Privacy Policy

 

Respecting your privacy

We respect your personal information, and this Privacy Policy explains how we handle it. The policy covers Right Click Capital Management Pty Limited (ACN 161 549 944)  and all its related body corporate (the ‘Group’).

What personal information do we collect and hold?

General information

The types of information that we collect and hold about you could include:

  • ID information such as your name, postal or email address, telephone numbers, and date of birth;
  • other contact details such as social media handles;
  • financial details such as your tax file number; and
  • other information we think is necessary.

When the law authorises or requires us to collect information

We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth Anti-Money Laundering law.

What do we collect via your website activity?

If you use the internet to access or transact with us or on an account with us, we monitor your use of our websites, to ensure we can verify you and you can receive information from us, and to identify ways we can improve our services for you.

To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information.

How do we collect your personal information?

How we collect and hold your information

We understand that your personal information needs to be looked after and isn’t something you leave lying around for just anybody to take. So unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.

There are many ways we seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call or used our websites. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.

How we collect your information from other sources

Sometimes we collect information about you from other sources. We do this only if it’s necessary to do so. Instances of when we may need to include where:

  • we can’t get hold of you and we rely on publicly available information to update your contact details;
  • we need information from other sources to assess an insurance application you make through us;
  • we are checking the security you are offering through public registers and our service providers; and
  • at your request, we exchange information with your legal or financial advisers or other representatives.

What if you don’t want to provide us with your personal information?

If you don’t provide your personal information to us, we may not be able to:

  • provide you with the product or service you want;
  • manage or administer your product or service;
  • verify your identity or protect against fraud; or
  • let you know about other products or services from across the Group.

What do we do when we get information we didn’t ask for?

People often share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.

When will we notify you that we have received your information?

When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

How do we take care of your personal information?

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

  • confidentiality requirements of our employees;
  • document storage security policies;
  • security measures for access to our systems;
  • only giving access to personal information to a person who is verified to be able to receive that information;
  • control of access to our buildings; and
  • electronic security systems, such as firewalls and data encryption on our websites.

We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.

What happens when we no longer need your information?

We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

How we use your personal information

What are the main reasons we collect, hold and use your information? Because we offer a range of services and products, collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:

  • provide you with information about products and services;
  • consider your request for products and services, including your eligibility;
  • process your application and provide you with products and services; and
  • administer products and services which includes answering your requests and complaints, varying products and services, taking any required legal action in relation to our accounts and managing our relevant product portfolios.

Can we use your information for marketing our products and services?

We may use or disclose your personal information to let you know about products and services from across the Group that might better serve your needs.

We may conduct these marketing activities via email, telephone, SMS, iM, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites), or based on your use of Group programs. We will always let you know that you can opt out from receiving our third party or Group program marketing offers.

Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.

With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation outside of the Group.

Yes, you can opt-out

You can let us know at any time if you no longer wish to receive direct marketing offers from the Group (see ‘Contact Us’). We will process your request as soon as practicable.

What are the other ways we use your information?

We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:

  • giving you information about a product or service;
  • considering whether you are eligible for a product or service;
  • processing your application and providing you with a product or service;
  • administering the product or service we provide you, which includes answering your requests and complaints, varying products and services and managing our relevant product portfolios;
  • identifying you or verifying your authority to act on behalf of a customer;
  • telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, iM, mail, or any other electronic means including via social networking forums), unless you tell us not to;
  • assisting in arrangements with other organisations (such as loyalty partners) in relation to a product or service we make available to you;
  • allowing us to run our business and perform administrative and operational tasks, such as:
  • training staff;
  • developing and marketing products and services;
  • risk management;
  • systems development and testing, including our websites and other online channels;
  • undertaking planning, research and statistical analysis;
  • determining whether a beneficiary will be paid a benefit;
  • preventing or investigating any fraud or crime, or any suspected fraud or crime;
  • as required by law, regulation or codes binding us; and
  • for any purpose for which you have given your consent.

Who do we share your personal information with?

To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.

Sharing with the Group

We may share your personal information with other Group members. This could depend on the product or service you have applied for and the Group member you are dealing with.

Sharing at your request

We may need to share your personal information with:

  • your representative or any person acting on your behalf (for example, financial advisers, lawyers, settlement agents, accountants, executors, administrators, trustees, guardians, brokers or auditors); and
  • your referee (to confirm details about you).

Sharing with third parties

We may disclose your personal information to third parties outside of the Group, including:

  • those involved in providing, managing or administering your product or service;
  • authorised representatives of the Group who advise and/or sell products or services on our behalf;
  • organisations in which you invest, superannuation and managed funds organisations, and their advisers and service providers;
  • re-insurers, claim assessors and investigators;
  • brokers or referrers who refer your application or business to us;
  • other financial institutions, such as banks;
  • organisations involved in debt collecting, including purchasers of debt;
  • fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
  • organisations involved in surveying or registering a security property or which otherwise have an interest in such property;
  • real estate agents;
  • government or regulatory bodies (including the Australian Securities and Investments Commission and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
  • our accountants, auditors or lawyers and other external advisers;
  • rating agencies to the extent necessary to allow the rating agency to rate particular investments;
  • any party involved in securitising your facility, including re-insurers and underwriters, loan servicers, trust managers, trustees and security trustees;
  • guarantors and prospective guarantors of your facility;
  • organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
  • organisations that participate with us in payments systems including merchants, payment organisations and organisations that produce cards, cheque books or statements for us;
  • our joint venture partners that conduct business with us;
  • organisations involved in a corporate re-organisation or transfer of Group assets or business;
  • organisations that assist with our product planning, research and development;
  • mailing houses and telemarketing agencies who assist us to communicate with you;
  • other organisations involved in our normal business practices, including our agents and contractors; and
  • where you’ve given your consent.

Sharing outside of Australia

We run our business in Australia and overseas. We may need to share some of your information with organisations outside Australia. Sometimes, we may need to ask you before this happens. Our current list of overseas countries is: New Zealand, The Philippines, United Kingdom, United States.

We may store your information in a cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.

Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

How do you access your personal information?

How you can generally access your information

We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us to access your personal information that we hold by filling out the Personal Information Access form.

We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first. You can find the schedule of fees explained on the Access form.

We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:

  • we believe there is a threat to life or public safety;
  • there is an unreasonable impact on other individuals;
  • the request is frivolous;
  • the information wouldn’t be ordinarily accessible because of legal proceedings;
  • it would prejudice negotiations with you;
  • it would be unlawful;
  • it would jeopardise taking action against serious misconduct by you;
  • it would be likely to harm the activities of an enforcement body (e.g. the police); or
  • it would harm the confidentiality of our commercial information.

If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain by using the ‘Contact’ link below.

How do you correct your personal information?

How we correct your information

Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s:

  • inaccurate;
  • out of date;
  • incomplete;
  • irrelevant; or
  • misleading.

If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.

Helping you manage corrections

Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.

Where we correct information

If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.

Where we can’t correct information

If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.

Time frame for correcting information

If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.

If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:

  • let you know about the delay, the reasons for it and when we expect to resolve the matter;
  • ask you to agree in writing to give us more time; and
  • let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

How do you make a complaint?

How do you generally make a complaint?

If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.

You can contact us by using the ‘Contact’ link below. We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within ten business days.

Need more help?

If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:

  • Online: www.oaic.gov.au/privacy
  • Phone: 1300 363 992
  • Email: [email protected]
  • Fax: +61 2 9284 9666
  • Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601

Ask for more time if we can’t fix things in 30 days

If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

Letting you know about our decision

We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

Anything else? Important things for you to know

What if you want to interact with us anonymously or use a pseudonym? If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way as we are often governed by strict regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:

  • it is impracticable; or
  • we are required or authorised by law or a court/tribunal order to deal with you personally.

What do we do with government-related identifiers?

In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.

Changes to this Privacy Policy

This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website. Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement.