LIMBA PRIVACY POLICY

AUSTRALIAN PRIVACY PRINCIPLE 1—OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION.

Limba is committed to protecting your privacy and safeguarding your financial information. Our Privacy Policy describes how we keep this commitment and how we comply with the “National Privacy Principles”, and in particular, the recent amendments introduced by the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

This Privacy Policy covers, inter alia, the following information and considerations:

  • the kinds of personal information that Limba collects and holds;
  • how Limba collects and holds personal information;
  • the purposes for which Limba collects holds, uses and discloses personal information;
  • how an individual may access personal information about the individual or business that is held by Limba, and seek the correction of such information;
  • how an individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint; and
  • whether Limba is likely to disclose personal information to overseas recipients.

If a person or body requests a copy of this privacy policy in a particular form, Limba will take such steps as are reasonable in the circumstances to give the person or body a copy in the requested form.

Limba understands and appreciates that you are concerned about your privacy and about the confidentiality and security of information we may gain about you/your business online. Limba is committed to protecting your privacy. This Limba Privacy Policy explains how your personal information will be treated. This Privacy Policy applies to all your dealings with us.

However, when dealing with various entities or parts of the website further privacy information may apply in addition to the matters discussed in this Privacy Policy. Accordingly, in addition to the provisions of this Privacy Policy, there may also be specific and additional privacy provisions which apply to certain sections of the Limba website. Because those specific and additional provisions also relate to your privacy protection, you should review them wherever they are accessible by you on the Limba website. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

The website and privacy policy are owned and operated by City Finance Business Lending Pty Ltd ABN 56 602 843 327 domain name www.limbaloans.com.au (“Limba website”).

AUSTRALIAN PRIVACY PRINCIPLE 2 — ANONYMITY AND PSEUDONYMITY

You can deal with Limba anonymously where it is lawful and reasonably practicable to do so. For example, if you inquire about our loan interest rates or fees and charges on a particular product you do not need to provide your personal details.

AUSTRALIAN PRIVACY PRINCIPLE 3 — COLLECTION OF SOLICITED PERSONAL INFORMATION

Limba may collect personal information from you in the course of your website visit or attendance at a branch or by telephone, facsimile or email, due either to the necessity and/or directly related to the loan that you have obtained, are interested in or formally applying. The collection of information will be undertaken lawfully and fairly.

Generally, the information that Limba collects about you is dependent on how you use the facilities offered by Limba.

The primary purpose for which we collect personal information, is to either refer your enquiry or enable an assessment to be undertaken for the purposes of providing credit, and otherwise, to provide you with the best service experience possible.

The information collected may include your business details, ABN, name, postal or email address, date of birth, financial details, tax file number, health information or other information Limba considers necessary.

We will, if it is reasonable or practicable to do so, collect your personal information from you directly. This may happen when you fill out a product or service application or an administrative form (e.g. a change of address form) or when you give us personal information over the telephone or counter, or through a Limba website.

In some instances, we collect your personal information from third parties, again, only if it is reasonable or necessary. For example, we may need to collect personal information from a credit reporting agency, your representative (such as a legal adviser), your financial adviser, your employer or publicly available sources of information or any of the other organisations identified below under “Using and Disclosing Your Personal Information”.

If you visit an unsecure area of the Limba website (that is, an area where you are not required to log on) to read, browse or download information, our system will record the date and time of your visit to our site, the pages viewed and any information downloaded. However, our systems will not record any personally identifiable information within these areas, and after a reasonable period of time that information will be destroyed.

AUSTRALIAN PRIVACY PRINCIPLE 4 — DEALING WITH UNSOLICITED PERSONAL INFORMATION

Any unsolicited information of a private nature, however received by Limba, will be subjected to a determination whether that information is or has been obtained by consent and if not it will be destroyed or de-identified.

AUSTRALIAN PRIVACY PRINCIPLE 5—NOTIFICATION OF THE COLLECTION OF PERSONAL INFORMATION

If we collect or are provided with private information from a third party about another individual and/or if we reasonably believe that a third party is not aware that we have been provided with confidential or private information, we will notify that person or body as to the fact that we have been provided with that information, the Limba contact details and the circumstances and reasons (if known) of/for the collection of that material along with a copy of this privacy policy.

AUSTRALIAN PRIVACY PRINCIPLE 6—USE OR DISCLOSURE OF PERSONAL INFORMATION

Limba customarily disclose personal information with City Finance Holdings Group Pty Ltd for the purposes of conducting your loan application, loan monitoring, referral reasons and marketing activities. We will only disclose personal information to an unrelated third party with your consent or pursuant to our obligations under the Anti-Money Laundering and Counter-Terrorism Financing legislation, or as required or authorised by law. Where your personal information is disclosed, we will seek to ensure that the information is held, used or disclosed consistently with the National Privacy Principles, State legislation and other applicable privacy laws and codes.

Limba may use your personal information and other data provided to us to assess and process your application for our credit product(s) and assist you in obtaining a loan. Limba may also use your personal information and other data to enhance your experience on its websites, and subject to your consent to transmit marketing communications.

We may also use your personal information and other data for such purposes as processing payments, updating our account records, arranging for your repayments, conducting statistical analysis or feedback purposes.

By completing a Limba online application, telephone application, face to face application you will be consenting to Limba contacting Equifax Pty Ltd and/or Illion Pty Ltd (Australia) (credit reporting bodies) (contact details below) to confirm your credit status. If you obtain a loan from Limba, credit information and default listings including a serious credit infringement listing may be passed to the credit reporting body.

The credit reporting body has a credit reporting policy about how they handle your information.  You can obtain a copy of their policy at their website.

Equifax Pty Ltd

  • Online: www.equifax.com.au
  • Equifax credit reporting policy is set out at http://www.equifax.com.au/privacy
  • Phone: 13 8332
  • Mail: Equifax Public Access – Attention: Equifax Australia Information Services and Solutions Pty Ltd GPO Box 964 North Sydney NSW 2059

Dun and Bradstreet (Australia) Pty Ltd/ Illion Pty Ltd

We may also use or disclose the personal information for the following purposes:

  • To enable us to discharge our statutory obligations;
  • To enable us to discharge our contractual obligations when providing services to third parties;
  • To enable the resolution of a concern or complaint such as to a mediator or lawyer; and
  • To provide services.

Contracts we enter into with other parties for the provision of services may require us to disclose your Personal Information to them. In those cases, our contracts require other parties providing services to us to observe the terms of this Privacy Statement. These parties are as follows:

  • third party suppliers, loyalty and affinity program partners, printers, posting services, call centres, and our professional advisers.
  • your financial advisers and their service providers, subject to your direct consent.
  • management advisors and contractors engaged to update our systems.
  • upon the occurrence of a sale of all or part of the assets or business of Limba to a purchaser.
  • entitles engaged to deal in the payments system including financial institutions, merchants and payment organisations.
  • credit and fraud reporting agencies, debt collection agencies, mortgage insurance companies, your guarantors.
  • Information may be provided to a credit reporting body in relation to consumer credit if there is a failure to meet their payment obligations in relation to consumer credit or commits a serious credit infringement.
  • The credit reporting body that Limba provides information may use that information to assess the individuals credit worthiness.
  • Limba will not provide to a credit reporting body information about a payment that this overdue in relation to consumer credit, where the amount of the overdue payment is less than $150.00.
  • Limba will issue to you the following information/notices according to industry standards prior to reporting a default to a credit reporting body:
    • Several attempts to reach client via phone, email and mail by Senior Credit Analyst
    • Ongoing account monitoring and attempted contact with client using our internal Collections Team
    • Direct contact from National Manager noting seriousness of situation and potential next steps for account.

Limba does not use credit related information from a Credit Reporting Body for the purposes of direct marketing.

Cookies for Internet Website Services

We generally use “cookies” as a fundamental part of our interaction with your Internet browser from any Limba website. The purpose is to provide you with better and more customised service and with a more effective website.

A “cookie” is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your browser.

Limba uses cookies for two different purposes. We allocate a cookie to each Internet browser that visits the Limba website. This cookie does not allow us to collect personally identifiable information about you. We use this cookie:

  1. to allocate a Limba identification number to your Internet browser (but we cannot identify you from this number);
  2. to determine if you have previously visited the Limba website;
  3. to identify pages that you have accessed and Third-Party websites you have accessed; and
  4. for security purposes.

Most of the Limba website operates by using this type of cookie. Accordingly, if you wish to make full use of the Limba website, it is required that you accept cookies.

Limba also uses cookies for secure services (that is, an area where Limba uses encryption) on the Limba website. These cookies are used for a variety of purposes, including for security and personalisation reasons. If your browser is configured to reject all cookies you will be unable to use secure services on the Limba website that require cookies in order to participate.

AUSTRALIAN PRIVACY PRINCIPLE 7—DIRECT MARKETING

We may use or disclose your personal information to let you know about, and develop, products and services from Limba that might better serve your financial, needs or promotions or other opportunities in which you may be interested. For example, we may do this after an initial marketing contact. You can contact us at any time if you no longer wish us to do so (see the Contacting Us section for more information).

AUSTRALIAN PRIVACY PRINCIPLE 8 — CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

Because we operate throughout Australia, some of these uses and disclosures may occur outside your State or Territory, accordingly in some circumstances we may require further consents. We do not operate outside of Australia.

AUSTRALIAN PRIVACY PRINCIPLE 9 — ADOPTION, USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS

Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

AUSTRALIAN PRIVACY PRINCIPLE 10 — QUALITY OF PERSONAL INFORMATION

Limba will take steps as are reasonable in the circumstances to ensure that the personal information that the entity collects, uses or discloses is accurate, up-to-date and complete and relevant.

AUSTRALIAN PRIVACY PRINCIPLE 11 — SECURITY OF PERSONAL INFORMATION

Limba stores information in various ways, usually either in paper and electronic form. The security of your personal information is paramount and we endeavour to take all reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure.

We have processes in place to ensure the security of your personal information, including encryption of all data when it is transferred to our service providers and limitations on access to personal information within our organisation.

Limba takes reasonable steps to preserve the security of cookie and personal information in accordance with the Limba website Terms of Use and this Security and Privacy Statement. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).

Limba regularly reviews developments in security and encryption technologies. Unfortunately, no data transmission over the Internet can be guaranteed as totally secure.

Accordingly, although Limba strives to protect such information, Limba cannot ensure or warrant the security of any information you transmit to us or from our online products or services and you do so at your own risk. Once we receive your transmission, we take reasonable steps to preserve the security of the information in our own systems.

How we Handle Email

We will preserve the content of any e-mail that you send us, if we believe that we have a legal requirement to do so. Your e-mail message content may be monitored by our Limba employees for security issues including where e-mail abuse is suspected; our response to you may be monitored for quality assurance issues.

AUSTRALIAN PRIVACY PRINCIPLE 12 — ACCESS TO PERSONAL INFORMATION

Limba allows, and is obligated at law in certain instances, to grant access to your personal information upon request. However, this is subject to various exceptions allowed by law such as:

  • access would pose a serious threat to the life or health of any individual;
  • access would have an unreasonable impact on the privacy of others;
  • a frivolous or vexatious request;
  • the information relates to a commercially sensitive decision-making process;
  • access would be unlawful;
  • access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you;
  • legal dispute resolution proceedings;
  • where a third party has given us health information about you in confidence;
  • denying access is required or authorised by or under law.

If an access request is denied, reasons will be provided.

AUSTRALIAN PRIVACY PRINCIPLE 13 — CORRECTION OF PERSONAL INFORMATION

If at any time, you believe that your information is not correct or requires updating please notify us. It is also an obligation in some instances that you maintain the accuracy of your personal information, such as your address and contact details if you have entered into a contract with Limba.

Limba will take all reasonable steps to ensure that your privacy details are accurate.

MISCELLANEOUS

Copyright

Copyright in the information contained on this website is owned by Limba. You may use this information for your own personal reference only. You may reproduce this information in hard copy solely for your personal use. The information may not otherwise be reproduced and must not be distributed or transmitted to any other person or incorporated in any way into another document or other material.

How to contact us about privacy

Your privacy is very important to us. For that reason, please read the following details carefully and get in contact with us if you have any questions.

You can contact us on:

Contact: Privacy Manager

Local Phone: (07) 3458 9201

By Post: Suite 134, 7 Clunies Ross Court, Eight Mile Plains QLD 4113

Updates to this Privacy Policy

This Privacy Policy will be reviewed from time to time as required or obligated by law.

Dated: 22nd May 2018