Privacy & Credit Reporting Policy

This policy applies to Nimble Australia Pty Ltd (ACN 135 501 807, Australian Credit Licence 386010) and its related bodies corporate (collectively 'we', 'us' or 'our').  

We are committed to protecting the personal information we collect and hold about you.

We recognise that any personal information we collect about you will only be collected, held, used or disclosed for the purposes we have collected it for or as allowed under the law (such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), the Privacy Act 1988 (Cth) or the National Consumer Credit Protection Act 2009 (Cth)). It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act 1988 (Cth) and any other relevant law.

Personal Information

When we refer to personal information we mean information or an opinion about an identifiable individual, or an individual who is reasonably identifiable. This information may include information or an opinion about you. The personal information we hold about you may also include credit-related information.

Credit-related information means:

• credit information, which is information which includes your identity; the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information (information about whether you meet your repayments on time); default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and

• credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.

Collection of personal information

The kinds of personal information we may collect and hold about you depends on your relationship with us (such as whether you are a customer or an employee) and may include your name, date of birth, address, email address, marital status, number of dependants, bank account details (including internet banking login details and account numbers), transactional history (e.g. payment history and loan balances), occupation, income details, employer information and any other information we made need to identify you such as your passport, driver's licence or Medicare number.

The main consequences of us not collecting personal information are an inability or delay in being able to identify you, contact you or provide services to you.

We will generally not ask you to disclose sensitive information about yourself, such as your religion or health related information. However, sometimes we may be required to collect or hold sensitive information about you or you may provide unsolicited sensitive information (e.g. if you volunteer information regarding your health). In those circumstances, we will ask for your consent to collect and hold sensitive information about you and we will also determine whether the information is reasonably necessary for one or more of the purposes outlined below. Otherwise, we will destroy or de-identify that information.

Electronic collection

We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications.

We use a technology called 'cookies' to provide you with better and more customised service and with a more effective website and mobile application (Site). A 'cookie' is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.

We or our service providers use cookies for different purposes such as:

• to allocate a unique number to your internet browsers;

• to customise our Site for you;

• for statistical and/or behavioural analysis purposes;

• to identify if you have accessed a third party website; and

• for security purposes.

In certain circumstances, data collected from use of cookies, pixels, click re-directs and tag containers may reasonably identify you and/or potentially constitute personal or sensitive information. By using our website you consent to our use of cookies, pixels, click re-directs and/or tag containers and the data they may collect or disclose, including to overseas entities.

Purposes of collection of personal information

We collect your personal and credit related information so we can:

• identify you and conduct appropriate checks on you and/ or any security;

• understand your requirements and provide you with a product or service;

• set up, administer and manage our products, including the management and administration of underwriting, and obtaining loan assessments and credit reports;

• assess your eligibility to be provided with finance and to manage the credit services we provide to you;

• manage, train and develop our employees and representatives, and providing continuing employment (in relation to our employees only);

• managing our relationship with you, including debt collection;

• manage complaints and disputes, and report to regulatory authorities and dispute resolution bodies;

• performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes. This may include matching information we collect against other information held by third parties. (We may also use and disclose de-identified data for these purposes);

• helping us tailor existing or develop new products, services or offers which may be offered to you, and to help us selectively target promotional offers and opportunities to your needs; and

• developing or seeking to deliver new ranges of products or services.

• search and register security interests on the Personal Property Securities Register

You must not give us inaccurate or incorrect information, or omit to provide us with information as we may not be able to provide you with our services.

If we hold sensitive information about you, we will not use the sensitive information for direct marketing purposes unless you specifically consent to us doing so.

Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from credit reporting bodies, your bank account providers, our service providers, other credit providers, lead generation businesses, access seekers, finance brokers and third party social media platforms such as Facebook.

We also collect information when you interact with our Site. For more information, please see our Website terms of use.

Disclosure of information

We may disclose your personal information to third party service providers we contract with to perform certain functions on our behalf such as:

• debt collection services;

• Illion, Equifax or Experian, and any related bodies corporate; and

• database providers who collect (sometimes through the use of first-party cookies, third-party cookies or other third-party identifiers), hold, use and disclose information in order to assist with identity verification, credit scoring and credit reporting bodies, debt collectors and lead providers.

We may also disclose your information to:

• any of our related bodies corporate;

• direct marketers (that is, associated businesses 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 in any of the ways listed at the end of this policy. If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take reasonable steps to meet your request at the earliest possible opportunity;

• anyone who represents you or anyone to whom you have consented to the information being disclosed;

• investors, agents or advisors or any entity that has an interest in, or is considering acquiring an interest in, our business or your loan contract;

• where we are required or permitted to do so by law, such as under the:

  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)

  • National Consumer Credit Protection Act 2009 (Cth); and

  • Personal Property Securities Act 2009 (Cth).

• companies that provide information and infrastructure systems to us;

• lead generation businesses and other credit providers. We may exchange or sell your information (including personal information and 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;

• online third party messenger applications, such as Facebook messenger, for the purposes of contacting you;

• social media platforms, such as Facebook, for marketing related purposes;

to third parties that assist us to enhance our business performance and/or the scope and 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; 

• imaging and document management service;

• search engine optimisation service providers;

• credit reporting agencies; and

• to your employer, referees or identity verification services.

The above mentioned recipients may be located overseas and may store your personal information outside of Australia, including in the USA, United Kingdom, Spain, Ukraine, Canada, New Zealand, India, Ireland, Singapore, European Economic Area and the Philippines.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

• the person or organisation has a commitment to protecting your personal information that is at least equal to our commitment; or

• you have consented to us making the disclosure.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located in or outside Australia.

Testimonials

We may publish testimonials, comments or feedback you provide to us on the Site, which may contain personal information such as your first name and suburb. If you want to remove your personal information that is being displayed on the Site, please send your request to customercare@nimble.com.au.

Credit-related information

We may collect and hold credit-related information and exchange this information with credit reporting bodies and other entities for the purposes of assessing your application for finance and managing that finance.

This credit-related information may be held by us in electronic form on our IT servers and may also be held in paper form. We may use cloud storage to store the credit-related information we hold about you and the IT servers may be located in or outside Australia.

When we obtain credit eligibility information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed. We may disclose your credit-related information to entities that provide support functions to us. These entities may be located overseas, including in the USA, Ukraine, New Zealand, United Kingdom, India, European Economic Area and the Philippines. You may obtain more information about these entities and their locations by contacting us.

Notifiable matters

The law requires us to advise you of 'notifiable matters' in relation to how we may use your credit-related information. You may request to have these notifiable matters (and this privacy and credit reporting policy) provided to you in an alternative form.

We exchange your credit-related information with credit reporting bodies. Credit reporting bodies include credit-related information in reports to assist credit providers (such as us) assess your creditworthiness, assess your application for finance and manage your finance.

If you fail to meet your payment obligations in relation to any finance that we have provided or you have committed a serious credit infringement, then we may disclose this information to a credit reporting body.

You have the right to request access to the credit-related information that we hold about you and make a request for us to correct that credit-related information if needed. Please see the heading ‘Access and correction to your personal information’, below.

Sometimes your credit-related 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 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-related information. You can contact any of the following credit reporting bodies for more information, including a copy of their credit reporting policy:

• illion – illion.com.au

• Experian – experian.com.au

• Equifax – equifax.com.au

Google Analytics

We do not collect ‘sensitive information’ as described in the Google AdWords sensitive category restrictions or sensitive interest information (which include personal hardships, identity and belief and sexual interests). The Google Analytics Advertising Features that we use include remarketing, 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 Google Analytics. You can opt-out of Google Analytics Advertising Features by following the instructions in this link: Google Analytics Opt-out Browser Add-on.

Hotjar

We use Hotjar to better understand how you use our Site. Hotjar is a technology service that helps us better understand your experience (e.g. how much time you spend on which pages, which links you choose to click, what you do and don’t like, etc.). Hotjar uses cookies and other technologies to collect data on your behavior and your devices (in particular a device's IP address (captured and stored only in anonymised form), device screen size, device type (unique device identifiers), browser information and geographic location (country only). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, see Hotjar's privacy policy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Security Information

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Access and correction to your personal and credit-related information

We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time by contacting us on customercare@nimble.com.au. We may charge a fee for our costs of retrieving and supplying the information to you.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within 7 days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is frivolous.  An explanation will be provided to you, if we deny you access to the personal information we hold about you.

If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information by contacting us in any of the ways listed at the end of this policy. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within 7 days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit-related information within 30 days.  We may need to consult with other finance providers or credit reporting bodies or entities as part of our investigation. If we refuse to correct personal information we will provide you with our reasons for not correcting the information.

Using government identifiers

If we collect government identifiers, such as your tax file number, Medicare number, passport number or driver's licence number, we do not use or disclose this information other than as required or permitted by law. We may use government identifiers to verify your identity when you deal with us.

Business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business, including answering general inquiries about our product or current promotional offers, however depending on the circumstances we may in some instances do business with you without you providing us with personal information. However the extent of the information and services we may be able to provide will be limited.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint, you can contact our complaints officer in any of the ways listed at the end of this policy.

We will acknowledge your complaint within 7 days. We will use our best efforts to provide you with a decision on your complaint within 30 days.

If you are dissatisfied with the response of our complaints officer you may make a complaint to our External Dispute Resolution Scheme, the Australian Financial Complaints Authority, which can be contacted on either www.afca.org.au or 1800 931 678 or the Privacy Commissioner, who can be contacted on either www.oaic.gov.au or 1300 363 992. 

Further information

You may request further information or provide feedback on the way we manage your personal or credit-related information by contacting us.

Changes to our privacy and credit reporting policy

We may change this policy from time to time. Any updated versions of this policy will be posted on our website and will be effective from the date of posting. You may request this policy in an alternative form by contacting us in any of the below ways.

This policy was last updated on 7 October 2019.

Contact Details

For privacy related queries, complaints or any other requests, you can contact us using any of the following methods:

Phone: 133 156

Email: customercare@nimble.com.au 

Mail: PO Box 3592, Australia Fair QLD 4215