Who are we?
‘We’, ‘us’ and ‘our’ refers to;
GROW FINANCE LIMITED ACN 613 082 698 (“Grow Finance”, “we”, “ours” or “us”) is committed to providing quality services to you. We recognise the importance of your privacy and understand your concerns regarding the security of the personal information which you provide to us. This policy outlines Grow Finance's ongoing obligations to you in respect of how Grow Finance manages your personal information. We also describe the measures we take to safeguard your personal information and tell you how to contact us regarding our privacy practices.
(a) when you sign up, access, or use our website (https://www.grow.com.au);
(b) when you apply for finance or otherwise purchase our products or services; and
(c) in relation to any personal information we collect from you during the course of our business or which we otherwise receive about you.
A copy of the APPs may be obtained from www.oaic.gov.au.
1. What is personal information?
Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true. Your personal information may also include credit reporting information (as defined in the CR Code) and any further information derived from such information.
2. What personal information do Grow Finance collect and hold?
A. Information collected directly from you
Grow Finance collect information about you and your interactions with Grow Finance, for example, when you purchase or use any of Grow Finance's products or services, call Grow Finance or visit Grow Finance's website. The information Grow Finance collects from you may include:
- your identity and contact details (including but not limited to your name, date of birth, address and email address);
- information about why you are applying for a particular product or service;
- details of your superannuation policies;
- details about your assets and liabilities;
- your history of purchases;
- your use of Grow Finance's products and services; and
- details of enquiries or complaints you make.
We may also collect sensitive information from you. We will only collect sensitive information from you with your consent. Sensitive information may include information about your health, ethnic origin or criminal record.
B. Credit Information
To the extent permitted by law, we may collect the following kinds of credit information and exchange this information with credit reporting bodies and other entities. Credit information may include the following:
- consumer credit liability information, including details of your credit provider and the terms of your credit;
- repayment history information;
- information about the type of finance that you are applying for;
- new arrangement information, which includes information about a variation to existing liabilities;
- serious credit infringements;
- payment information with respect to previously reported defaults;
- personal insolvency information, which is information that is entered into the National Personal Insolvency Index which relate to such things as debt agreements, bankruptcy personal insolvency agreements; and
- court proceedings information including court judgements and writs.
C. Information collected automatically
Grow Finance may also automatically collect information about how you access, use and interact with Grow Finance's website. This information may include:
- the location from which you have come to the site and the pages you visited; and
- technical data, which may include your IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.
3. Why do Grow Finance collect, hold and use your personal information?
We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities and as necessary to provide our services to you or to respond to and action any requests made by you. We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions.
Specifically, Grow Finance may collect, hold and use your personal information so that Grow Finance can:
- provide you with products and services, and manage Grow Finance 's relationship with you;
- arrange and assess your application for finance or other products and manage that finance or other product;
- assess your financial situation and discharge our duties and functions under relevant legislation, include the Bankruptcy Act 1966 (Cth) and the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);
- respond and communicate with you about your requests, transactions, questions and comments and allow you to receive our newsletters and communications;
- provide other loan products and service(s) you have requested or qualify for;
- provide services in relation to business options;
- undertake debt recovery and associated enforcement activities;
- comply with our legal obligations and assist government and law enforcement agencies or regulators; and
- identify and tell you about other products or services that Grow Finance think may be of interest to you.
- recognise your computer when you visit the website;
- track you as you navigate the website;
- display content on our website;
- operate, evaluate and improve our business and website usability;
- analyse your use of the website;
- personalise the website, including targeted advertisements that may be of particular interest to you;
- help diagnose technical and service problems; and
- gather demographic information about our users.
We use such information to assist us in providing an effective service (for example, to adapt our website to the needs of your device or to allow you to log in to our website), and to collect broad demographic information for identified, aggregated use.
4. How do Grow Finance collect your personal information?
Where reasonable and practical, Grow Finance will collect your personal information directly from you. For example, we may collect personal information from you via telephone, email or from the information you submit to us directly via the website. Grow Finance may also collect information from third parties such as:
- law enforcement / government agencies;
- credit providers and credit reporting bodies;
- previous employers;
- social media; and
- third party data providers.
If we receive unsolicited personal information that we have not requested or which we do not require to provide our services to you then we will destroy or de-identify the information if it is lawful and reasonable to do so.
5. How do Grow Finance store and hold personal information?
We respect the privacy of personal information and will take reasonable steps to keep it strictly confidential.
Grow Finance store most information about you in computer systems and databases operated by either Grow Finance or Grow Finance's external service providers. Some information about you is recorded in paper files that Grow Finance store securely.
GrowFinance may store data aboutyou:
- in Grow Finance's cloud-based data storage systems located in Australia and hosted by Microsoft Azure; and
- in Grow Finance's offices in Sydney, Melbourne and Brisbane.
Grow Finance implement and maintain processes and security measures to protect personal information which Grow Finance hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. These processes and systems include:
- the use of identity and access management technologies to control access to systems on which information is processed and stored;
- requiring all employees to comply with internal information security policies and keep information secure;
- requiring all employees to complete training about information security; and
- monitoring and regularly reviewing Grow Finance's practices against Grow Finance 's own policies and against industry best practice.
Grow Finance will also take reasonable steps to destroy or de-identify personal information once Grow Finance no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the Privacy Act or the CR Code. The security of your personal information is important to us. As any submission of information over the internet is never entirely secure, we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, but we will use all reasonable efforts to prevent it.
6. Who does Grow Finance dosclose your personal information to, and why?
We will disclose personal information to third parties if it is necessary for the primary purpose for which we collected the information, or for a related secondary purpose, if the disclosure could be reasonably expected.
Your personal information may be made available to suppliers, contractors or other third parties in order for them to perform services on our behalf, or to resolve issues or disputes that arise in connection with your use of our services.
For example, we may share your personal information to:
- credit providers and credit reporting bodies; and
- Government agencies (by request or statutory requirement).
Grow Finance may also transfer or disclose your personal information to its related companies and affiliates.
Where required by law, we will require that the third party undertake to treat the personal information in accordance with the APPs and any other applicable privacy laws.
Where we wish to use or disclose your personal information for other purposes which you may not reasonably expect, we will seek your prior consent to such disclosure.
Otherwise, we will only disclose your personal information to third parties without your consent if the disclosure is:
- necessary to protect or enforce our legal rights or interests or to defend any claims;
- necessary to prevent or lessen a serious threat to a person’s health or safety;
- required or authorised by law; or
- permitted by another exception in the applicable privacy laws.
If the ownership or control of all or part of Grow Finance's business changes, Grow Finance may transfer your personal information to the new owner.
7. Does Grow Finance disclose personal information to overseas recipients?
Grow Finance may disclose your personal information to recipients which are located outside Australia. Those recipients are likely to be located in the United States of America, Canada and New Zealand. If Grow Finance discloses your personal information to a recipient which is located outside Australia, Grow Finance will:
- take reasonable steps to make sure the overseas recipient will not breach the APPs (e.g. contractually bind the overseas recipient to comply with the APPs); or
- expressly inform the relevant individual that if they consent to the disclosure, Grow Finance will not be required to comply with the APPs regarding disclosure of the information overseas and the relevant individual expressly consents to the disclosure; or
- form a reasonable belief that:
a. the overseas recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way the APPs protect the information; and
b. there are mechanisms that can be accessed by the relevant individual to enforce that protection of the law or binding scheme.
We do not disclose your credit information overseas.
The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit information. We provide your credit information to the credit reporting body and to other credit providers as permitted by law.
We use the credit information that we exchange with the credit reporting body to assess your creditworthiness, assess your application for finance, manage your finance, and administer your debt or personal insolvency agreement.
If you fail to meet your payment obligations in relation to any finance that we have provided or arranged for you or if you have committed a serious credit infringement, we may disclose this information to a credit reporting body. The credit reporting body may disclose the credit information that we provide to other credit providers to assess your creditworthiness.
Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting body at any time to request that your credit information is not used in this way. You may also contact the credit reporting body to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the credit reporting body receives your notification, the credit reporting body must not use or disclose that credit information.
The credit reporting body that we use is Equifax. You can contact the mat www.equifax.com.au/contact at any time, 13 83 32 between 9am to 5pm AEST. A copy of Equifax’s policy setting out how it manages credit-related personal information can be found at www.equifax.com.au/privacy.
Unless you have opted out of marketing communications Grow Finance may use your personal information to offer you products and services Grow Finance believes may interest you.
10. What rights you have over your personal information
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
A. Access to information
You may request (i) information as to whether your personal or credit information is held by us; and (ii) access to your personal or credit information.
There is no charge for requesting access to your personal or credit information but Grow Finance may require you to meet its reasonable costs in providing you with access (for example, photocopying costs or costs for time spent on collating large amounts of material).
There may be situations where we are not required to provide you with access to your personal or credit information. If we refuse to give you access to the information you have requested, we will give you written notice within 30 days of your request setting out our reasons for the refusal(unless it is unreasonable to do so), the mechanisms available to you to complain about our decision, and other information as required by law.
You may request rectification, erasure, removal or restriction of your personal or credit information, for example, because (i) it is in complete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) you have withdrawn your consent.
We take all reasonable steps to ensure that the personal information Grow Finance hold about you remains accurate, up to date and complete.
Where we are satisfied that credit-related personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct the information within 30days.
If you remain unsatisfied with the way in which Grow Finance have handled a privacy issue, you may contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
12. Contact details
Name: Andrew McVeigh
13. Changes to this policy
You may request further information about the way we manage your personal or credit information by contacting us.