Rumo Finance Pty Ltd Privacy Policy 

1.1.  This website (www.rumo.com.au) (Site), the financial products and/or services sold on, or via, this Site are created, operated and controlled by Rumo Finance Pty Ltd (ACN 676 162 735) (we, us or our).

1.2.  We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) and our credit reporting obligations under the Privacy Act, Privacy Regulations 2013 (Cth) and Privacy (Credit Reporting) Code 2014 (collectively, Credit Reporting Regime).

1.3.  By accessing, using and continuing to use our Site, financial products or services you agree to this Privacy Policy.

1.4.  This Privacy Policy outlines how we collect, store, use and disclose your Personal Information, including how we manage your credit-related information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

2.1.  Personal Information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.

2.2.  We will only collect and hold Personal Information and non-Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver our Site, financial products and services to you, or as otherwise permitted by law.

2.3.  The type of Personal Information that we collect and use depends on the type of dealings that you have with us and includes the following:

(a)  personal and contact details (for example, full name, residential address, date of birth, mobile and telephone numbers and email address);

(b)  business details (for example, business name, business address, ABN, mobile and office telephone numbers and work email address);

(c)   employment details (for example, employment history and salary information);

(d)  credit-related information (for example, credit history, any repayment obligations, credit ratings or hardship applications)

(e)  identification information (for example, driver’s licence, passport, tax file number, Medicare card and proof of age card);

(f)    credit card, debit card or bank account details;

(g)  financial information (your information or that of your business) such as income, expenses, financial assets and liabilities;

(h)  citizenship and residential status;

(i)    information relating to your dealings, or enquiries you have made, with us, including information about the financial products or services you have ordered or enquired about;

(j)    information regarding your access and use of our website, including location information, your computer’s internet protocol (IP) address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on your website, dates and times of visits to our website and other usage statistics;

(k)   other information that you provide to us or that we may collect in the course of our relationship with you; and

(l)    information provided by or on behalf of applicants for employment.

2.4.  We do not collect your Sensitive Information (as defined by the Privacy Act), such as your race, religion, political affiliations, sexual preferences, criminal record or medical history.

3.1.  We will collect Personal Information about you in a number of different ways. We may collect Personal Information directly from you or in the course of our dealings with you. For example, when you:

(a)  contact and correspond with us (for example, when you visit our Site (including via cookies), complete and submit forms or applications to us (in writing or through our Site), when you subscribe to our publications, alerts and newsletters, contact us online, via email or telephone with a query or request or make a comment on our social media sites;

(b)  enquire about, use or order our financial products or services;

(c)   provide information or submit documents (such as your driver’s licence and passport) to us via email or on our Site;

(d)  provide your Personal Information to third parties that you obtain services from and that you have consented to sharing information with us (including to our related bodies corporate, business partners and service providers, credit reporting bodies, credit providers, financial institutions, financial service licensors, government agencies, public registries, search agencies, regulatory and licensing bodies, parties to whom you refer us (for example, previous employers, referees or joint applicants), someone acting on your behalf (for example, financial advisors, trustees or financial accountants), recruitment agencies and from publicly available sources of information (for example, online databases and social media));

(e)  apply for a position of employment with us; or

(f)    other information that you provide to us or that we may collect in the course of our relationship with you.

3.2.  When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection. As a collection notice is specific to a particular collection of Personal Information, it will provide more specific information about our information-handling practices than this Privacy Policy.

4.1.  We use and disclose your Personal Information and non-Personal Information for the primary purposes for which the information is collected, including (but not limited to):

(a)  enabling us to determine whether to provide financial products and services to you;

(b)  providing or delivering our financial products or services to you, including, without limitation to, personalising or tailoring our financial products and services to meet your  specific needs or the needs of your business;

(c)   assisting with, or responding to, your queries, requests for information about the financial products and services we offer and to resolve any complaints;

(d)  assessing your current and future loan applications, including by reviewing any previous loan applications you may have made, and the reasons for granting or rejecting those applications;

(e)  managing your financial products and services (such as your loan facility on an ongoing basis);

(f)    informing you of other financial products and services which may meet your needs or requirements of your business or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires, or other matters which we believe are of interest to you (such as recruitment or job opportunities). For example, we may share your Personal Information with Rumo Mortgages for the purpose of offering you mortgage products or other value-added services that may be of interest to you;

(g)  meeting our legal and regulatory obligations (e.g. to verify your identity);

(h)  carrying out our internal operations, such as record keeping, training and auditing.

(i)    recovering funds and/or secured property when you are in default of your obligations; 

(j)    sharing with our Third Party Providers;

(k)   detecting, investigating or preventing actual or potential fraud in connection with the financial products or services that we may provide to you;

(l)    administer, improve and manage our financial products and services, Site (including customising the advertising and content on our Site) and relationship with you;

(m) charge and bill you for the use of our financial products and services; and

(n)  for direct marketing purposes (see section 7 below).

4.2.  You also have the right to refuse to provide us with your Personal Information. However, this may mean that we are unable to offer you our financial products and services or allow you to participate in marketing activities that depend on the collection of that information.

5.1.  In order to provide or deliver our Site, financial products and/or services to you we may disclose your Personal Information and Non-Personal Information to:

(a)  our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers (such as Rumo Mortgages ACN 676 162 735) (Rumo Mortgages);

(b)  authorised external service providers who perform functions on our behalf, such as financial and credit card institutions in order to process any payments, internet and technology services providers, web developers, hosting companies, marketing, advertising and security service providers, identity verification providers and payment verification providers, third party payment processors, fulfilment companies, credit reporting agents, ratings or reference agencies (eg Equifax and Dun and Bradstreet), debt collection agents, debt purchasers, financial institutions, financial services licensors and finance aggregators (eg ACL Holders Connective Asset Finance Pty Ltd), debt funders and advisors, market research and recruitment service providers;

(c)   law enforcement agencies and national and international regulatory authorities, such as the Australian Taxation Office, the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission and the Australian Transaction Reports and Analysis Centre.

(d)  external business advisors, such as auditors, lawyers, insurers and financiers,

(collectively, Third Party Providers).

5.2.  We may also disclose your Personal Information to:

(a)  to any other party with your consent and direction; and

(b)  law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law.

5.3.  Prior to the disclosure of Personal Information to Third Party Providers, we will take such steps as are reasonable in the circumstances to ensure that the Third Party Providers treat your Personal Information securely and otherwise complies with the relevant Australian Privacy Principles in relation to the Personal Information.

6.1.  By applying for credit or loan with us or when you offer to act as a guarantor of a loan facility, we may obtain your Personal Information and credit information from credit reporting bodies and/or such credit reporting bodies may provide your Personal Information and credit information to us. These credit reporting bodies include but are not limited to Equifax and Dun and Bradstreet. To view the policies for each credit reporting body, use the details below:

(a)  Equifax (www.equifax.com); and

(b)  Dun and Bradstreet (www.dnb.com/en-us).

6.2.  Information that we disclose or receive from credit reporting bodies may include:

(a)  our identification details (such as full name, date of birth, gender, your current (or last known) address and previous two addresses and your driver’s licence number);

(b)  the name of your current (or last known) employer

(c)   the names of any credit providers that have provided you with credit, and whether they are licenced by ASIC;

(d)  the type of credit provided by those credit providers;

(e)  the day on which that credit was made available to you and (if relevant) terminated

(f)    the limit on that credit;

(g)  certain terms and conditions of that credit, including limited information about your repayment and interest obligations;

(h)  repayment history information, which is information about whether you have made a credit payment on time, or whether you have missed a payment

(i)    financial hardship information, which is reported against your repayment history information;

(j)    that a credit provider has requested access to information held in your consumer credit report in connection with an application that you have made to that credit provider for consumer or commercial credit (an information request, more commonly known as a credit enquiry);

(k)   the type and amount of consumer or commercial credit that you sought in that application; and

(l)    that you have defaulted on a consumer credit payment of $150 or more (this means that you are at least 60 days overdue in making the payment).

6.3.  The purposes for which we may collect, hold, use and disclose your Personal Information and credit information in accordance with the Privacy Act and Credit Reporting Regime is to provide our financial products and services to you, to assess credit applications, determining your credit eligibility or worthiness, assist in the collection of overdue payments or debt assignments, to administer or enforce any guarantee, internal management purposes, such as risk management, to prevent defaults or financial hardship, to assist other credit providers, credit reporting bodies or third-party providers, or as otherwise permitted by law.

6.4.  We may ask credit reporting bodies to use their information to vet you for direct marketing. You can ask a credit reporting body not to do this. In addition, if you have or suspect you have been a victim of fraud, you can ask the credit reporting body not to use or disclose any information it holds about you.

7.1.  We may use and disclose your Personal Information, including contact details, to send you information about the financial products or services we offer, as well as other information that may be of interest to you. This may include third party products and services (including products and services offered by Rumo Mortgages). We may send this information in a variety of ways, such as by mail, email, SMS, telephone, social media or by customising online content and displaying advertising on our website.

7.2.  We may also use or provide your details to other organisations and third-party vendors for specific marketing purposes, such as to personalise or provide target marketing to you. Third party vendors, including Google, may use cookies and/or device identifiers to show our marketing based on your past visits to our Site or third party websites. You may opt-out of third-party vendors (such as Google) use of cookies or use of device identifiers by visiting their website.

7.3.  If you do not wish to receive any of these marketing communications, you can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us using the contact details set out in section 13 below. 

8.1.  In the course of providing you with our financial products or services, it may become necessary or desirable to disclose Personal Information to Third Party Providers located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we do not disclose Personal Information to overseas Third Party Providers.

8.2.  The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. In the event we transfer your Personal Information overseas we will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.

8.3.  If you have any questions in relation to the transfer of your Personal Information, please contact us using the contact details set out in section 13 below. 

In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with the notifiable data breach scheme contained in Part IIIC of the Privacy Act.

10.1. We will take steps that are reasonable in the circumstances to ensure that the Personal Information that we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold Personal Information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.

10.2. We protect your information using physical, technological and administrative security measures to minimise and manage the risks of unauthorised access, disclosure, use and alteration of your Personal Information.

10.3. The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services and any transmission is at your own risk. This extends to any third party website linked to our Site.

10.4. We will destroy or de-identify Personal Information in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.

11.1. We take steps reasonable in the circumstances to ensure Personal Information (including credit information) it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have the right to access and seek correction of your Personal Information including credit information) that is collected and held by us.

11.2. If at any time you would like to access or correct the Personal Information (including credit information) we hold about you, or you would like more information about our approach to privacy, please contact us via the contact details set out in section 13 below. We will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct Personal Information (including credit information) where necessary and appropriate.

11.3. We will deal with any request to access or correct your Personal Information (including credit information) within a reasonable time. To obtain access to your Personal Information (including credit information):

(a)  you will have to provide proof of identity to ensure that Personal Information (including credit information) is provided only to the correct individuals and that the privacy of others is protected; and

(b)  we may charge you a reasonable administration fee, which reflects our costs in providing you with access to your Personal Information (including credit information) in accordance with your request.

11.4. If we do not agree with the corrections you have requested, we are not obliged to alter your Personal Information (including credit information) accordingly. However, where we refuse to correct any Personal Information (including credit information) as requested by you, we will give you a written notice which sets out the reasons for our refusal.

12.1. We use small text files placed on your computer called ‘cookies’ to collect standard log and visitor behaviour information in an anonymous form. We use this information to analyse how visitors use our Site and to compile statistical reports on website activity. You can set your computer to reject cookies, but this may affect your ability to use certain parts of our Site.

12.2. We may also log your IP address. Your IP address is your computer’s electronic Internet address. We may collect your IP address to see trends, run the Site, track user movements, and gather broad demographic information.

12.3. Services that our Site may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our Site. By using our Site, you consent to Google processing your data in the manner described in Google’s Privacy Policy (www.policies.google.com/privacy) and for the purposes set out in this Privacy Policy.

12.4. Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out (see https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh/related?hl=en-GB ).

13.1. If you have any complaints or issues you wish to raise with us regarding the way we have handled your Personal Information or credit information, or you would like to discuss any issues about our Privacy Policy, please contact us directly by email at contact@rumo.com.au or by calling us on (07) 3227 0310. Please provide us with full details of your complaint and any supporting documentation.

13.2. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in resolving your complaint. At all times, we will treat your privacy complaint seriously and in a confidential manner.

13.3.  If you are unhappy with a response that you have received from us, you may direct your complaint to the Office of the Australian Information Commissioner.

14.1. Our Site may contain links to third party websites. Please be aware that the terms of this Privacy Policy do not apply to external websites. If you wish to find out how any third parties handle your Personal Information (including credit information), you will need to obtain a copy of their privacy policy.

From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our website. We encourage you to check our website from time to time to ensure you are familiar with our latest Privacy Policy.