HAL GROUP PRIVACY POLICY

Introduction

This Privacy Policy covers the Hal Group of companies including TL Commercial Finance Pty Ltd (ACN 071 702 264). We respect your right to privacy and recognise that maintaining confidentiality is an integral part of providing our services. We are committed to protecting and maintaining the privacy of all individuals with whom we deal. We are also committed to complying with the Privacy Act 1988 (Cth) (“the Privacy Act”) and the Australian Privacy Principles.

This Policy describes how we manage any personal information we collect about you and how we hold, use and disclose that information. It also explains how to contact us if you have any queries about our management of your personal information. This Policy applies to you only to the extent that the collection and handling of your personal information by us is subject to the Privacy Act.

What is “personal information”?

Personal information is information or an opinion (regardless of its accuracy or form) about an identified individual, or from which the identity of a person is reasonably identifiable. It includes your name, age, gender and contact details.

What kind of personal information do we collect and hold?

We only collect personal information about you which is reasonably necessary for our functions and/or activities, including in relation to:

 

    • considering any application you make to us;
    • maintaining your contact details;
    • fulfilling our legal obligations under applicable laws, rules and regulations such as those relating to taxation and anti-money laundering.

We may hold the following information about you:

    • name, address, telephone numbers;
    • date of birth;
    • credit history information;
    • any information you provided to us through the application process;
    • any additional information you may have provided us;
    • records of our communications with you, including by telephone and email;
    • your enquiries or complaints.

We do not generally collect sensitive information about you unless required by applicable laws or rules. “Sensitive information” includes information relating to race, political or religious beliefs or affiliations, sexual preferences, criminal convictions, health information, genetic information or biometric information.

How do we collect personal information?

We only collect personal information about you in the manner permitted by the Privacy Act.

We may collect your personal information from you in a number of ways including in person, by phone, through our website or by email. We may also collect your personal information from third parties, such as from brokers or introducers.  We may also collect your personal information from organisations engaged by us to carry out functions on our behalf.

For what purposes do we collect, hold and use your personal information?

We collect, hold and use your Personal Information for the following purposes:

    • to provide our services to you;
    • to assist us in communicating with you;
    • for our internal administration requirements;
    • to assess and process applications for finance;
    • to assess an application by you to be a guarantor;
    • to work with our suppliers, funders, brokers and introducers;
    • to distribute information about our services to you;
    • to collect overdue payments;
    • to deal with any enquiries or complaints.

Our range of products and services, as well as our functions and activities, may change from time to time.

How do we hold your personal information?

When holding your personal information, we are required by the Privacy Act to take reasonable steps:

    • to ensure that your personal information that we collect, hold, use and disclose is accurate, complete and up-to-date; and
    • to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure; and
    • to destroy or permanently de-identify your personal information if we no longer require that information for any purpose that is permitted by the Privacy Act.

All reasonable measures are taken to protect personal information we hold from unauthorised access, improper use, disclosure, unlawful destruction and accidental loss.

We store personal information:

    • contained in electronic databases in a secure environment with controlled access; and
    • contained in paper based and other hard copy documents located securely within our premises.

Who do we disclose your personal information to?

In order to carry out the above-mentioned purposes, we may disclose on a confidential basis your personal information in the ordinary operation of our business and also to persons or organisations such as our funders, professional advisers and regulatory bodies.

We may exchange credit-related information with credit reporting bodies such as Equifax.

Marketing

We may use your personal information to contact you (including by post, phone, text message or email) about products or services which we think may be of interest to you.  This may include our own, our related business’s or a third party’s products or services.  In particular, we may contact you about products and services we think may be of interest to you.  You may opt-out of receiving marketing information from us and our related businesses at any time by contacting us directly on 1300 137 146 or by using the opt-out response available through the marketing communication.

Access and Correction

We will take reasonable steps to ensure your personal information is accurate. You may request access to your personal information under the Freedom of Information Act 1982 (Cth) which we hold by writing to us or emailing us at the address below:

By email:          [email protected]
By post:                        Level 1, 72 Archer Street, Chatswood NSW 2067

You do not have to provide a reason for requesting access. Where we hold information that you are entitled to access, we will endeavour to provide you with the information within a reasonable period.  On request, we will ask you for a form of identification such as a driver licence. A fee for collation, copying and delivery of information may be charged.

If we deem it necessary to deny your application for personal information then we will give you our reasons for denial in writing. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate then you may request it to be amended. We will then consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

Are we likely to disclose your personal information to overseas recipients?

We may transfer your personal information to overseas outsourced services.  If we transfer your personal information outside Australia, we will comply with the requirements of the Privacy Act which relate to trans-border data flow.

Contact us

If you would like any further information, have any questions about this Privacy Policy or any concerns regarding treatment of your privacy or complaints about a breach of the Australian Privacy Principles or the Privacy Act please contact us on 1300 137 146 or by email to [email protected]

We will respond to the complaint in writing within 20 business days and endeavour to resolve the complaint to your satisfaction.  For further information see our Internal Dispute Resolution Policy.  

If you have a complaint about our collection and use of your personal information, you may refer the matter to the Office of the Australian Information Commissioner who will investigate your concerns free of charge to you.  How to contact them:

Website:           www.oaic.gov.au
By phone:         1300 363 992
By mail:            GPO Box 5218, Sydney NSW 2001

This document represents our Privacy Policy as at the date noted below. We may change or update this Policy from time to time.

Date: 3 July 2020