Credit Simple Privacy Policy

Last updated August 2021

Credit Simple recognises the importance of protecting Personal Information about individuals. This Privacy Policy explains how Credit Simple collects, uses, stores and discloses your Personal Information. It also explains how your Personal Information may be used by our Related Bodies Corporate. This Privacy Policy does not limit our rights and obligations under Privacy Laws.

  1. Introduction
    • 1.1 This Privacy Policy sets out how your Personal Information may be collected, used, stored and disclosed by Credit Simple, including where you appoint Credit Simple to request information about you, on your behalf, from a Credit Reporter. By accessing the Credit Simple Website, and/or using our Services you agree to be bound by this Privacy Policy.
    • 1.2 Capitalised terms used in this Privacy Policy have the meaning given to them in clause 16.
  2. Unbundled consents
    • 2.1 Credit Simple uses an “unbundled” approach to our privacy consents. This means that you have control of how we use your Personal Information depending on the Services that you use. For example, you will be asked if you agree to opt into different uses of your Personal Information, when you register for Credit Simple and when you use different Services available on the Credit Simple Website.
  3. Changing this Privacy Policy
    • 3.1 We may amend this Privacy Policy from time to time to reflect changes in applicable laws and our business practices, by publishing an updated Privacy Policy on the Credit Simple Website. We will notify you using the email that you have provided to us of any material changes to this Privacy Policy. The changes will automatically apply to all Personal Information that we hold about you. You should check from time to time to see if any part of this Privacy Policy has been updated.
  4. Personal Information we collect
    • 4.1 We may collect the following Personal Information from or about you, where the information is reasonably necessary for our business purposes, including to provide our Services to you:
      • (a) name, gender and date of birth;
      • (b) driver’s licence or passport details;
      • (c) phone number, email address and residential address;
      • (d) credit information (on behalf of the Credit Reporter) that may be relevant to a correction request or a complaint that you raise through the “Dispute this”function in Credit Simple.
      • (e) any other information that you provide to us or authorise us to collect in connection with a specific service offered on the Website; and
      • (f) information about your use of the Services, including the dates on which and the times at which you use the Services and the duration of such use, the IP address and/or the MAC address of your computer and/or mobile device, device identifiers, the type of operating system and/or other software or firmware used by your computer or mobile device, and your location information, to understand how you use the Services and to improve the Services.
  5. Payment Information
    • 5.1 A Subscription fee applies to the My Alerts service (refer to the Credit Simple Terms of Use). If you make a payment to Subscribe for My Alerts (or to renew your Subscription), our payment services provider (currently Ezidebit) will process your payment. Ezidebit will encrypt and store your payment card number securely, in accordance with Ezidebit’s Privacy Policy available at https://www.ezidebit.com/en-nz/privacy-policy .
    • 5.2 We will never hold your payment card number. However, we may collect the expiry date (to assist us with managing your Subscription renewals) and the last 4 digits of your card number to remind you of your payment method.

     

  6. How we collect your Personal Information
    • 6.1 Personal Information about you may be collected by us in a number of circumstances, including if you: (a) register with us by creating an account; (b) use our Services; (c) lodge an enquiry with us on the Website, by email or telephone; (d) complete any surveys that we issue; or (e) contact us for any reason, including with support queries.
    • 6.2 We collect Personal Information from you directly, unless it is unreasonable or impracticable to do so or if we collect it from the following:
      • (a) Third parties that support our Services – we may collect Personal Information from the following third parties who support our Services: (i) suppliers who supply services to us;
      • (b) Credit Reporter – if you use Credit Information Access Services or My Alerts Subscription Services, we may access your credit score and other credit information from a Credit Reporter (on your behalf when you use Credit Information Access Services and in order to provide My Alerts, in accordance with our Terms of Use);
      • (c) Bank(s) – Money Simple enable you to access information relating to all of your chosen Bank accounts in one place. If you use Money Simple on the Website, in order to make this Service efficient, illion Open Data Solutions (one of our Related Bodies Corporate) may collect all information available from your Bank(s) using your Bank credentials (even if you only request to see part of that information at any particular time, for example, by selecting specific chosen accounts).The information will be updated on a daily basis (for accounts that do not require multi-factor authentication) even if you do not log into your account on the Website. For accounts that require multi-factor authentication which are currently only supported on the Website, your information will be updated each time you authenticate yourself on the Website, using the individual authentication requirement of the relevant bank;
      • (d)Related Bodies Corporate – we may access Personal Information from our Related Bodies Corporate: (a) in order to enhance the services we provide to you; or (b) to receive specialised services in connection with the Services that we provide to you. We will only access Credit Information in accordance with clause 6.2 (b) above.
    • 6.3 We also collect, use, store and disclose non-identifiable information relating to your use of the Credit Simple Website and our Services.
  7. Purpose of collection of Personal Information
    • 7.1 Primary purpose: We collect Personal Information for the primary purpose of being able to operate our business, including to provide Services to you. If you do not provide all of the Personal Information we request (or authorise us to collect that information), you may not be able to use some or all of our Services. Collection of Personal Information for the primary purpose of the Services includes:
      • (a) when you register for Credit Simple, to assess, process and manage your application to use our services – including for identity verification purposes (this includes utilising identity verification service providers and providing identity verification information to a Credit Reporter to confirm your identity);
      • (b) if you use Credit Information Access Services, to enable you to get your credit score and other Credit Information from a Credit Reporter and to enable you to request a Credit Reporting Body to correct and update the Credit Information it holds about you;
      • (c) if you use My Alerts Subscription Services, to update you with Credit Information alerts and email monitoring services;
      • (d) if you use Credit Simple for Business, to verify whether you are a director of a registered New Zealand company in order to notify you, and confirm, that you are eligible to use Credit Simple for Business to enable you to get your Business Credit Information from a Credit Reporter); and
      • (e) if you use Money Simple, to enable you to see your chosen Bank accounts in one place, as well as Money Simple Updates relating to your use of Money Simple.
    • 7.2 Additional purposes: We do not use Credit Information for any purpose other than the primary purposes set out in clause 7.1 (b), (c) and (d) above. For all other Personal Information, In addition to the primary purposes set out above, to the extent permitted by applicable laws, we may collect Personal Information so that we can carry out the following actions:
      • (a) to provide you with a more targeted experience when you use our Services;
      • (b) to validate, update and/or enhance our products, services and databases (including those of our Related Bodies Corporate);
      • (c) assisting identity verification service providers to identify you (this does not involve the disclosure of your information to any other party);
      • (d) to undertake research, analytics and/or benchmarking;
      • (e) to identify and understand user needs;
      • (f) to connect future publicly available data sets into our services;
      • (g) for our business development purposes – for example, see clause 9 below;
      • (h) for any other purpose you have consented to or which is permitted under the Privacy Laws; and
      • (i) for internal record keeping, audit and compliance purposes and to comply with our legal and regulatory obligations.
  8. Disclosure of Personal Information
    • 8.1 You authorise us to disclose Personal Information to any of our Related Bodies Corporates for the purposes set out in clause 7.
    • 8.2 In addition, we may disclose Personal Information to:
      • (a) the Credit Reporter – if you use Credit Information Access Services, My Alerts Subscription Service or Credit Simple for Business – refer to clause 8.3 below;
      • (b) illion Open Data Solutions – if you use Money Simple Services – refer to clause 8.4 below;
      • (c) Our service providers – such as identity verification service providers, Google Analytics, (refer to clause 8.5 below), identity theft monitoring service providers, social media & IT suppliers/contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants, auditors, and other service providers, who need to have access to your Personal Information to provide their services to us;
      • (d) Organisations that provide products or services used by us – including intermediaries, trustee companies, financial institutions and securitisers;
      • (e) Other – (i) our employees or contractors to the extent reasonably necessary to fulfil our obligations to you; (ii) anyone considering acquiring an interest in our business or assets; (iii) other entities or persons to the extent reasonably necessary for the purposes set out in clause 7 above; (iv) any law enforcement, legal, government or regulatory agency, where such disclosure is required or authorised by law; and (v) other individuals or companies authorised by you.
    • 8.3 Credit Reporter – If you use Credit Information Access Services, My Alerts Subscription Service or Credit Simple for Business, you also acknowledge and agree that we may disclose your identity verification information and contact details to a Credit Reporter. The relevant Credit Reporter Body may use that information to update or correct information held by it (including to create a record and credit score if you don’t already have one) and to provide its credit reporting services. The collection, use, storage and disclosure of Personal Information by a Credit Reporter, and your rights to request access to and correction of that information, is subject to the Credit Reporter’s privacy policy. For more information about how a Credit Reporter may collect, use, store and disclose your Personal Information, please refer to the Privacy Policy at https://www.illion.co.nz/privacy-policy-risk-marketing-solutions/.
    • 8.4 illion Open Data Solutions – the provision of Money Simple Services, on the Website, is made possible through the specialised services provided to us by illion Open Data Solutions. You must read illion Open Data Solutions End User Terms at https://www.bankstatements.com.au/about/terms. If you use Money Simple, you authorise us to disclose your Money Simple Information to, and to collect your Money Simple Information from, illion Open Data Solutions and you authorise illion Open Data Solutions to use your Money Simple Information in accordance with illion Open Data Solution’s Privacy Policy available at https://www.illion.co.nz/privacy-policy-risk-marketing-solutions/.
    • 8.5 Third Party Analytics – We use Google Analytics (on the Website) to gather, collect and analyse the activities of visitors and users of our Website in order to conduct research and analysis to improve our products, services, and content. You authorise the use of cookies and other tracking technologies to enable Google Analytics to understand visitor or user behaviour on the Website. Such access to and use of information collected by Google and Apple are governed by Google’s Privacy Policy.
    • 8.6 Linked Sites – Our Website may link directly to websites operated by third parties (Linked Sites). You acknowledge that Linked Sites are not operated by us. We are not responsible for the content or practice of the Linked Sites or their privacy policies regarding the collection, storage, use and sharing of your Personal Information. We encourage you to always read the applicable privacy policy and terms and conditions of any Linked Site.
    • 8.7 You acknowledge that we do not control and are not responsible for any use of Personal Information by any third party that you disclose, or authorise us to disclose, your Personal Information to.
    • 8.8 Email monitoring – If you Subscribe for Email Address Monitoring Alerts we will provide email monitoring services. However, Credit Simple does not share any personal information (including your email) with any service provider in connection with email monitoring services. Credit Simple will undertake searches to identify if your email address is part of a breach. Only an anonymised extract of your email address will be shared with a service provider in connection with this service.
  9. Communications from us
    • 9.1 From time to time we may use your Personal Information which we hold to provide you with factual information about our services, including by mail, email, SMS, social media, telephone and other electronic means. These may include essential information such as Privacy Policy and Terms of Use updates.
    • 9.2 We may send you My Alerts (including Credit Information alerts and Email Monitoring Alerts when you subscribe to those services) , in accordance with our Terms of Use. These will include factual information and updates about your Credit Information.
    • 9.3 If you use Money Simple, we will send you Money Simple updates to provide you with factual information and updates about your use of Money Simple and connected financial institutions (Money Simple Updates). These are not Marketing Communications. Credit Simple may send you Money Simple Updates until you terminate or suspend your use of Money Simple by removing all of your chosen accounts (refer to the Terms of Use).
  10. Sending information overseas
    • 10.1 We operate in both Australia and New Zealand so your Personal Information may be accessible in both countries to ensure we are able to provide our services to you.
    • 10.2 Personal Information that we collect is either held by us (at our offices in Australia and New Zealand) or on our behalf. Some information we hold may be stored in “the cloud” in databases on our behalf locally or overseas.
    • 10.3 We take reasonable steps to ensure that Personal Information disclosed to third party service providers are subject to comparable privacy safeguards. Please be aware that where your Personal Information is disclosed to a third party service provider, or other entity, they also may use cloud based processes located outside of Australia or New Zealand. We do not control where these service providers may allow Personal Information to be accessible including overseas.
  11. Provision of information about others
    • 11.1 Please be aware that the Terms of Use prohibit the use of Services on behalf of any other person. We will not ask you to provide us with information about someone else. However, if you provide unsolicited Personal Information to us about someone else, you must ensure that you are authorised by the relevant individual to disclose their Personal Information to us for the purpose for which it is provided.
  12. Use of Cookies
    • 12.1 We may use technology known as a “cookie” to collect statistical information about you when using internet browsing, mobile or tablet applications. Cookies are small pieces of information captured when your device is used to access online content. They can record information about your visit to the Website, allowing it to remember you the next time you visit and provide a more meaningful experience.
    • 12.2 You can switch off cookies by adjusting the settings on your web browser. If you disable the use of cookies on your web browser or remove or reject specific cookies from the Website or the Linked Sites then you may not be able to gain access to all of the content and facilities on those sites.
  13. Storage & Security
    • 13.1 We will use all reasonable endeavours to keep your Personal Information in a secure environment, however this security cannot be guaranteed. Our procedures are designed to prevent your Personal Information being accessed by unauthorised personnel, lost or misused. If you reasonably believe that there has been unauthorised use or disclosure of your Personal Information, please contact us immediately using the contact details below.
    • 13.2 Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving Personal Information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Law requirements.
  14. Your access to your Personal Information
    • 14.1 It is important to our relationship that the Personal Information we hold about you is accurate and up to date.
    • 14.2 You may request access to any of the Personal Information we hold about you at any time. To request access to the Personal Information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
    • 14.3 We will respond to your request within a reasonable period of time and, where reasonable and practicable, grant access to the information in the manner requested. An explanation will be provided to you if we deny you access to your Personal Information we hold.
    • 14.4 If you consider that any information we hold about you is incorrect, you should contact us to request that it is updated. Please let us know if there are any changes to the Personal Information you have provided to us. While we take reasonable steps to ensure that the Personal Information held by us is up to date, we will generally rely on you to assist by informing us if the information we hold about you is inaccurate or incomplete.
  15. Further Information and complaints
    • 15.1 You may request further information about the way we manage your Personal Information including how to access, request deletion, request a correction or lodge a complaint by contacting us using the contact details below.
    • 15.2 We will deal with any complaint by investigating the complaint, and providing a response within 20 days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree an alternative time frame with you.
  16. Definitions and interpretation
    • 16.1 Capitalised terms have the meanings given to them in the Credit Simple Terms of Use and:
      • (a) illion Open Data Solutions End User Terms means the end user terms available at https://www.bankstatements.com.au/about/terms.
      • (b) Privacy Policy means this privacy policy, as amended from time to time.
      • (c) Terms of Use means the Credit Simple Terms of Use (as amended from time to time) available on the Credit Simple New Zealand website at creditsimple.co.nz
  17. How to contact us