Privacy Policy

1. PURPOSE

This policy outlines the way that Incredo Pty Limited ACN: 602 432 146 (“we” or “us”) collects, protects and handles personal information and credit reporting information.

2. SCOPE

This policy applies to personal information we handle about our customers, visitors to our website https://incredo.com and users of products and services we may from time to time provide, including credit applicants. It provides information about the personal information we collect and the ways in which we use that personal information.

This policy also includes our credit policy, that is, it additionally covers how we manage any credit reporting information (as that term is defined in the Privacy Act 1998 (Cth) as amended from time to time (“Act”)) that we may collect or derive in connection with the services we provide.

By accessing our website or using our products or services, you agree to be bound by the terms of this policy.

This policy will be reviewed from time to time to take account of new laws and/or changes to our operations. Any information we hold about you will be governed by our most current policy. We recommend that you periodically review this policy for any changes.

3. OBJECTIVE

We recognise that your privacy is very important to you and we are committed to protecting your personal information in accordance with the Act including the Australian Privacy Principles (“APPs”) and any other applicable laws. To the extent that we hold any credit reporting information, we will handle that information in accordance with the credit reporting provisions of the Act and any registered credit reporting privacy code that applies to credit reporting bodies.

4. POLICY

4.1 THE KINDS OF INFORMATION WE COLLECT AND HOW WE COLLECT IT

The kinds of personal information we collect may include your name, date of birth, contact details, employment related information including job title and work contact details and bank account details. We may collect and disclose government related identifiers such as your driver’s licence number in order to verify your identify.

We may also collect any other information (including personal information) contained in bank account statements or relating to your bank accounts or financial institution which you permit us to access, and any information from your myGov Account where you allow us to access this information. This information may include credit information (as that term is defined in the Act). We may also collect the following kinds of credit information: repayment history information, payment default information, details about credit commencement and expiry dates and credit terms and conditions, serious credit infringement information and court proceeding information.

This is not an exhaustive list of the types of personal information which we may collect. There may also be other types of information that we collect which is not strictly personal information (as that term is defined in the Act). Other information relevant to assessing your eligibility for credit and credit worthiness may include details of your assets and liabilities including existing debts, details of the type of credit you are applying for and details of dependants. Nevertheless we will handle any such information in accordance with this policy.

Generally we collect personal information and credit information when you voluntarily provide it to us or allow us to access it from third parties such as financial institutions, such as when you enter your personal information into forms on our website or other online products. We may also collect personal information and credit reporting information from third parties that we deal with, such as credit providers or other credit reporting bodies, and publically available sources.

4.2 HOW WE USE PERSONAL INFORMATION AND CREDIT INFORMATION

We process the information we collect into summaries, reports, scores and ratings that may be used by credit providers to determine your eligibility for credit and your credit worthiness. Any such raw and derived information will be held by us and disclosed in accordance with this policy. Any personal information we collect is used solely to identify you and your credit file.

4.3 DISCLOSURE OF INFORMATION

To the extent that we hold any credit reporting information about you, we may disclose this information in any circumstances in which we are permitted to do so under the Act and any registered credit reporting privacy code, including to other credit reporting bodies.

We may disclose your personal information (including credit reporting information) to the extent that we are required to do so by law, including in connection with any legal proceedings or anticipated legal proceedings, or in order to comply with any legal obligation, or to establish, exercise or defend our legal rights. We may sell, transfer, or otherwise disclose our database of personal information to an actual or potential successor entity, purchaser, or investor in connection with a corporate merger, consolidation, sale of our assets or a substantial part of our assets, share sale, investment transaction or other corporate rearrangement.

You agree that we may disclose your personal information and any credit reporting information in any of these circumstances. We disclaim all liability for any privacy breaches by third parties to whom we have disclosed your personal information in accordance with this policy.

4.4 DISCLOSURES AND TRANSFERS OF INFORMATION TO OVERSEAS RECIPIENTS

Personal information and credit reporting information that we collect may be transferred and stored outside of Australia between any of the countries in which we, our related entities or our service providers operate. Such countries are likely to include United States of America, Canada, Germany, United Kingdom, France, Italy, Spain and Ireland. It is not practicable to specify all the countries in which such overseas recipients may be located.

The Act and corresponding APPs require relevant Australian entities to ensure that, before disclosing personal information overseas, reasonable steps are taken to ensure that overseas recipients do not breach the Act or the APPs (APP 8.1). It is not always possible to ensure that overseas recipients will comply. We do not take any responsibility for the actions of overseas third party recipients of personal information. By agreeing to this Privacy Policy you are agreeing that your personal information (including credit reporting information) may be disclosed overseas and that APP 8.1 will not apply to that disclosure. This means that you will not have recourse against us under the Act in the event that an overseas recipient of your personal information breaches the APPs.

Your personal information may also be transferred overseas if we sell, transfer or disclose our database of personal information to an actual or potential successor entity, purchaser or investor who is located or has offices overseas. It is not practicable to specify the likely countries in which recipients of information may be located in this regard.

4.5 SECURITY OF INFORMATION

Once in our possession, we take all reasonable precautions to protect the personal and credit reporting information we hold about you from misuse, interference and loss and unauthorised access, modification or disclosure.

Whilst we endeavour to provide a secure online environment, there are inherent risks associated with the transmission of information via the internet and no data transmission over the internet can be guaranteed to be completely secure. We therefore cannot warrant the security of any information you provide to us over the internet and you do so at your own risk.

We encourage you to play an important role in keeping your personal information secure, by maintaining the confidentiality of any passwords and account details used on our website or other online products. It is your sole responsibility to maintain such confidentiality and we will not be liable for any damage, loss or expense suffered due to such disclosure.

4.6 WEBSITE ACCESS AND USE

Cookies (files that are implanted in your hard drive to store information about your web use patterns) may be used by us to collect information such as IP addresses of visitors to our website. Cookies also allow us determine who has seen particular pages on our website and how frequently. This can help us to identify your preferences and allow us to recommend content we believe you would be most interested in or would be most relevant to you.

We, and our third party service providers including Google, may also use cookies to show you ads about our products and services on websites other than our own. These ads are based on your past visits to our website. You may opt out of Google’s use of cookies for interest-based advertising by visiting the following web page: http://www.google.com/settings/ads. You can also adjust your browser settings to disable cookies and remove advertising from the pages you visit, although in doing so you may lose some of the features and functionality of our website.

For each visitor to reach our website, we expressly collect the following anonymous information: browser type, version and language, operating system, pages viewed while browsing our website, page access times and any referring website address. This information is used solely for internal purposes, such as gauging visitor traffic, trends and delivering personalised content to you while you are browsing our website. This information is generally automatically provided to us by your web browser.

4.7 THIRD PARTIES

Our products may be imbedded in third party websites or online products or forms. We are not responsible for the privacy policies or practices of any third party. Any information you provide to third parties will be handled in accordance with their privacy policies and practices. We encourage you to read the applicable privacy policy whenever interacting with any third party website or online product.

4.8 ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

We aim to ensure that all personal information and credit reporting information we hold is accurate, complete and up-to-date. To assist us, please contact us via the details below if any of your details provided have changed or if you believe that the information we hold is otherwise inaccurate, out-of-date, incomplete, irrelevant or misleading.
• By email to compliance@incredo.com
• At our website https://incredo.com using the contact us facilities
• By mail to The Compliance Department, GPO Box 7030 Brisbane QLD 4001
• By telephone on 1300 918 875
You may also request us to provide you with access to any personal or credit reporting information we hold about you at any time. We will endeavour to provide you with the copies of the information you require or to correct your information within a reasonable time following receipt by us of your request. Prior to providing you with any such information it will be necessary for you to satisfactorily verify your identity. There are exceptional circumstances where access to or correction of your personal or credit reporting information may be refused by us such as where access would be unlawful. We will advise you of such circumstances if they arise. Where your request for correction relates to credit reporting information, we may have to consult third parties (such as a credit provider or a credit reporting body) in order for us to be satisfied that the information sought to be corrected is indeed in-accurate, out-of-date, incomplete, irrelevant or misleading.

If a fee will apply to supply of the information, we will advise you as soon as reasonably possible following receipt of your request for that information.

4.9  ELECTRONIC TRANSACTIONS

Customers who wish to purchase a product from Incredo can do so through the Incredo website, or another site affiliated with the business. A variety of payment methods are offered, including:

  • credit card;
  • debit card;
  • PayPal; or
  • Visa Checkout.

Clients who subscribe to Incredo Analytics can also process payments through the website at their discretion.

Payments made through the website go through a payment gateway which is a secure link between the website and the bank. The gateway receives the information and sends it to the bank to be verified. The bank then replies with an appropriate response confirming the payment or a notification that it has failed through the gateway which is delivered to the user. The bank has the appropriate security measures in place to protect your banking information. Incredo does not store any of your card details, and the banks standards are compliant with PCI DSS.

4.9 CONTACT US

If you have queries or concerns about how we manage your personal information you may contact our internal dispute resolution (‘IDR‘) team on 1300 918 875 or use our email facility on our websitehttps://incredo.com. We will endeavour to provide you with an acknowledgement upon receipt of your query or complaint and resolve it within 30 days.

In the event you are not satisfied with the resolution provided by us, you may contact the Information Commissioner using the OAIC website http://oaic.gov.au or telephone 1300 363 992.