Privacy and Collection Notice

ABOUT US (“WE, US, OUR”):

Licensee: Polar Finance Pty Ltd ACN 670 356 644 Trading as Polar Finance

Australian Credit Licence Number: 552744

Our Contact Details:

The Privacy Act 1988 (Cth) (the Act) allows for ‘personal information’, including ‘sensitive information’, ‘credit information’and ‘credit eligibility information’ (terms defined in the Act) about you to be collected, used and disclosed provided we have obtained your consent. This privacy policy tells you how we collect personal information about you, what we use the personal information for and who we share the personal information with. This will include obtaining / sharing information (including personal information) about you with (among other organisations) a Credit Reporting Body.

We will, in relation to your application for credit and any guarantee in respect of any credit, collect personal information from you. Most personal information we collect is collected from the credit application and supporting documentation supplied / to be supplied. If your credit application is approved, we also collect personal information from the records we maintain about the products and services you receive. We can check and verify that personal information from sources referred to in the credit application and/or in this document.

We will only collect personal information from other sources where it is reasonably necessary for us to do so, in relation to your credit application, your loan and any guarantee, including to comply with our responsible lending obligations under the National Consumer and Credit Protection Act 2009 (Cth). Examples include:

-personal information (including commercial credit information concerning your credit history or worthiness, consumer information and collection of overdue payments information either within or outside of Australia) from a Credit Reporting Body for any purpose described below;

-personal information about your credit application, loan or a guarantee of the loan, from other organizations, such as other credit intermediaries and mortgage and title insurers;

-if we are unable to contact you and we obtain publicly available personal information about you in order to update our records and contact details;

-checking property details, your offer of any security, through public registers or our service providers including a Credit Reporting Body; or

-we exchange information with your legal, financial advisers or other representatives and advisers in relation to or in connection with your credit application, loan or a guarantee of the loan.

There are laws that require us to collect and disclose personal information about you. For example, we are required to collect and disclose your personal information for assessment and verification under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) and any rules, regulations or guidance notes made under or in connection with that Act (“AML/CTF Act”).

We may collect and disclose your personal information for purposes including:

-supplying you with information about loan products or related services;

-considering whether you are eligible for a loan, any related service you request or to provide a guarantee;

-processing the credit application and providing you with a loan or related service;

-administering your loan or any related service, for example, to respond to requests or complaints;

-identifying and verifying your identify;

-allowing us to run our business efficiently and to perform administrative and operational tasks;

-preventing or investigating any fraud or crime or any suspected fraud or crime;

-as required by any law, regulation or code binding on us; and

-any purpose to which you have consented.

We may use personal information about you to:

-enable an insurer (which includes the Lenders Mortgage Insurers listed in the Schedule) to assess the risk of providing insurance to us or to address our arrangements with the Insurer;

-assess whether to accept a guarantor or the risk of a guarantor being unable to meet their obligations;

-consider hardship requests; and

-assess whether to securitise loans and to arrange securitising loans the lender makes.

We may use and share your personal information with other organisations for any purpose described in this policy.

-your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); and

-your referees, like your employer, to confirm details about you.

We may share your personal information with third parties (including those parties identified in the Schedule) in relation to services we provide to you or services that we reasonably consider you may be interested. Those third parties may include:

-the mortgage manager, the Polar Finance Group (refer to the schedule), through whom we may submit loan applications to Credit Providers (refer to the schedule);

-the Credit Providers (refer to the schedule), Lender’s Mortgage Insurers (refer to the schedule) and other loan intermediaries;

-financial services suppliers with whom we have arrangements;

-property valuers;

-organizations that assist us to carry out identification / verification of identity checks

-organisations, like fraud reporting agencies that may identify, investigate and/or prevent fraud, -suspected fraud, crimes, suspected crimes, or other misconduct;

-government and regulatory bodies as required or authorised by law including, the Australian Securities and Investments Commission, the Australian Financial Security Authority and AUSTRAC. These government or regulatory bodies may also share the information with relevant foreign authorities;

-service providers, agents, contractors and advisers that assist us to conduct our business;

-guarantors and prospective guarantors of your loan;

-referrers that referred your business to us;

-any organisation that wishes to take an interest in our business or assets; and

-any third party to which you consent to us sharing your information.

Sharing with Credit Providers

You should read the Privacy Policies and Credit Reporting Policies of the Credit Providers. These policies contain information about how you can access and seek correction of your personal information (including credit related personal information) and how you can complain about a breach of the privacy laws by them and how they will deal with a complaint. The policies also explain whether they will disclose personal information (including credit related personal information) to overseas entities, including related entities, and the countries those recipients are located in including USA, Canada, the Philippines, European Union, Asia Pacific and the United Kingdom. Further information on overseas disclosure may be found in the Credit Providers Privacy Policies and Credit Reporting Policies (a link to their Privacy Policy and Credit Reporting Policy is referred to in the Schedule).

Sharing information with Credit Reporting Bodies

We, the relevant Credit Provider and the Lenders Mortgage Insurer can give to and receive from a Credit Reporting Body (refer to the schedule) personal or commercial information about you including to allow a Credit Reporting Body to create or maintain a credit information file about you. The information may include:

-identification information including to have your identity information verified with the Issuer or Official Record Holder via the Credit Reporting Bodies systems for the purpose of verifying your identity;

-consumer credit liability information;

-repayment history information;

-a statement that an information request has been made in relation to you by us, a Credit Provider or a Lenders Mortgage Insurer or trade insurer;

-the type of consumer credit or commercial credit, and the amount of credit, sought in an application that has been made by you, and in connection with which we have made an information request in relation to you, default information, payment information, new arrangement information, court proceedings information, personal insolvency information;

-publicly available information that relates to your activities in Australia or the external Territories and your credit worthiness and that is not court proceedings information about you or information about you that is entered or recorded on the National Personal Insolvency Index;

-in ours or a Credit Provider’s opinion that you have committed, in circumstances specified by us, a serious credit infringement in relation to consumer credit provided by us or a Credit Provider to you.

A Credit Reporting Body may include information about you in reports that it gives other organisations (such as other credit providers and insurers) to help them assess your credit worthiness. In some cases a Credit Reporting Body may use your personal information for pre-screening your eligibility to receive direct marketing from us or other credit providers. If you do not want a Credit Reporting Body to do this contact the credit reporting body.

Some of the information held by a Credit Reporting Body may reflect adversely on your credit worthiness, for example, where you fail to make payments or if you commit a series credit infringement (like obtaining credit by deception / fraud). If information of this nature is held on your credit file then this will likely affect your ability to obtain credit from other credit providers.

Currently we deal with the Credit Reporting Bodies disclosed in the Schedule. Each Credit Reporting Body also has a policy about how they handle information about you. You should be able to obtain a copy of their policy by contacting them directly.

We will only share any credit information about you with a Credit Reporting Body if that body has a business operation in Australia and is unlikely to share credit eligibility information with organisations that do not have business operations in Australia.

We may share personal information about you with our related companies for the purposes described above.

We may disclose your personal information to organisations overseas, most likely Chinese and the Philippines. We may store your personal information in cloud or other types of networked or electronic storage. We will take reasonable steps to ensure that any overseas organisation that receives your personal information will comply with the Act.

We take reasonable steps to protect all information which we hold (including any personal or sensitive information) from misuse, loss, unauthorised access, modification or disclosure.

We may also use the information including personal information provided by you for marketing and research purposes, to analyse and improve products and services and to inform you of products and services provided by us, our related entities or preferred suppliers which we consider may be of value or interest to you, unless you tell us or have previously told us not to. You can tell us at any time if you no longer wish to receive direct marketing information or other offers from us. We will process your request as soon as reasonably practicable after receipt of the request.