Wave Money is committed to protecting the privacy and security of your information. In accordance with the Privacy Act 1988 (Cth)(the Privacy Act) and the Australian Privacy Principles (APP’s), we have put in place procedures and systems to comply with our obligations with respect to your information. This Policy explains our obligations, and your rights, with respect to how we handle your information.
1. What personal information does Wave Money collect and hold?
The types of information that we collect and hold about you could include:
- ID information such as your name, postal or email address, telephone numbers, and date of birth
- Financial details such as your tax file number and bank account, superannuation or insurance policy information
- Credit information such as details relating to credit history, credit capacity, and eligibility for credit
- Other information we think necessary
- Over the course of our relationship with you, we may collect and hold additional personal information about you, including transactional information, complaint or enquiries about your product or service
Information from a credit reporting body
When we’re checking your credit worthiness and at other times, we might collect information about you from and give it to credit reporting bodies. This information can include:
ID information: a record of your name(s) (including an alias or previous name), date of birth, gender, current or last known address and previous two addresses, name of current or last known employer and drivers licence number.
Information request: a record of a lender asking a credit reporting body for information in relation to a credit application, including the type and amount of credit applied for.
Default information: a record of your consumer credit payments being overdue.
Serious credit infringement: a record of when a lender reasonably believes that there has been a fraud relating to your consumer credit or that you have avoided paying your consumer credit payments and the credit provider can’t find you.
Personal insolvency information: a record relating to your bankruptcy or your entry into a debt agreement or personal insolvency agreement.
Court proceedings information: an Australian court judgment relating to your credit.
Publicly available information: a record relating to your activities in Australia and your credit worthiness.
Consumer credit liability information: certain details relating to your consumer credit, such as the name of the credit provider, whether the credit provider has an Australian Credit Licence, the type of consumer credit, the day on which the consumer credit was entered into and terminated, the maximum amount of credit available and certain repayment terms and conditions.
Repayment history information: a record of whether or not you’ve made monthly consumer credit payments and when they were paid.
Payment information: If a lender gave a credit reporting body default information about you and the overdue amount is paid, a statement that the payment has been made.
New arrangement information: If a lender gave a credit reporting body default information about you and your consumer credit contract is varied or replaced, a statement about this.
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth Anti-Money Laundering law.
2. Why do we collect your personal information?
When we refer to personal information we mean information or an opinion about you, from which you are, or may reasonably be, identified.
This information may include (but is not limited to) your name, date of birth, driver’s licence number, marital status, phone number, email address, address, nationality, employment history, income, assets, liabilities and repayment history information.
Personal information also includes credit information. Credit information is personal information or an opinion about you that has a bearing on credit that has been provided to you or that you have applied for.
We collect and receive personal information about you (including credit information) in order to conduct our business, including assessing and obtaining approval for loans and other products.
3. How we collect your personal information
There are many ways we seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call or used our website. In addition, when you use our website or mobile applications we may collect information about your IP address, location or activity. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details, including doing e-verification of identity.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We may collect information about you that is publicly available, for example from public registers, social media or made available by third parties. We do this where:
- We can’t get hold of you and need to update your contact details
- We need information from third parties about an application you make through us
- We are checking the security you are offering
- We can learn insight about your financial needs, such as through property information
- You have consented to third parties sharing it with us
- At your request, we exchange information with your legal or financial advisers or other representatives
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
- Provide you with the product or service you want
- Manage or administer your product or service
- Personalise your experience with us
- Verify your identity or protect against fraud
- Let you know about other products or services that might better meet your financial, e-commerce and lifestyle needs
4. Disclosure of information
To enable us to maintain a successful business relationship with you, we may disclose your personal information to organisations that provide products or services used by us, including, other credit providers, mortgage intermediaries (such as mortgage broker), funders, lenders, valuers, trustee companies, financial institutions and securitisers, title insurers, surveyors, credit reporting agencies, rating agencies and debt collectors, your employer/s or referees, your professional advisors, your bank and any other organisation that may have or is considering having an interest in your loan, or in our business, companies and contractors who we retain to provide services for us, such as IT contractors, call centres, payroll providers, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your personal information to provide those services, people considering acquiring an interest in our business or assets, other individuals or companies authorised by you, associated businesses that may want to market products to you, to anyone where you have provided consent and where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth),
By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case by case basis.
Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office.
We may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the Asia-Pacific, European Union or the United States of America. We may also use cloud storage and IT servers that are located offshore.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
Credit reporting bodies and notifiable matters
We may provide your credit information to a credit reporting body. The credit reporting body may provide the information that we report about you to other credit providers to assist them to assess your credit worthiness. We may also obtain information that other credit providers have provided to the credit reporting body to use in our assessments of your credit-worthiness.
If you fail to meet your payment obligations in relation to any loan that we have provided to you, or any loan that we have arranged for you, or if you commit a serious credit infringement, we may report this to the credit reporting body.
You may access the credit information that we hold about you. Please refer to the section titled ‘Accessing your Personal Information’ below. You may also request that we correct any credit information that we hold about you if you believe the information is out-of-date, incomplete, or incorrect. Please refer to the section titled ‘Updating your Personal Information’ below.
You may contact the credit reporting body to request that they not use or disclose the credit-reporting information they hold about you if you consider that you may have been a victim of fraud or if you believe on reasonable grounds that the information they hold about you is out-of-date, incomplete or incorrect. The credit reporting body must not use or disclose your credit information for a period of 21 days after receiving your notice.
For further information, contact the following credit reporting bodies at:
5. Security of personal information
It is important to us that your information is kept secure. We take reasonable steps to make sure your information is protected from being lost, misused, shared or accessed in an unauthorised way. This includes your credit related personal information by storing it in a secure environment, and when the information is not longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
6. Integrity of your information
We take reasonable steps to make sure that your information is accurate, complete, up-to-date and, with respect to your credit information, that it is also relevant and not misleading. You have the right to ask us for access to the information we have about you, or for correction to that information. We will make sure to respond to you within a reasonable time by giving you access to the requested information, a notice confirming that we have corrected it, or our lawful reason(s) for refusing to do so.
Correcting your personal information
Contact us if you think there is something wrong with the information we hold about you.
Our contact details are at the end of this policy. If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
Correcting your credit information
Whether we made the mistake or someone else made it, we will help you correct the information within 30 days. If we can’t make a correction in that timeframe, we will ask you for extra time. We also might need to talk to others in order to process your request. The most efficient way for you to make a correction request is to ask the organisation which made the mistake.
Whether we’re able to correct the information or not, we’ll let you know. If we can’t we will provide reasons. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing. If you have any concerns, you can access the Credit and Investments Ombudsman service or make a complaint to the Office of the Australian Information Commissioner.
Updating your personal information
It is important that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we ask you to inform us if any of your personal information has changed.
If you consider that any information we hold about you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
7. Complaints and queries
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can contact us by using the details below:
The Privacy Officer
L6, 1 Castlereagh St, Sydney NSW 2000
Email address: email@example.com
If you subsequently feel that the issue has not been resolved to your satisfaction, you may contact:
The Australian Financial Complaints Authority (AFCA), the external dispute resolution scheme is a free service established to provide you with an independent mechanism to resolve financial services complaints:
Phone: 1800 931 678
Mail: GPO Box 3 Melbourne VIC 3001; or
The Office of the Australian Information Commissioner:
Phone: 1300 363 992
Fax: +61 2 9284 9666
Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
8. Variations and availability of this policy
This policy may change from time to time and is available on our website. More information about Australia’s privacy protection regime is available on the Australian Information Commissions website at https://www.oaic.gov.au/privacy-law/