2 comply with the Privacy Act 1988, which contains provisions designed to safeguard personal information about you. The Privacy Act 1988 requires us to comply with privacy principles set out in that Act. Personal information is any information that we use to identify a living person. This may include names, addresses, date of birth, gender, phone numbers or employment details.
3Collection of your information is essential for us to service the relationship and the business operations. Without the Personal Information, we would not be able to provide you with the products and services, enter into contracts or undertake transactions with you.
2Should there be any inconsistency between this policy, the Privacy Act 1988 and other laws and codes, this policy shall be interpreted to give effect to and comply with the legislation.
COLLECTION OF PERSONAL INFORMATION
may collect information about you, which may include non-public Personal Information:
1Information that you provide us in the course of using the Services and Products of . We may also collect certain sensitive information from you including your bank account number, credit or debit card number and date of birth;
2Information that you provide us in the course of your participation in various promotional programs or while you submit a query or feedback;
3To facilitate our Service or Product, we request certain third party Personal Information from you, such as your Beneficiary or Recipient's full name, mailing address, email address, telephone number, date of birth, nationality etc. We may also collect from you sensitive financial information of a Beneficiary or a Recipient, including bank account numbers;
4Information that we lawfully obtain from third parties, such as Service Companies, Document verification service providers, electronic database services, and credit reporting agencies;
6Recordings of your communications with our customer service department, including telephone calls,electronic communications and letters.
INFORMATION WE COLLECT
We may collect the following types of personal information from you:
and any other information we may collect with your approval, as permitted or required by law and in compliance with Australian Privacy Laws. If you are an entity then, by applying for anyServices or Products of PFG Smart Credit you agree and consent to the matters following. If you supply us with Personal Information about an individual you agree to inform that person:
10We are holding information about that person and he or she can contact us at any of our offices.
11Personal Information collected about that person will be used for the primary purpose of accessing your application for the requested service and if your application is approved, for the initial establishment of the service and then for the subsequent administration and eventual finalization of your service and that without that Personal Information, this purpose cannot be fulfilled.
12Personal Information collected about that person will usually be disclosed to any of us and to the organizations mentioned below.
13That person has the right to access and correct Personal Information.
USE OF YOUR PERSONAL INFORMATION
Your Personal information is not used for any third party marketing purposes or sold to any other entity. collects, uses, holds and discloses your personal information for the following purposes:
1To process and complete your money transfer request;
2To identify you and verify your identity from third parties, such as Service Companies, Document verification service providers, electronic database services, and credit reporting agencies
3Check your eligibility to use the services and products offered by ;
4To collect payment for your use of the Service
5To troubleshoot problems with the service;
6To process car loan or home loan services from Lacsa Group Pty Ltd and/or to allow our partners to fulfil their promotional obligations to you;
7To allow our partners to fulfil their promotional obligations to you;
8To monitor, review and improve the services of ;
9To monitor compliance and comply with AML CTF Act 2006, and AML CTF Rules; and
10Prevent money laundering, terrorism financing, fraud and other illegal uses of the service.
might use your personal information to:
11Train our staff, risk management and record keeping;
12To send you marketing notices, service updates, promotional offers and inform you about the new services of (you have the option to opt out from receiving these updates anytime you wish);
13Complete research and market studies;
14Maintain good relationship with our customers; and
15Comply with other legal regulations or as permitted by any laws.
USE OF PSEUDONYMS
1 requires its Customers to accurately identify themselves to make avail our services as per the Privacy Act 1988. cannot deal with Customers who have not identified themselves or who have used a pseudonym. However, this does not restrain Customers to make enquiries on our products and services using a pseudonym.
DISCLOSURE OF YOUR PERSONAL INFORMATION
may share your personal information with companies only within the Group and its network which includes the affiliated companies and partnering entities that offers services and products for distribution. The personal information that you provide us will be disclosed to a third party only if it is necessary and in compliance with the Privacy Laws.Personal information will be used and disclosed only for the purposes for which it is collected.
You agree that we disclose your Personal Information to any of the following types of organizations or individuals.
1Providers, contractors and external advisers who we engage to carry out our functions and activities from time to time;
2’s correspondent banks to process the money transfer requests;
3To any agents or intermediaries who are a part of ’s products and services;
4To Lacsa Group Pty Ltd (ABN 24 111 297 539) (ACL 470128) to process the car loan/home loan referral services;
5To overseas intermediaries to complete your money transfer request;
6To any credit reporting bodies to verify your identity;
7Your executor, administrator, trustee, guardian or attorney;
8Regulatory bodies, governments agencies and law enforcement bodies; and
9As may be authorized or required by law to disclose Personal Information.
OVERSEAS USE AND DISCLOSURE
1 may transfer your personal information overseas to complete the services and products requested by you, this will always be subject to Australian data protection and Privacy Laws.
ACCESS AND CORRECTION OF PERSONAL INFORMATION
You have the right to request access to your personal information and request its correction. You can access the personal information we hold about you by putting a written request to our Privacy Officer at the following address.
2You can also access your personal information that we hold by visiting our office. Alternatively, you contact us on email@example.com (indicating Privacy Request at the message line) or at 03 9001 5864. However, all requests for your access to your personal information are to be in writing. Information will be provided to you within 14 days, or within a reasonable timeframe. In some situations we may exercise our right, as allowed by the law, to deny you access to particular information. If we deny you access to your personal information we will explain our reasons for doing so.
3If you are requesting to access personal documents please include a certified copy of primary photographic identification (such as a Passport or Driver’s license) to assist us in processing your request. Access may be withheld or provided subject to Privacy Act 1988.
4If you are able to establish that any information held by us is not accurate, complete and up to date, we will take reasonable steps to ensure that the information is accurate, complete and up to date provided any refusal made is subject to valid reasons. A copy of primary identification document and address proof may be necessary to correct your personal information. PFG Smart Credit will not charge from you for the making of the request or for giving access to the personal information. However, we might charge a minimal fee if the personal information you request requires research or preparation time.
SECURITY AND RETENTION
applies technical, physical, and administrative data security measures to protect your personal information from loss, misuse, unauthorized access, modification, alteration or disclosure. Once our dealing with you is completed, we endeavour to take reasonable steps to delete or permanently erase the personal information if not required further.We take all steps reasonably necessary toensure we keep your information secure, for example by:
1Encrypting our services via a secure 256-bit SSL encryption and digital archiving;
2Properly trained staffs on privacy matters and data protection;
3Maintaining the servers in multiple secure locations tested regularly by external experts. is obliged to comply the requirement AML/CFT Act and the Privacy Laws, information relating to personal identity is retained for a period of 7 years. will destroy, erase, or make anonymous your personal information when it is no longer required as per the Law.
PREVENT UNAUTHORIZED DISCLOSURE OF PERSONAL INFORMATION BY YOU
1 is committed in protecting the personal information of its Customers. We will never request you to disclose your personal information via unauthorized emails or fax.
2Ensure you do not share any sensitive information to unauthorized individuals via unsecured emails, calls or fax. Contact us immediately if you have been contacted by an unauthorized person, email, call or fax.
3We collect and store all information electronically and take all reasonable steps to protect information from unauthorized access, but we cannot accept liability for unauthorized access or use of your personal information.
LOSS OF PERSONAL INFORMATION
maintains adequate data security measures to protect information against unauthorized access and disclosure, despite our efforts chances breach of security cannot be completely ruled out. In the event of loss of personal information will:
1Identify and prevent further breaches at the earliest instance possible.
2Assess the nature and severity of the breach including the type of personal information involved and the risk of harm to affected individuals.
3Alert the affected individuals if required.
4Engage appropriate authorities if criminal activity is suspected
5Notify the Privacy Commissioner (at the OAIC) if the breach is significant
If you have a complaint about our handling of personal information we request you to contact us first. We will then follow it with our Internal Dispute Resolution team and respond within 30 days wherever possible. If the matter proves to be complex we may advise you to put the complaint in writing.
1To lodge a complaint please contact our:
Dispute Resolution Officer,
We do our best to resolve the matter in a timely fashion. If we cannot resolve the matter promptly due to its complexity, you will be advised in writing.
OFFICE OF THE AUSTRALIAN INFORMATION COMMISSIONER (OAIC)
1The Office of the Australian Information Commissioner (OAIC) can investigate privacy complaints from individuals about Australian and private sector organisations covered by the Privacy Act 1988 (Privacy Act). Before you can lodge a complaint with the OAIC, you will generally need to complain directly to the agency or organisation you are complaining about and allow 30 days for it to respond. If you do not receive a response (after 30 days), or you are dissatisfied with the response, you may then complain to the OAIC.
2You can contact OAIC by
email to firstname.lastname@example.org;
calling 1300 363 992,
If calling from outside Australia call: + 61 2 9284 9749,
or write to
OAIC,GPO Box 5218, Sydney, NSW – 2001 Or /
OAIC, GPO Box 2999, Canberra, ACT- 2601
THIRD PARTY SITES
1 site may have links to other websites not owned or controlled by us. We are not responsible for these sites or the consequences of you going on to those sites.
1If you have any questions or concerns about our privacy practices please contact us by telephone, letter, facsimile or email
Facsimile: 03 9011 6111