Walker Stores Pty Ltd trading as Snaffle (ACN 007 973 962)
Australian Credit License Number 393023
Level 7, 1 Corporate Court, Bundall QLD 4217
1. Who we are and what this policy is about
Snaffle specialises in household products to consumers through consumer credit products including a line of credit. In the process of providing you with consumer credit services, Snaffle may collect, receive, deal with and store your Personal Information and Credit Eligibility Information. Snaffle is committed to safeguarding your Personal Information it collects, receives and discloses and is committed to doing so in accordance with the requirements of the Privacy Act, 1988 Commonwealth (Privacy Act) as amended from time to time. This policy describes our commitment in relation to protecting your privacy.
2. What information does this policy apply to?
This policy only applies to: (a) Personal Information; (b) Credit Eligible Information; and (c) Credit Information. These items are defined in the Privacy Act. Generally speaking, Personal Information is information (or opinion), in any form, about an individual (not a business, company or trust) whose identity is apparent or can be ascertained from the information held whether the information is true or not. Credit Eligibility Information means information we collect from a credit reporting entity or that has been derived from information that is about the individual’s consumer and or commercial credit worthiness. Credit Information means information that includes the following.
Information about an individual, like their name and address that we may use to identify that individual.
Information about an individual’s current or terminated consumer credit accounts and from the 12th March 2014, an individual’s repayment history.
The type and amount of credit applied for in any previous consumer or commercial credit applications to any credit provider, where that credit provider has requested information.
Information about an individual from a credit reporting body.
Information about consumer and or commercial credit payments overdue for at least 60 days and for which collection action has started.
Advice that payments that were previously notified to a credit reporting body as overdue or no longer overdue.
Information about new credit arrangements an individual may have made with a credit provider, in relation to consumer credit currently or previously held, to deal with any defaults or serious credit infringements by that individual.
Information about the individual’s consumer and or commercial credit worthiness.
Information about court judgments which relate to judgments which relate to credit that an individual has obtained or applied for.
Information about an individual on the national Personal Insolvency Index.
Publicly available information about an individual’s credit worthiness, and an opinion of a credit provider that an individual has committed a serious credit infringement of credit provided by that credit provider.
Credit Related Information – for the purpose of this policy Credit Related Information includes, as relevant, any information we collect, store, use or disclose that out of Personal Information, Credit Eligibility Information and Credit Information.
3. Our general commitment
Snaffle undertakes to collect, store and use Credit Related Information only in a manner which is compliant with the Privacy Act. Snaffle will not use or disclose Credit Related Information other than for:
a purpose for which the information was provided,
a purpose required or permitted by law,
a purpose you authorised or is disclosed to you, and/or
to give effect to your instructions.
Snaffle may collect, store and or disclose information about you to third parties for the following purposes:
to comply with the law;
to obtain a credit report about you,
to allow the credit reporting agency to create or maintain a credit information file containing information about you,
to provide you with promotional information about financial services and products we may provide (see section 7),
to manage and administer the agreement with you
to protect our lawful interests
to give effect to your instructions; and/or
if we negotiate with a third party the possibility of an acquisition of part to the whole of our business.
4. Our collection and Disclosure of Personal Information
Snaffle collects and discloses Credit Related Information as it may become necessary to process your application and give effect to your instructions. The information we may collect or disclose includes, when permitted by law:
the fact that you have applied for credit, the type of credit and the amount,
whether payments are more than 60 days overdue,
the fact that any overdue payments are no longer overdue or a default is remedied,
information whether you have committed a serious credit infringement (that is, acted fraudulently or shown an intention to not comply with your credit obligations
information about dishonoured cheques,
information about court judgements against you,
any information which is publicly available and relevant to your credit worthiness, and/or
certain insolvency information from the National Personal Insolvency Index
Third Party Service Provider
Subject to the Privacy Act, in the process of providing you with the services, we may share, as relevant, Credit Related Information with related bodies corporate and with third parties with whom we have dealings in the usual course of carrying on our business. These third-party service providers may include agents, portfolio managers, mailhouse operators, collection agencies, research providers, dispute resolution schemes, accounting and legal advisers.
We may disclose your Credit Related Information to other organisations, for example:
Our related companies.
External organisations that are our assignees, agents or contractors.
External service providers to us, such as organisations which we use to verify your identity, payment systems operators, mailing houses and research consultants.
Insurers and re-insurers, where insurance is provided in connection with our services to you.
Credit reporting bodies, including disclosing that you are in default under a credit agreement (for an amount exceeding $150 and over 60 days overdue) or commit a serious credit infringement, if that is the case lenders, mortgage insurers, where relevant to credit we have provided.
Debt collection agencies, if you have not repaid a loan as required.
Our professional advisors, such as accountants, lawyers and auditors.
State or territory authorities that give assistance to facilitate the provision of home loans to individuals.
Your representative, for example, lawyer, mortgage broker, financial advisor or attorney as authorised by you, or if required or authorised by law, to government and regulatory authorities.
If we disclose Credit Related Information to third parties, we will ensure that these organisations are bound by similar (but not necessarily the same) framework of privacy protection as the framework that governs us.
5. Access to your personal information
You have the right to seek access to any information we hold about you. Contact our privacy officer in this regard. We may charge you a fee to access and or correct your Personal Information that is held with us. You have the right to ask us to correct any information we hold about you if the information is inaccurate or erroneous.
6. Security of your personal information
Snaffle maintains strict procedures and standards and takes all reasonable care to prevent unauthorised access to, and modification and disclosure of, your Personal Information. Snaffle will protect any Credit Related Information it holds against misuse or loss. If we no longer need the Personal Information, we will take steps to either destroy the information or de-identify it.
7. Direct marketing
Snaffle may use your Personal Information to provide you with information from time to time in relation to additional services and or products we provide. You expressly authorise us to provide you with this information. You may withdraw your consent at any time by calling us or unsubscribing directly from any email or sms.
8. Credit Reporting Bureau
We may collect, hold and use, information related to your commercial and consumer creditworthiness from a credit reporting agency in order to assist us to produce our own assessments and ratings in respect of your credit worthiness, which may also take into account information we obtain from you and other sources. The reports will have Credit Information from your credit file. We also disclose information to the credit reporting agency. This activity is conducted for the purpose of assessing your credit capacity, eligibility or history in connection with an application or an obligation as a guarantor, collecting payments from you, and managing our credit relationship. Creditworthiness information includes information that is both positive (like payment information) and negative (like defaults or serious credit infringements that we may disclose to credit reporting bodies if you fail to pay us). If you are in default (for an amount exceeding $150 and over 60 days overdue), we may report the default to the credit reporting agencies in compliance with the Privacy Act 1988.
The credit reporting agencies we use may include but not limited to:
Equifax, PO Box 964 North Sydney 2059,
www.mycreditfile.com.au, 138 332
Illion, Level 7, 479 St. Kilda Road Melbourne 3004,
www.illion.com.au, 1300 734 806
9. Government identifiers
Snaffle does not have access to any Personal Information that can be regarded as or be used as an identifier unless you supply it to us. For example, Snaffle does not have access to your Medicare number or tax file number. Snaffle will not use any government identifier that was disclosed to us (such as Centrelink number) to identify you.
If you believe that your Personal Information has been mishandled by us or that we have breached this policy in any way, we invite you to write to our privacy officer at email@example.com. We will make every effort to resolve your complaint internally. If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority, or AFCA. AFCA provides fair and independent financial services complaint resolution that is free to consumers.
1800 931 678 (free call)
Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001
12. Transborder use of data
It is not likely that we will disclose Credit Related Information to overseas entities. If we disclose Credit Related Information to overseas entities, we will provide details on our website detailing the entities and countries where the information will be disclosed to. We will ensure that they protect the privacy of your Credit Related Information as we are committed under this Policy and the Privacy Act.
When you use our website, we may collect statistical data in relation to your use of the site. This date includes the time and date of the visit to the site, the nature of the inquiry and any documents loaded. We may record your browser type and other internet protocols as permitted.
If you disclosed any Personal Information on the site, the information will be governed under this policy. The use of public internet public access to our website is not without risk. If you transmit Persona Information via the internet you should ensure that the transmission is secured.
14. Acknowledgments and Consents
I/We as Applicant(s) for credit from Snaffle:
Authorise Snaffle to collect information about me from my employer and my referees for the purpose of my/our application and for any purposes related to a Finance Agreement approved pursuant to that application.
Acknowledge that Snaffle may have collected the personal information referred to in this form from its related parties or other unrelated retailers in accordance with your application, if you make that application via any such other company or retailer.
Acknowledge having been informed of the notice of disclosure to a credit reporting body.
Advise that, if Snaffle considers it relevant to assessing my/our application I/We agree in accordance with the provisions of s21H of the Privacy Act, to Snaffle obtaining credit information about my/our commercial activities or credit eligibility information from a credit reporting body.
Advise that, if Snaffle considers it relevant to collecting overdue payments in respect of credit provided to me, I/We agree in accordance with the provisions of s20E(3)(a) of the Privacy Act, to Snaffle receiving personal information about me/us in relation to collecting overdue payments from a credit reporting body.
In accordance with the provisions of s21J(1) of the Privacy Act, I/We agree that Snaffle may use, give to and seek from any credit providers named in my/our application and any credit providers named by a credit reporting body, information about my/our credit arrangements. I/We understand that this information can include any information about my/our credit eligibility, credit standing, credit history or credit capacity which credit providers are allowed to give or receive from each other under the Privacy Act.
Understand that the information about me/us disclosed to or by Snaffle in accordance with this Privacy Form may be used for the following purposes:
To assess an application by me/us for credit;
To notify other credit providers of a default by me/us;
To exchange information with other credit providers as to the status of my/our account where I/We am/are in default with other credit providers; and
To assess my/our eligibility for credit.
Understand that, if there is more than one applicant, and Snaffle rejects the application, each applicant may be advised that the application has been rejected wholly or partly on the basis of credit information about me.
Understand that the Privacy Act prohibits Snaffle from disclosing any part of my/our credit information to any other person.
Understand that as part of the credit application process, I/we will be required to prove my/our identity to Snaffle and that my/our identity details will be submitted to the Australian Government's Document Verification Service (DVS). The DVS is a national online system that allows organisations to compare an individual's Identifying Information with a Government record. More information about the DVS is available on their website www.DVS.gov.au.
By submitting your details to Snaffle, I/we agree that: - I/we are authorised to provide the ID document (s); and, - I/we understand that the ID document(s) details will be checked against records held by the Issuer or Official Record Holder.
By accepting these terms and conditions you give consent for Snaffle to disclose your name, residential address and date of birth to a credit reporting agency for the purpose of verifying your identity.
15. Electronic Transactions
I/We as Applicant(s) for credit from Walker Stores Pty Ltd trading as Snaffle:
a. Confirm that by submitting an Application for a line of credit or any document of any nature whatsoever relating to the line of credit, that:
I/We am/are in fact the person(s) identified as signing the relevant document;
I/We consent to the method proposed by which I/we will sign the relevant document and for future signing by me/us; and
I/We acknowledge and agree that I/we am/are contractually bound by the line of credit terms and conditions.
Electronic Communication - Acknowledgements / Consents
b. Consent to receive all documents and information of any nature whatsoever relating to the line of credit from Snaffle by electronic communication including, but not limited to:
All documentation comprising the package of line of credit documentation such as but not limited to the Schedule, Information Statement, Credit Guide and Terms and Conditions;
All Notices, disclosures and other documents Snaffle is required to provide me/us;
My/our copy of the fully executed line of credit; and
Any other document of any nature whatsoever that I/we separately agree will be provided by electronic communication.
c. Consent to receipt of the documents and information referred to above, to the mobile number or email address set out in this Application or address provided by me/us to Snaffle at any other time in connection with the line of credit.
d. Acknowledge that I/we may not receive a copy of any of the documents referred to above in a paper form unless I/we subsequently specifically request a copy from Snaffle.
e. Acknowledge that I/we must check my/our mobile phone and email regularly for communications from Snaffle.
f. Note that Snaffle can withdraw its consent to the giving of the documents and information above by electronic communication at any time, by contacting me/us.
16. More Information?