Venture 5 Group Pty Ltd (trading as CashnGo Australia)
Venture 5 Group Pty Ltd trading as CashnGo Australia (ABN 82 156 288 078) Australian Credit Licence Number 431627 (referred to as ‘CashnGo Australia’, ‘we’, ‘our’, ‘us’) is a short term and small amount loan credit provider for people who need a small amount of money for a short time. We recognise that our success in this business depends on us maintaining the utmost commitment to upholding your privacy rights when collecting, holding, using, or disclosing your personal information. We have established a number of procedures and protocols to help us keep personal information we hold secure, accurate, up to date, and complete.
This Policy outlines CashnGo Australia’s obligations to manage and protect personal information and reflects the requirements of the Australian Privacy Principles (APPs’), the Credit Reporting Privacy Code (‘the Code’) and the Privacy Act 1988 (Cth) (“the Privacy Act”). This Policy is available free of charge from our website: www.cashngo.com.au.
This Policy also outlines CashnGo Australia’s practices, procedures and systems that ensure compliance with the Privacy Act, APPs and the Code.
In this Policy:
- ‘Credit information’ is personal information (other than Sensitive Information) that relates to an individual’s credit history or credit worthiness, and is further defined in the Privacy Act. Credit information includes information that we have obtained from Third Parties, including individuals, other credit providers and Credit Reporting Bodies (‘CRBs’);
- ‘Disclosure’ of information means providing information to persons outside CashnGo Australia;
- ‘Individual’ means all persons whose personal information we collect, use or disclose. ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
- ‘Sensitive Information’ is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information;
- ‘Third Parties’ mean customers, suppliers, sub-contractors, agents or other people having a commercial relationship with CashnGo Australia; and
- ‘Use’ of information means use of information within CashnGo Australia.
- WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect and hold the following kinds of personal information about you:
- phone numbers;
- email addresses;
- employment details, pay slips and income statements;
- bank account details and account statements;
- drivers’ licence details;
- marital status and dependents;
- financial and credit information, including: details of assets, liabilities, income, expenses; information about consumer credit liabilities, such as the name of an entity that has provided you with credit, the date of the credit was provided and the maximum amount of credit made available. This information may also include the following;
- information about your repayment history, such as whether you were late in making a monthly repayment and when repayments were due;
- the type and amount of credit you have applied for;
- whether you are 60 days or more overdue in making a repayment of $150 or more and whether you have repaid overdue amounts;
- information about new credit arrangements you have entered into as a result of defaulting on repayments;
- information about court judgements against you in relation to credit that has been provided to you;
- publicly available information that relates to your credit worthiness;
- information recorded in the National Personal Insolvency Index about you;
- our opinion as to whether you have committed a serious credit infringement in relation to consumer credit we provided to you;
- any other personal information that may impact our assessment of your credit worthiness; and
- any other information that is relevant to the services that we provide.
- HOW WE COLLECT PERSONAL INFORMATION
CashnGo Australia does not give you the option of dealing with it anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for CashnGo Australia to deal with individuals who are not identified.
- UNSOLICITED PERSONAL INFORMATION
CashnGo Australia may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information, unless it is relevant to CashnGo Australia’s purposes, under this Policy, for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.
- WEBSITE & ELECTRONIC COLLECTION
We may collect personal information from you electronically from our website :www.cashngo.com.au, when we receive emails and online account application forms. We may also use third parties to analyse traffic at that website, which may involve the use of a technology called 'cookies'.
- a) to allocate a unique number to your internet browsers;
- b) to customise our website for you;
- c) for statistical and/or behavioural analysis purposes;
- d) to identify if you have accessed a third party website;
- e) and for security purposes.
- GOOGLE ANALYTICS
CashnGo Australia does not collect Sensitive Information as defined in section 1 and as described in the Google AdWords sensitive category restrictions or sensitive interest information (which include personal hardship, identity and belief and sexual interests). The Google Analytics Advertising Features that we use include re-marketing, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. These features require the collection of data via advertising cookies and identifiers. For more information about Google Analytics please refer to the Google Analytics link at : https://www.google.com.au/analytics. You can opt-out of Google Analytics Advertising Features by following the instructions in this link: https://tools.google.com/dlpage/gaoptout.
- WHY DO WE COLLECT AND HOLD PERSONAL INFORMATION?
We may collect and hold personal information about you to:
- assist CashnGo Australia in providing you with credit;
- verify your identity and financial situation;
- assess whether our credit products are suitable for you;
- assess any applications by you for credit;
- managing credit provided to you, collect payments and collect overdue payments from you;
- provide you with our promotional material;
- to assist us in tailoring existing or develop new products, services or offers which may be offered to you, and to help us selectively target promotional offers and opportunities that meet your needs;
- develop or seek to deliver new ranges of products or services;
- protect our business and other customers from fraudulent or unlawful activity;
- conduct our business and perform other management and administration tasks;
- consider any concerns or complaints you may have;
- bring, defend, or manage any legal action involving you and CashnGo Australia;
- comply with relevant laws, regulations and other legal obligations, including the National Consumer Credit Protection Act 2009 (Cth) or Anti-Money Laundering and Counter-Terrorism Financing Act 2006(Cth) ; and
- help us improve our products and services, and to enhance our overall business.
The main consequences of us not collecting your personal information are our inability or delay in being able to identify you, contact you or provide services to you.
- HOW MIGHT WE USE AND DISCLOSE PERSONAL INFORMATION?
CashnGo Australia may use and disclose your personal information for:
- the primary purpose for which it is collected of providing you with credit and managing your loan;
- secondary purposes which are related to this primary purpose that you may reasonably expect, such as keeping you informed about changes to your loan, or new products and services; and
- other purposes authorised by the Privacy Act.
We use and disclose personal information for the purposes outlined in section 7 above. Sensitive Information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or if certain other limited circumstances apply (e.g., where required by law). Credit information will only be used and disclosed for the purposes outlined in section 10 below.
We engage other people to perform services for us (“Contractors”), which may involve them handling personal information we hold. In these situations, we prohibit Contractors from using personal information about you except for the specific purpose for which we supply it. We prohibit Contractors from using your information for the direct marketing of their products or services. CashnGo Australia will attempt to de-identify Sensitive Information held by us, wherever possible. We also undertake to delete all personal information about you when it is no longer needed or relevant.
- TO WHOM MIGHT WE DISCLOSE PERSONAL INFORMATION?
We may disclose your personal information, excluding credit information, to:
- a related entity of CashnGo Australia;
- an agent, contractor or service provider we engage to carry out functions and activities in connection with approving or administering credit products or services, such as our electronic verification service, lawyers, accountants, debt collectors or other advisors;
- direct marketers (that is, associated business that may want to market products to you). If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us. We will not charge you for fulfilling your request and will take reasonable steps to meet your request at the earlier possible opportunity;
- social media platforms, such as Facebook, for marketing related purposes;
- lead generation businesses and other credit providers. We may exchange or sell your information (including personal information or credit-related information) to third party lead generation companies or other credit providers, who may use that information for any of the purposes for which we can use it. That information may also be disclosed to agents, contractors or advisors of the lead generation business or other credit provider;
- to third parties that assist us in improving our business performance and the quality of our services to you such as:
- website behaviour analysis providers;
- interest data, remarketing and network impression reporting providers;
- customer, product, business or strategic research and development organisations;
- administration or business management services, consultancy firms, auditors and business management consultants;
- print/mail/digital service providers; and
- imaging and document management service;
- search engine optimisation service providers; and
- credit reporting agencies.
- to your employer, referees or identity verification service providers;
- organisations involved in a transfer or sale of all or part of our assets or business;
- organisations involved in managing our payments, payment merchants and other financial institutions such as banks;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- an individual’s financial institutions, referee(s), employer, co-account holder or authorised signatory; and anyone else to whom the individual authorises us to disclose it.
- HOW MIGHT WE USE AND DISCLOSE CREDIT INFORMATION?
We will only use and disclose your credit information for the following purposes:
- assessing an application by you for credit;
- collecting payments that are overdue in relation to credit provided by us;
- dealing with a serious credit infringement we believe you have committed;
- responding to questions in the course of an investigation by the Australian Financial Complaints Authority (“AFCA”), or any other external dispute resolution body of which we are a member;
- purposes required or authorised by law;
- assisting you to avoid defaulting on your obligations; or
- internal management purposes that are directly related to the provision or management of credit to you.
We will only disclose your credit information to:
- a related body corporate;
- a person who will be processing your application for credit;
- a person who manages credit provided by us for use in managing that credit;
- another credit provider if we believe you have committed a serious credit infringement, or the individual has consented to the disclosure; a debt collector; or
- a CRB. If we intend to provide default information about an individual to a CRB, we will give you at least 14 days’ written notice. If we disclose default information to a CRB, and you subsequently repay the amount owed, we will tell the CRB that you have repaid the amount owing. We will not disclose credit repayment history information to the CRB which is more than 2 years old or relates to an amount owing of less than $150.
- SENDING INFORMATION OVERSEAS
We will not send personal information to recipients outside of Australia unless:
- we have taken reasonable steps to ensure the recipient does not breach the Privacy Act, the APPs and the Credit Reporting Privacy Code;
- the recipient is subject to an information privacy scheme similar to the Privacy Act; or
- the individual has consented to the disclosure.
- MANAGEMENT OF PERSONAL INFORMATION
The APPs require us to take all reasonable steps to protect the security of personal information, including credit information. CashnGo Australia employees respect the confidentiality of the personal information we collect. CashnGo Australia takes reasonable steps to protect personal information held from misuse, loss, unauthorised access, modification or disclosure. All personal information contained in hard copy documents held by CashnGo Australia is stored in locked cabinets. All personal information stored on CashnGo Australia’s computer system is backed up regularly, and back-up copies are held in a secure location. In relation to our customer database, we apply the following guidelines:
- data ownership is clearly defined within CashnGo Australia ;
- passwords are routinely checked;
- we change employees’ access capabilities when they are assigned to a new position;
- employees have restricted access to certain sections of the system;
- the system automatically logs and reviews all unauthorised access attempts;
- the system automatically limits the amount of personal information appearing on any one screen;
- unauthorised employees are barred from updating and editing personal information;
- all personal computers which contain personal information are secured, physically and electronically;
- data is encrypted during transmission over the network;
- print reporting of data containing personal information is limited;
- CashnGo Australia has created procedures for the disposal of personal information; and
- personal information is overwritten to the extent possible when the information is no longer required. Where we no longer require personal information we will take reasonable steps to destroy or de-identify it.
- DIRECT MARKETING
CashnGo Australia does not use your personal information for the purposes of direct marketing, unless:
- the personal information does not include Sensitive Information; and
- you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
- we provide you with a simple way of opting out of direct marketing; and
- you have not requested to opt out from receiving direct marketing from us. If you would not reasonably expect us to use or disclose the information for the purpose of direct marketing, we may only use or disclose that information for direct marketing if you have consented to the use or disclosure of the information for direct marketing or it is impracticable to obtain that consent. Individuals can opt out of direct marketing by contacting us, and we will give effect to the request within a reasonable period of time.
CashnGo Australia will provide you with the source of its information about you on request free of charge within a reasonable period of time. We will not use or disclose credit information for the purposes of direct marketing. CashnGo Australia may only use or disclose Sensitive Information about you for the purpose of direct marketing with your consent.
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. We may use government identifiers (as required or permitted by law) to verify your identity when you deal with us.
- HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
CashnGo Australia takes reasonable steps to ensure that the personal information, including credit information, it collects, uses and discloses is relevant, accurate, complete and up-to-date. We encourage you to contact us in order to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. If we are satisfied that personal information we hold is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting your information.
- ACCESS TO PERSONAL INFORMATION
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information, including credit information, which CashnGo Australia holds about you by contacting the CashnGo Australia Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide access, we will provide reasons for the refusal. You can look at your personal information at the offices of CashnGo Australia. We will require you to verify your identity and specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
- UPDATES TO THIS POLICY
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and the business environment. You will be notified if that happens.
- INQUIRIES AND COMPLAINTS
If you have any questions about our privacy procedures, or if you wish to make a complaint about how we have handled your personal information (including credit information) you may lodge a complaint by:
- telephoning us on 13 13 11; or
- writing to us: The Privacy Officer, CashnGo Australia, Suite 3, Level 1, 460 Church Street, Parramatta NSW 2150; or
- emailing: firstname.lastname@example.org.
If you are not satisfied with the response to your complaint you can contact the following:
- Australian Financial Complaints Authority (“AFCA”) by calling 1300 56 55 62 or visiting AFCA’s website at https://www.afca.org.au; or
- Office of the Australian Information Commissioner by calling 1300 363 992, emailing email@example.com, or writing to Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001.
This Policy was updated on: 31 May, 2018