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Privacy Statement

How we collect, use and protect your personal information

SECTION A - INTRODUCTION

  1. 1Introduction
    1. 1.1The information in this document details how we, PBA Financial Licensing Pty Ltd (“PBA Licensing”), comply with the requirements of the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles in protecting the personal information we hold about you.
    2. 1.2Personal information is any information or opinion about you that is capable, or reasonably capable, of identifying you, whether the information or opinion is true or not and is recorded in material form or not.
    3. 1.3Sensitive information includes such things as your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record, that is also personal information. Your health, genetic and biometric information and biometric templates are also sensitive information.
    4. 1.4We will act to protect your personal and sensitive information in accordance with the Australian Privacy Principles and the Privacy Act.
    5. 1.5We collect personal and/or sensitive information to provide you with the products and services you request as well as information on other products and services offered by or through us. The law requires us to collect personal and/or sensitive information.
    6. 1.6Your personal and/or sensitive information may be used by us to administer our products and services, for prudential and risk management purposes and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We cooperate with police and other enforcement bodies as required or allowed by law.
    7. 1.7We disclose relevant personal information to external organisations that help us provide services. These organisations are bound by confidentiality arrangements. They may include overseas organisations.
    8. 1.8You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why. For example, we may give an explanation of a commercially sensitive decision, or give you access to the information through a mutually agreed intermediary, rather than direct access to evaluative information connected with it.

SECTION B - COLLECTION OF PERSONAL INFORMATION

  1. 1WHY WE COLLECT INFORMATION
    1. 1.1We collect personal information when it is reasonably necessary for one or more of our functions or activities.
    2. 1.2These include:
      1. 1.2.1providing customers with the products and services they request and, unless they tell us otherwise, to provide information on products and services offered by us and external product and service providers for whom we act as agent. (If you have provided us with your email or mobile phone details, we may provide information to you electronically with respect to those products and services);
      2. 1.2.2complying with our legal obligations;
      3. 1.2.3monitoring and evaluating products and services;
      4. 1.2.4gathering and aggregating information for statistical, prudential, actuarial and research purpose;
      5. 1.2.5assisting customers with queries; and
      6. 1.2.6taking measures to detect and prevent frauds.
  2. 2INFORMATION WE MAY COLLECT
    1. 2.1The personal and sensitive information we collect generally consists of name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and e-mail) and financial information.
    2. 2.2We may store credit card information on file for future transactions once a credit card has been used by a customer. This stored information allows for seamless future payments and improves the customer experience.
    3. 2.3In addition, we will obtain your consent to collect, use and disclose credit information about you.
    4. 2.4We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) in order to meet the standards set under those laws.
    5. 2.5Where it is necessary to do so, we also collect information on individuals such as:
      1. 2.5.1trustees;
      2. 2.5.2partners;
      3. 2.5.3company directors and officers;
      4. 2.5.4officers of co-operatives and associations;
      5. 2.5.5customer's agents;
      6. 2.5.6beneficial owners of a client; and
      7. 2.5.7persons dealing with us on a 'one-off' basis.
    6. 2.6We may take steps to verify the information we collect; for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation, or we may verify with an employer that employment information provided is accurate.
  3. 3HOW WE COLLECT INFORMATION
    1. 3.1We only collect personal information about you directly from you (rather than someone else) unless it is unreasonable or impracticable to do so or you have instructed us to liaise with someone else.
  4. 4INFORMATION COLLECTED FROM SOMEONE ELSE
    1. 4.1If it is impracticable or unreasonable for us to collect the personal information directly from you, we may collect such information from agents, or from your family members or friends. If you are not aware that we have collected the personal information, we will notify you of collection and the circumstances of collection, if we consider it is reasonable to do so.
    2. 4.2The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) require us to collect certain identification information about you. We will collect personal information from third parties in respect of AML/CTF checks which are required to be carried out, under AML/CTF Legislation.
  5. 5INCOMPLETE OR INACCURATE INFORMATION
    1. 5.1We may not be able to provide you with the products or services you are seeking if you provide incomplete or inaccurate information.
  6. 6CONSENT
    1. 6.1In most cases, before or at the time of collecting your personal information, we will obtain your consent to the purposes for which we intend to use and disclose your personal information.
    2. 6.2If you don’t give us consent, we may not be able to provide you with the products or services you want. This is because we are required to collect this information to provide you advice.
  7. 7WITHDRAWING CONSENT
    1. 7.1Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact our office. Please note that withdrawing your consent may lead to us no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.
  8. 8SENSITIVE INFORMATION
    1. 8.1In addition to the above conditions of collecting personal information, we will only collect sensitive information about you if we obtain prior consent to the collection of the information or if the collection is required or authorised by law.
  9. 9DEALING WITH UNSOLICITED PERSONAL INFORMATION
    1. 9.1If we receive personal information that is not solicited by us, we will only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.
    2. 9.2If these conditions are not met, we will destroy or de-identify the information.
    3. 9.3If such unsolicited information is sensitive information, we will obtain your consent to retain it regardless of what the circumstances are.

SECTION C - INTEGRITY OF YOUR PERSONAL INFORMATION

  1. 1QUALITY OF PERSONAL INFORMATION
    1. 1.1We ensure that the personal information we collect and use or disclose is accurate, up to date, complete and relevant.
    2. 1.2Please contact us if any of the details you have provided to us change or if you believe that the information we have about you is not accurate or up to date.
    3. 1.3We may also take steps to update personal information we hold, for example, an address, by collecting personal information from publicly available sources such as telephone directories or electoral rolls.
  2. 2SECURITY OF PERSONAL INFORMATION
    1. 2.1We are committed to ensure that we protect any personal information we hold from misuse, interference, loss, unauthorised access, modification and disclosure.
    2. 2.2For this purpose, we have a range of practices and policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.
    3. 2.3Our security measures include, but are not limited to:
      1. 2.3.1educating our staff as to their obligations with regard to your personal information;
      2. 2.3.2requiring our staff to use passwords when accessing our systems;
      3. 2.3.3encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
      4. 2.3.4employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
      5. 2.3.5using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
      6. 2.3.6providing secure storage for physical records; and
      7. 2.3.7employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.
    4. 2.4Where information we hold is identified as no longer needed for any purpose we ensure it is effectively and securely destroyed, for example, by shredding or pulping in the case of paper records or by degaussing (demagnetism of the medium using alternating electric currents) and other means in the case of electronic records and equipment.

SECTION D - USE AND DISCLOSURE OF PERSONAL INFORMATION

  1. 1USE OR DISCLOSURE
    1. 1.1If we hold personal information about you that was collected for a particular purpose (“the primary purpose”), we will not use or disclose the information for another purpose (“the secondary purpose”) unless:
      1. 1.1.1we have obtained your consent to use or disclose the information; or
      2. 1.1.2you would reasonably expect us to use or disclose the information for the secondary purpose and the secondary purpose is:
        1. 1.1.2.1if the information is sensitive - directly related to the primary purpose; or
        2. 1.1.2.2if the information is not sensitive - related to the primary purpose;
      3. 1.1.3the use or disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order; or
      4. 1.1.4a permitted general situation exists in relation to the use or disclosure of the information by us; or
      5. 1.1.5a permitted health situation exists in relation to the use or disclosure of the information by us, in which case we will de-identify the information before disclosing it; or
      6. 1.1.6we reasonably believe that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
    2. 1.2Where we use or disclose personal information in accordance with section 13(1)(e) we will keep a copy of this disclosure (e.g.: the email or letter used to do so).
  2. 2WHO WE MAY COMMUNICATE WITH
    1. 2.1Depending on the product or service you have, the entities we exchange your information with include but are not limited to:
      1. 2.1.1brokers and agents who refer your business to us;
      2. 2.1.2affiliated product and service providers and external product and service providers for whom we act as agent (so that they may provide you with the product or service you seek or in which you have expressed an interest);
      3. 2.1.3auditors we appoint to ensure the integrity of our operations;
      4. 2.1.4any person acting on your behalf, including your solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney;
      5. 2.1.5your referee (to confirm details about you);
      6. 2.1.6if required or authorised to do so, regulatory bodies and government agencies; (g) credit reporting agencies;
      7. 2.1.7other organisations who in conjunction with us provide products and services (so that they may provide their products and services to you); and
      8. 2.1.8professional associations or organisations with whom we conduct an affinity relationship (to verify your membership of those associations or organisations).
    2. 2.2Our use or disclosure of personal information may not be limited to the examples above.
  3. 3OUTSOURCING
    1. 3.1We disclose personal information when we outsource certain functions, including bulk mailing, card and cheque book production, market research, direct marketing, statement production, debt recovery and information technology support. We also seek expert help from time to time to help us improve our systems, products and services.
    2. 3.2In all circumstances where personal information may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.
    3. 3.3We take our obligations to protect customer information very seriously we make every effort to deal only with parties who share and demonstrate the same attitude.
  4. 4DISCLOSURE REQUIRED BY LAW
    1. 4.1We may be required to disclose customer information by law e.g. under Court Orders or Statutory Notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter terrorism financing.

SECTION E - DIRECT MARKETING

  1. 1DIRECT MARKETING
    1. 1.1We will only use or disclose the personal information we hold about you for the purpose of direct marketing if we have received the information from you and you have not requested not to receive such information.
    2. 1.2Direct marketing means that we should use your personal information to provide you with information on our products and services that may interest you.
    3. 1.3If you wish to opt-out of receiving marketing information altogether, you can: (a) write to us at support@payadvantage.com.au

SECTION F - CROSS BORDER DISCLOSURE OF PERSONAL INFORMATION

  1. 1DISCLOSING PERSONAL INFORMATION TO CROSS BORDER RECIPIENTS
    1. 1.1We will only disclose your personal information to a recipient who is not in Australia and who is not our entity after we ensure that:
      1. 1.1.1the overseas recipient does not breach the Australian Privacy Principles; or
      2. 1.1.2you will be able to access to take action to enforce the protection of a law or binding scheme that has the effect of protecting the information in a way that is at least substantially similar to the way in which the Australian Privacy Principles protect the information; or
      3. 1.1.3you have consented to the disclosure after we expressly you that there is no guarantee that the overseas recipient will not breach the Australian Privacy Principles; or
      4. 1.1.4the disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order; or
      5. 1.1.5a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) Privacy Act) exists in relation to the disclosure of the information.

SECTION G - ADOPTION, USE OR DISCLOSURE OF GOVERNMENT IDENTIFIERS

  1. 1ADOPTION OF GOVERNMENT RELATED IDENTIFIERS
    1. 1.1We will not adopt a government related identifier of an individual as our own identifier unless required or authorised to do so by or under an Australian law, regulation or court/tribunal order.
  2. 2USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS
    1. 2.1Before using or disclosing a government related identifier of an individual, we will ensure that such use or disclosure is:
      1. 2.1.1reasonably necessary for us to verify your identity for the purposes of our activities or functions; or
      2. 2.1.2reasonably necessary for us to fulfil its obligations to a government agency or a State or Territory authority; or
      3. 2.1.3required or authorised by or under an Australian law, regulation or a court/tribunal order; or
      4. 2.1.4within a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) Privacy Act); or
      5. 2.1.5reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

SECTION H - ACCESS TO PERSONAL INFORMATION

  1. 1ACCESS
    1. 1.1You can request us to provide you with access to the personal information we hold about you.
    2. 1.2Requests for access to limited amounts of personal information, such as checking to see what address or telephone number we have recorded, can generally be handled over the telephone.
    3. 1.3If you would like to request access to more substantial amounts of personal information such as details of what is recorded in your account file, we will require you to complete and sign a “Request for Access to Personal Information” form.
    4. 1.4Following receipt of your request, we will provide you with an estimate of the access charge and confirm that you want to proceed.
    5. 1.5We will not charge you for making the request for access, however access charges may apply to cover our costs in locating, collating and explaining the information you request. The charges are based on a rate of $220 dollars per hour.
    6. 1.6We will respond to your request as soon as possible and in the manner requested by you. We will endeavour to comply with your request within 14 days of its receipt but, if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within 30 days. It will help us provide access if you can tell us what you are looking for.
    7. 1.7Your identity will be confirmed before access is provided.
  2. 2EXCEPTIONS
    1. 2.1In particular circumstances we are permitted by law to deny your request for access, or limit the access we provide. We will let you know why your request is denied or limited if this is the case. For example, we may give an explanation of a commercially sensitive decision rather than direct access to evaluative information connected with it.
  3. 3REFUSAL TO GIVE ACCESS AND OTHER MEANS OF ACCESS
    1. 3.1If we refuse to give access to the personal information or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.
    2. 3.2Additionally, we will endeavour to give access in a way that meets both yours and our needs.
  4. 4ACCESS TO A CREDIT REPORT ABOUT YOU
    1. 4.1You have the right to ask for a copy of any credit report we have obtained about you from a credit-reporting agency. However, as we may not have retained a copy after we have used it in accordance with Part IIIA of the Privacy Act the best means of obtaining an up-to-date copy is to get in touch with the credit-reporting agency direct.
    2. 4.2You have a right to have any inaccuracies corrected or, if there is any dispute as to accuracy, to have a note added to your credit reporting agency file explaining your position. The major credit-reporting agency in Australia is Equifax, https://www.equifax.com.au/. As the largest agency, it is likely that it will be Equifax that you will need to contact in relation to access to an up-to-date copy of your credit report and any correction of information on your file. You can contact Equifax at https://www.equifax.com.au/contact.

SECTION I - CORRECTION OF PERSONAL INFORMATION

  1. 1CORRECTION
    1. 1.1We will correct all personal information that we believe to be inaccurate, out of date, incomplete, irrelevant or misleading given the purpose for which that information is held or if you request us to correct the information.
    2. 1.2If we correct your personal information that we previously disclosed to another APP entity you can request us to notify the other APP entity of the correction. Following such a request, we will give that notification unless it is impracticable or unlawful to do so.
  2. 2REFUSAL TO CORRECT INFORMATION
    1. 2.1If we refuse to correct the personal information as requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.
  3. 3REQUEST TO ASSOCIATE A STATEMENT
    1. 3.1If we refuse to correct the personal information as requested by you, you can request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then associate the statement in such a way that will make the statement apparent to users of the information.
  4. 4DELETION OF STORED CREDIT CARD INFORMATION
    1. 4.1If you have credit card information stored with us and wish to have it deleted from our systems, you can request your merchant to remove the card from your file. We will process such deletion requests promptly in accordance with your rights under the Privacy Act.

SECTION J - CONTACT US AND COMPLAINTS

  1. 1COMPLAINTS
    1. 1.1If you have any questions or would like further information about our privacy and information handling practices, please contact us by:
      1. 1.1.1Email: support@payadvantage.com.au; or
      2. 1.1.2Phone: 1300 641 310;
  2. 2MAKING A PRIVACY COMPLAINT
    1. 2.1We offer a free internal complaint resolution scheme to all of our customers. Should you have a privacy complaint, please contact us to discuss your concerns.
    2. 2.2You will also have free access to an external dispute resolution scheme in which we are member.
    3. 2.3To assist us in helping you, we ask you to follow a simple three-step process:
      1. 2.3.1Gather all supporting documents relating to the complaint.
      2. 2.3.2Contact us and we will review your situation and if possible, resolve your complaint immediately.
      3. 2.3.3If the matter is not resolved to your satisfaction, please contact our Complaints Officer on 1300 641 310 or put your complaint in writing and send it to PBA Licensing Pty Ltd at compliance@payadvantage.com.au.
    4. 2.4 If you are still not satisfied, you have the right to contact the Office of the Australian Information Commissioner (“OAIC”). You can contact the OAIC to make a query concerning your privacy rights, or to lodge a complaint with the OAIC about how we have handled your personal information. You can contact the OAIC's hotline on 1300 363 992 or visit their website at www.oaic.gov.au. The OAIC has the power to investigate a complaint and make a determination.
  3. 3REQUEST TO ASSOCIATE A STATEMENT
    1. 3.1If we refuse to correct the personal information as requested by you, you can request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then associate the statement in such a way that will make the statement apparent to users of the information.