Privacy Policy

INTRODUCTION
Privacy matters to us and we know It matters to you. We are committed to protecting your privacy, keeping your information safe and ensuring the security of your data.

This Privacy Policy sets out the way we collect, use, disclose and manage personal information. It extends to both our control and processing of personal information., It also incorporates our Credit Reporting Policy which lets you know how we use any credit related information we might collect.

By using the Website, buying our products or services or entering into an agreement with us in relation to the Website, our products or our services, you are taken to have read, and agreed to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.

This current policy came into effect on 1 September 2021. We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes, as we will post any updates on our Website. Any changes to this Privacy Policy for users of our Website which are not customers become effective immediately upon being
published online and for our customers become effective on the date nominated by us which must not be less than 30 days after we give you notice of same in writing.

DEFINITIONS

The following definitions apply to this Privacy Policy:

1. “Credit Information” includes without limitation any of the following:
   1. identification information (such as your name, address, date of birth and/or employer)
   2. details about information requests made about you to credit reporting bodies
   3. current and historical details about credit applications you have made and credit arrangements you have entered into
   4. information about overdue payments, default listings, serious credit infringements, payments made on overdue payments or subsequent arrangements in relation to either of these
   5. various publicly available information like bankruptcy, insolvency and credit-related court judgments
   6. credit scores or risk assessments indicating an assessment of your credit worthiness
   7. consumer credit accounts you hold with other credit providers
2. “Website” means protectortrade.com.au;
3. “We”, “Us” and “Our” means Protector Trade Pty Ltd A.C.N 652 315 430.

INFORMATION WE COLLECT ABOUT YOU

The types of information we collect depends on how you use our products and services as well as the relationship we have with you as a customer.

This can include basic information like your name, date of birth, gender, personal interests, contact details (including address, email address, phone number or mobile telephone number) occupation, driver’s licence or passport number, username or password, other information you provide to us and financial information (such as credit card or bank account numbers).

If you access our Website through a social network site or login to our Website using your social network credentials such as Facebook, we will collect limited information provided to us by that social network site, such as user name, site ID, profile photo and email address.

If you submit personal information to us in relation to an employment opportunity, we may also collect information about your employment and academic history.

We may also collect non-personal information about you including, but not limited to, data relating to your activities on the Website (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.

You acknowledge that the personal information you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us.

We may also collect more in-depth information including:

• Financial and Credit Information related to your financial relationship with us, such as your income details, payment history, your credit history and your service history. For more details, see the section on Credit Reporting below.

Information about how you use our Website such as:

• How you use our Website;
• Your location or the location of your devices when you are using our Website;
• Information that allows us to identify you for verification purposes including, when you have given us permission to do so, biometric information like your fingerprints and voice patterns.

Sensitive information includes information about a person’s race, ethnic origin, political opinions, health, religious or philosophical beliefs and criminal history. We may collect some forms of sensitive information. We are subject to strict requirements in relation to sensitive information including to only collect and use sensitive information with consent or otherwise in accordance with applicable law such as the Commonwealth Privacy Act 1988.

You might also need to provide personal information about other individuals to use (e.g. about your authorised representative). If so, we rely on you to have informed those individuals that you are giving their personal information to us and to have advised them about this statement.

It is important to be aware that if you access another party’s website or application using one of our products, that other party will deal with your personal information in accordance with its own privacy policy.

HOW WE COLLECT YOUR PERSONAL INFORMATION

There are several ways that we can collect your information, including but not limited to:

1. You give it to us when you or your representative interacts with either us, or one of our trusted partners. This might happen when you are:
   1. Registering to use the Website or parts of it through an account,
   2. Using our Website.
   3. Logging in to use our Website via your social networking site account;
   4. Subscribing to receive alerts, e-brochures or updates;
   5. Completion of any forms, applications, surveys, research;
   6. Participating in promotions;
   7. Contacting us for any reason including, but not limited to reporting a problem with the Website, requesting further services or seeking our assistance;
   8. Emailing us or calling us for any reason, including without limitation to engage us to provide you with products or services;
   9. Purchasing any products or services from us; and
   10. Using any credit provided by us in connection with our products and services.
2. We collect information when you use our Website and services including calling us and any online services and queries. For example, we may use cookies, web beacons and other technologies to identify your unique web browser. If you do not want information collected through the use of cookies, web beacons or measurement software, you may be able to delete or reject cookies or some of the measurement software features through your browser or the settings section of your device. Disabling these functions may cause some of the functions on the Website to not work properly.
3. We obtain information from outside sources like credit reports, marketing mailing lists, and public information, (including public posts to social networking sites and our Website) and commercially available personal, identity, geographic and demographic information. This can also include information gained from our partners if you have interacted with them. These partners include our business and commercial partners, identity and fraud checking services, credit reporting bodies and wholesale and other customers.

We understand that you might not want to give us particular personal information. If so, that may mean we are not able to provide you with the products or services you need.

HOW WE KEEP YOUR INFORMATION

We strive to ensure the security, integrity and privacy of personal information we collect. We have established safeguards and use reasonable security measures to protect your personal information from unauthorised access, modification and disclosure. Our employees, contractors, agents and service providers who provide services related to our computer systems and Website, are obliged to respect the confidentiality of any personal information held by us. We review and update our security measures in accordance with industry standards. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.

We may store your information in hard copy or electronic format and keep it in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.

We endeavour to ensure that personal information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some personal information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

HOW WE USE YOUR PERSONAL INFORMATION

We use the personal information we have collected largely for the purpose of providing you with products and services that you have requested, responding to your inquiries, creating and maintaining your account and ensuring you comply and adhere to any terms of use applicable to the Website.

We will only use your information if we have a lawful reason to do so such as when it’s our legal duty or we have your consent and when it’s in our legitimate interest to do so. These include, but are not limited to:

Administration

• To help us properly manage our Website (to ensure that content from the Website is presented in the most effective manner) and the products and services we provide to you and to maintain and update our records. For example, we need to be able to verify your identity to detect, prevent and address fraud. We also use your information for charging and billing (if applicable) and to identify breaches of any terms and conditions applicable to the products and services we are providing to you.
• We may combine your personal information with information that the Website has collected from its service providers, third parties, cookies or web beacons in order to provide you with a better or more relevant and personalised experience and to improve the quality of our Website, products and services. For example, we may combine behavioural data we have collected about you through the use of cookies or web beacons and combine it with your personal information from requests you send to third parties through the Website.
• Personalise and customise your service, experience, advertising and content that you view and engage with on the Website.
• Verify your identity when you register or log in to our Website.
• Remind you of your password and username for your login to our Website.
• Allow you to participate in any interactive features of the Website.
• Assess your application for credit for any services and products provided by us.
• Notify you of changes to our Website, products or services provided by us.
• Disclosing information to debt collection agencies to recover any amounts you owe us.

Communication
We need to be able to communicate with you in order to provide you with our products and services, and to respond to you. We might do this on mediums such as email, SMS, social media, and our Website.

Development and analysis
It’s important we understand your information needs. One of the ways we do this through using analysis and business intelligence techniques. This gives us high level insights into things like usage patterns, demographic trends and other types of behavioural data. In many cases this information is aggregated and de-identified when analysed. We may share these anonymized insights with select business and commercial partners. In some cases, we may create insights with your information on an identified basis but would only do so in compliance with privacy laws (such as, with your consent).

Direct Marketing
We want to make sure that you know about all our products, services and special offers that are relevant and are of interest to you. We may use the information we hold to market and promote them directly to you. This also may include products, services and offers provided by our trusted partners. In some cases, this marketing activity can continue after you have stopped using our products or services, unless you opt-out. You can stop us using your information for direct marketing by updating your preferences by logging into your account or by calling us on the contact details at the end of this Policy.

Compliance
There are a number of circumstances where we are required or authorised by laws to collect, use or disclose information. These include:

• As required or authorised by legislation
• As required by or in accordance with any industry code or industry standard
• When we need to undertake identity checks for any services and products we provide

Improvement
We are constantly working to not only maintain and improve our products, services and processes but to develop new ones. We use information we hold to help us do this in a number of ways. For example, to monitor Website use, quality and performance, and to operate, maintain, develop, test and upgrade our systems and infrastructure. We may also combine information from one service with formation from one of our partner’s services to improve our credit assessment and debt recovery processes. We may also contact you to conduct surveys, research and feedback about our Website, products and/or services.

DISCLOSURE OF YOUR INFORMATION
We may disclose your information with other parties who provide services to us, including organisations, agents, partners and contractors that assist us with providing our business processes, products, services and Website. These services include:

• Providing, managing or administering our Website
• Mailing operations, billing and debt-recovery functions
• Information technology
• To develop our credit assessment and credit worthiness rating system
• Fraud, crime or misconduct identification, investigation and prevention services
• Market research, marketing, telemarketing and door-knocking services
• Development, analysis and business intelligence functions.

We may also disclose your information to:

• Your authorised representatives or advisers
• Other parties such as real estate agents, builders, landlords, financiers, brokers or any other persons when you ask us to do so
• Other parties when you consent to that disclosure for the purposes of fraud, crime or misconduct identification, investigation and prevention services
• Credit- reporting bodies (for more information see the Credit Reporting section below) for identity checking and credit related purposes such as credit worthiness, credit rating, default listing, credit provision and financing. These include:

▪ Equifax
Telephone: 13 83 32
Address: Equifax, Customer Resolutions Team, PO Box 964 North Sydney NSW 2059
Online: www.mycreditfile.com.au/

▪ Illion Australia
Telephone: 1300 734 806
Email: PACAustral@illion.com.au
Online: www.checkcheckillion.com.au

▪ Experian Australia Credit Services Pty Ltd
Telephone: 1300 783 684
Email: creditreport@au.experian.com
Onilne: www.experian.com.au

• Our related entities or our business or commercial partners and other businesses we work with.
• Parties that assist us with fraud and identity checking including financial institutions and the Government’s National Document Verification Service, to verify the validity of any Government issued documentation you provide as proof of identity i.e.: to check a Drivers Licence, Medicare, Passport etc.
• Law enforcement and national security agencies, and other government and regulatory authorities as required or authorized by law
• Other parties who assist us in managing or developing our business and corporate strategies and functions, including our corporate risk or funding functions
• Financiers, investors or other participants and parties (such as service providers and ratings agencies) and advisers involved in any sale of our debts, securitization or other financing arrangement (for example, a sale of amounts payable to you to us)
• Other parties as required by or in accordance with any industry code or industry standard
• Government agencies as required
• And for the purpose of facilitating or implementing a transfer/sale of all or part of our assets or business.

In some cases, the organisations that we may disclose your information to may be based outside the location where the information is collected, including outside Australia.

Where we do this, we require these parties to take appropriate measures to protect that information and to restrict how they can use that information.

CREDIT REPORTING
If you apply to us for credit, we may disclose your personal information and Credit Information to:

1. credit reporting bodies (for the purpose of obtaining credit reporting information about you and other permitted purposes – see our Credit Reporting Policy below for more details); and
2. other credit providers, existing or previous suppliers of goods or services, your bank and certain other businesses for the purposes of assessing your application; Credit Information relates primarily to your dealings with other credit providers (for example banks, other financial institutions, or other organisations that may provide you with credit in connection with their products or services). It may also include certain credit worthiness information that we derive from the data that we receive from a credit reporting body. Sometimes we may collect this information about you from other credit providers.

We may disclose your Credit Information to credit reporting bodies. They in turn may include it in credit reporting information they provide to other credit providers to assist them to assess your credit worthiness.

We may use or disclose your Credit Information for purposes such as:

• developing our credit assessment and credit worthiness rating system
• processing credit-related applications and managing credit that we provide
• assisting you to avoid defaults
• collecting amounts, you may owe us in relation to such credit and dealing with serious credit infringements
• assigning our debts or acting in connection with any securitisation or other financing arrangement
• participating in the credit reporting system
• dealing with complaints or regulatory matters relating to credit or credit reporting
• when required or authorised by another law
• those purposes under the “How we use your personal information” and “Disclosure of your information” sections above, except in relation to information we collect from credit reporting bodies.

HOW YOU CAN ACCESS OR CORRECT YOUR PERSONAL INFORMATION
It’s important that you make sure the personal information we hold about you is accurate, up-todate and complete. If for any reason your details change or you discover the information held about you is incorrect, you can update them by contacting us using the contact details at the end of this policy.

You also have the right to request a copy of your information that we hold about you, subject to exceptions provided for by law. There is no charge to submit a request or to correct information, however we may apply an administrative charge for providing access to your personal information on request. To make this request please contact us on the details at the end of this policy.

APPLICATIONS, WIDGETS OR LINKS TO OTHER WEBSITES
We provide links to websites outside of the Website. We also allow some third parties to display widgets and applications on our Website that allow you to interact and share content including social media buttons such as Facebook share and like, Twitter, Pinterest and Google+. These linked sites, applications and widgets are not under our control, and we cannot accept responsibility for the conduct of companies linked to the Website, or their collection of information through these third party applications or widgets. Before disclosing your personal information on any other website, or using these applications or widgets we advise you to examine the terms and conditions of using that website and the relevant third party’s data collection practices and controls in their privacy policy.

PRIVACY COMPLAINT
We are committed to providing you with a fair and responsible system for handling of complaints.

You can use our contact details to notify us of any privacy concerns, complaints or questions in relation to your privacy or the operation of our Website.

If your complaint is in relation to a credit reporting issue, we may need to consult with a credit reporting body or another credit provider to investigate your complaint.

While we hope that we will be able to resolve any complaints you may have without needing to involve third parties, you may also be able to lodge a complaint with a relevant regulator such as the Australian Information Commissioner at www.privacy.gov.au.

CONTACT US
If you have any questions in relation to this Privacy Policy, our management of your information or you would like a copy of this statement sent to you, please call us on 07 5476 5022 or email us at trade@protectortrade.com.au.