils all NDB obligations accordingly.

Complaints

C1 Finance offers a free internal complaint resolution service. If you have a privacy complaint, please contact us using the following details:

C1 Finance will rectify any breach where a complaint is justified and will take the necessary steps to resolve the issue. After receiving a complaint, C1 Finance will send you a written acknowledgement setting out the process. The complaint will be investigated and a decision provided to you within thirty (30) days, unless you have agreed to a longer period.

If you are not satisfied with C1 Finance’s internal privacy practices or the outcome of your complaint, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):

Policy Changes

We may change this Privacy Policy from time to time to reflect changes in the law, regulation, or our business practices. Amendments will be effective when the updated Policy is published on our website at www.c1carloans.com.au. We encourage you to check this page periodically.

Contact Us

For privacy-related questions or requests, or any other enquiries, please contact us: