Privacy Policy
Last Updated May 11, 2020
Last Updated May 11, 2020
When you trust Alex Pty Ltd (ABN 13 627 244 848) and its related bodies corporate (Alex, we, us or our) with your personal information, you expect us to protect it and keep it safe. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and will protect your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act. The Australian Privacy Principles govern how we can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information.
This Privacy Policy contains important information about the collection, use, disclosure and management of your personal information by Alex.
Here are a few principles to keep in mind as you read through this policy:
Our Credit Reporting Policy is here. This policy provides information on our management of your credit information and contains information about:
“Personal information” includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information. The information or opinion will still be personal information whether it is true or not and regardless of whether we have kept a record of it. Personal information includes sensitive information and credit reporting information which are subject to additional protections under the Privacy Act.
The information that we seek to collect about you will depend on the products or services that we provide. If you do not allow us to collect all of the information we request, we may not be able to deliver all of those services effectively.
We collect personal information from you from existing and prospective customers, consumers and other individuals for the purposes set out in this policy.
We may collect personal information from you in the following ways:
We may also collect personal information about you indirectly from other people or organisations. This may happen without your direct involvement. For instance, we may collect personal information about you from from third party sources, including:
We will also collect your personal information from data aggregators such as illion BankStatements. illion BankStatements is a service provider that collects your transactional banking data and shares it with us to allow us to assess your personal loan application. If you apply for a personal loan with us, we will require you to agree with our privacy policy as well as illion’s terms and conditions and their privacy policy.
Personal information that we collect may include (but is not limited to) the following:
Throughout the life of any product or service you obtain from us, we may also collect and hold additional personal information about you and your use of our product or service. This could include transaction information or records of queries or complaints you make.
From time to time, the Personal Information we collect may include sensitive information. This may include health information required to assess any financial hardship status relevant to your credit application, as well as any relevant information about your religion, racial or ethnic origin, political opinions, criminal record, sexual orientation and biometric information (including photo and video identification). We only collect this sort of information if it is necessary to provide you with a specific product or service and you have consented to that collection. For example, we may collect financial hardship information and identity document information about you to process a credit application or collect voice biometric information to verify your identity and authorise transactions.
You do not have to provide us with any personal information. However, if you do not do so, this may limit our ability to fulfil the applicable purpose for collection and the assistance we are able to provide you. For example, we may not be able to consider or process an application you have made, or provide a product or service you have requested.
The main reason we collect, use, hold and disclose personal information for the following purposes:
As permitted by applicable law, we may also use your information for marketing and promotional purposes. See ‘Do we use or disclose personal information for marketing?’ below for more details.
We are required or authorised to collect:
We will take active steps to ensure that the personal information we hold is accurate, up-to-date and complete. We will remind you from time-to-time to keep personal information up-to-date and will update our records promptly.
Much of the information we hold about you will be stored electronically in secure data centres which are located in Australia and owned by either Alex or external service providers. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. See “Do we disclose personal information overseas?” section below for more detail.
Some information we hold about you will be stored in paper files. We use a range of physical and electronic security measures to protect the security of the personal information we hold and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. For example:
We take reasonable steps to destroy or permanently de-identify any personal information after it can no longer be used for the purposes for which it was collected.
The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
We may share your personal information with our related bodies corporate and other companies within the Alex group of entities.
We may also provide personal information about our customers to organisations and third parties outside the Alex Group that assist us to perform our business activities and functions. To protect your personal information, we enter into contracts with our service providers on terms which will ensure that your personal information afforded protection which is the equivalent basis to those protections provided under the Privacy Act. These contracts oblige them to only use the personal information we disclose to them for the specific role we ask them to perform and for the purposes set out in this Privacy Policy.
The third parties we may disclose your personal information to include:
We may also disclose your personal information to others outside Alex where:
We may disclose your personal information including your credit information or credit eligibility information to a recipient which is located outside Australia. In particular, your personal information including your credit information or credit eligibility information may be disclosed to third parties located in the United States, Hong Kong, Singapore, Taiwan, Finland, Belgium, Ireland, Chile, Hungary and the Netherlands. This includes information which we are legally required to store such as personal identification information for anti-money laundering and counter-terrorism financing laws and our Australian Credit Licensing responsibilities in relation to your loans.
Before we disclose any personal information including any credit information or credit eligibility information to an overseas recipient, we will make sure that all personal information is controlled and protected by the recipient in a way that is equivalent to the protections provided under the Australian Privacy Principles.
As permitted by applicable law, we may send you, from time to time, information about us or about products or services that we believe may be of interest to you, including advertising and promotional material relating to Alex, our related entities or our preferred suppliers by means of mail, telephone and electronic messaging (such as email and SMS messages).
By ticking the Privacy Policy box as part of the application process for any of our products, you acknowledge that you have read, understand and consent to our collection, use and disclosure of your personal information for marketing and promotional purposes described in this Privacy Policy. We will use your personal information to offer you products and services we believe may interest you. These products and services may be offered by a member of the Alex Group or one of its preferred suppliers. We may offer you products and services on an ongoing basis and by various means, including by mail, telephone, email, SMS or other electronic means such as through social media or targeted advertising via Alex Group or non-Alex Group websites. We may also disclose your personal information to companies outside the Alex Group who assist us to market products and services to you. If you don’t want to receive marketing offers from us, you may choose to unsubscribe by contacting us or choosing the option to opt-out when you receive the marketing offer.
Along with the Australian Privacy Principles, we will comply with the Spam Act 2003 (Cth) as well as the Do Not Call Register Act 2006 (Cth) in undertaking all marketing activities.
Alex and other third-party service providers (such as Google Analytics) may also use digital technologies such as data analytics, cookies, server logs, cloud service logs and web beacons in connection with Alex’s website and other online services to collect information from you electronically.
Each time you visit our website, we collect information about your use of the website, which may include the following:
Some of these technologies may operate without collecting or using any personal information. Please note that this Privacy Policy applies to our collection, use, disclosure and storage of personal information only.
Alex will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. You have the responsibility to ensure that changes in your personal circumstances are notified to us.
You may request access to and correction of the personal information we hold about you. To do so, please contact us using the contact information set out above.
At your request, Alex will provide you with a copy of any personal information which we hold about you unless an exception under the Privacy Act or other applicable legislation applies which means we are not required or permitted to provide you with that information.
If we correct the personal information which has been disclosed to us by another person or organisation, you may also request for us to notify that other person or organisation of the correction.
There is no fee payable for requesting to correct your personal information or for us to make corrections. However, in processing your request for access to your personal information, a reasonable cost may be charged. This charge covers such things as locating the information and supplying it to you.
We will respond to any request for access or correction within a reasonable period after the request is made. Access to personal information will be given in the format requested by you, given it is reasonable and practicable for us to do so.
If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Australian Privacy Principles, please contact us.
We will acknowledge your complaint as soon as we can after receipt of your complaint and will let you know if we need any further information from you to resolve your complaint.
We aim to resolve complaints as quickly as possible. While we strive to resolve complaints within five business days, some complaints take longer to resolve. If your complaint is taking longer to resolve, we will let you know what is happening and a date by which you can reasonably expect a response.
If you are unhappy with our response, there are other bodies you can go to.
The Australian Financial Complaints Authority (AFCA) can consider most privacy complaints involving providers of financial services.
AFCA can be contacted at:
Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
Phone: 1800 931 678
website: www.afca.org.au
Under the Privacy Act, you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information. The Commissioner can be contacted at:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
website: www.oaic.gov.au