Privacy & Credit Reporting Policy

This Policy governs the collection, use, disclosure, and storage of your personal information, and information relating to your business (where relevant) including your credit-related information. We may, from time to time, amend and update the Policy by publishing changes to it on our website and the platforms and software applications we own and operate (Website).

OurMoneyMarket Holdings Pty Ltd ABN 30 614 872 105 (OMM Holdings), OurMoneyMarket Operations Pty Ltd ABN 43 640 771 535 (OMM Operations), OurMoneyMarket Pty Ltd ACN 616 335 409 (OMM PL), OurMoneyMarket Lending Pty Ltd ABN 64 605 231 669 Australian Credit License Number 488228 (OMM Lending), and OurMoneyMarket Services Pty Ltd ABN 66 614 874 761 Authorised Credit Representative Number 494238 of OMM Lending (OMM Services) – collectively ‘OMM’– uses, and handles your personal information (including your credit-related information) in accordance with the Privacy Act 1988 (Cth) (Privacy Act), and the Privacy (Credit Reporting) Code 2025 (CR Code).

Use of the terms “you” or “your” in this Policy means you as an individual or, where you interact with us as a representative of a business, that business. Use of the terms “we”, “our” and “us” means, as relevant, OMM

We may, from time to time, amend and update this Policy by publishing changes to it on our Website. We encourage you to check our Website periodically to ensure that you are aware of our current Policy.

What are personal information and credit-related information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. Personal information may include sensitive information, which includes, for example, information about an individual’s health, religion and any criminal convictions they may have.

The personal information we collect may include (but is not limited to):

details such as your name, date of birth, driver’s licence and/or passport number, tax file number, marital status, phone number, email address, residential address, nationality, employment history, income, assets, liabilities, repayment history information and financial hardship arrangement information including whether you have made a financial hardship arrangement with us;
details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
any additional information relating to or about you that you provide to us directly through our website or other online channels (such as our mobile app) (Website) or indirectly through your use of our Website;
any information relating to or about you that you provide to third parties who disclose this information to us; and
any other personal information that may be required in order to facilitate your dealings with us.

Credit-related information is a form of personal information that includes information about your credit history or creditworthiness. It includes:

information about you or your business’ loan experience with us and other lenders;
consumer credit information;
commercial credit reports and information;
the kinds of credit products you have had or sought;
how you have managed your obligations, including such things as your repayment history, arrears you have cleared;
information contained in a credit report about you which is obtained by us from a credit reporting body (CRB); and
information about your creditworthiness that has been derived by us from such a credit report about you.

Why do we collect information and who do we collect such information from?

We may collect, hold, use and disclose personal information and credit-related information about you for a range of purposes, including:

identifying you in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and verifying that your information is correct;
learning about and verify your financial situation in accordance with the National Consumer Credit Protection Act 2009 (Cth);
providing you an indicative quote for credit or considering and assessing an application for credit;
managing any credit facility we may provide you and executing your instructions.
informing you about a product or service that we think may be of interest to you;
assisting you to apply for and providing our products or services;
contacting and managing our relationship with you;
helping us design and improve our products and services;
inviting you to marketing events and webinars;
conducting and enhancing our overall business to add more value to you and our customers;
undertaking securitisation activities and other activities relating to funding and capital requirements;
compiling statistical data e.g. credit scoring information;
operating, protecting, improving and optimising our Website, services and business (e.g. perform analytics, conduct research and for advertising and marketing);
considering and handling any concerns or complaints you or any other person may have;
protecting our business and our customers from fraudulent or unlawful activity; and
complying with our legal obligations and resolve any disputes that we may have with any of our customers.

We collect your personal and credit-related information directly from you most of the time, however on occasion, we may also collect information about you from other people and organisations.

For example, we may collect personal information and credit-related information about you from:

other lenders and CRBs;
brokers and intermediaries;
third parties that refer you to us;
your employer; and
third party social media sources.

We also collect information from you or third parties about your interactions with us (for example, transaction history).

We may also use third parties to analyse traffic on our Website, which may involve the use of cookies.

If you do not provide some or all of the information which we request, we may not be able to provide credit (or any other product or service) to you.

Direct marketing

We may use your personal information (including information collected from others) to advertise or promote products or services we think may interest you, including by:

contacting you by telephone (notwithstanding registration at any time of your telephone number on the Do Not Call Register) or writing to you; and
sending commercial electronic messages to any electronic address which you provide or for which you are responsible (and in that regard, you warrant that you have authority, either as or on behalf of the electronic address account holder, to provide this consent and agree that until you withdraw your consent by using the unsubscribe facility in the message, or calling us on 1300 990 115, we may continue to send commercial electronic messages to those addresses).

We may also provide your information to other organisations for specific marketing purposes.

If you have previously opted out of receiving direct marketing communications, submitting a new request for a quote or loan application and accepting the Privacy Statement and Electronic Communication Consent constitutes a fresh consent to receive the marketing communications described above. The consent supersedes any previous opt-out and remains effective until you withdraw it.

You may withdraw your consent at any time by using the unsubscribe facility in the message, replying STOP to an SMS, or calling us on 1300 990 115. Withdrawing your marketing consent will not prevent us from sending non-marketing communications that are reasonably necessary to respond to or assist with your quote or application, or to administer your loan or account.

Conversion tracking

We may use services provided by third parties to improve the accuracy of our conversion tracking and measure how effectively our marketing practices lead to completed transactions. These services work by securely matching personal information collected by us – such as your name, email address, mobile number or residential address – with data held by the service provider, to attribute conversions back to ad interactions.

Your personal information is ‘hashed’ before being shared with the service provider, meaning it is converted into an encrypted form that is designed to protect your privacy. While hashing protects your information, hashed data remains personal information and is handled in accordance with this Policy and the Privacy Act. We will not share your credit-related information with these service providers for these purposes.

You may ask us to stop sharing your personal information with these service providers for these purposes at any time by calling us on 1300 990 115. You may also be able to set preferences for how these service providers advertise to you through their respective advertising preference settings.

Exchange of your sensitive information

In some cases, sensitive information may be collected for specific purposes (for example, information regarding your health to enable the assessment of a hardship relief application). You understand that references in this Policy to personal information include sensitive information such as your medical and health related details, and we may exchange such information with other parties listed in this Policy for the purpose of assessing or processing credit applications and may seek further information from any medical attendant consulted by you.

Document Verification Service

To verify your identity, we may collect, use and disclose the information derived from your government issued documents (such as your Australian passport, state or territory driver licence, Medicare card, citizenship certificate or birth certificate) to the relevant government agency via the Document Verification Service (DVS), provided we have obtained your express consent to do so.

Our collection, use and disclosure of your information to the DVS to verify your identity is subject to compliance with our legal obligations under the Privacy Act and Australian Privacy Principles and our DVS Business User Participation Agreement. Our use of the DVS may involve the use of third-party systems and services. The DVS verifies supplied information by checking it against information held by the government agency that originally issued that document.

You may withdraw your consent at any time by contacting us at [email protected] or [email protected], or by calling us on 1300 990 115. Verification of your identity is necessary for us to perform our functions and activities and provide products and services to you. If you do not provide evidence of your identity, or your express consent for us to verify your identity using the DVS, we may be unable to verify your identity, and you may not be able to receive products and services from us as a result.

If you wish to make a complaint relating to the collection, use and disclosure of your information for the purposes of verifying your identity with the DVS, you may contact us by emailing us at [email protected] or [email protected], or calling us on 1300 990 115.

You can find more information about the DVS, including information about the operation and management of the DVS Hub by the Attorney-General’s Department, at www.dvs.gov.au.

How do we use your information?

In addition to the use described in the section of this Policy titled “Why do we collect information and who do we collect such information from”, we may use and exchange your information so that we can seek access to credit information held by a CRB on your behalf, provide you with credit (and associated services) and to manage our relationship with you, including to:

identify you and verify your identity;
verify that your information is correct;
assess, complete and process your application for credit;
establish, provide and administer your credit facility;
comply with legislative or regulatory requirements;
corresponding with you and contractors in relation to your credit facility;
undertake internal processes, including product development, risk management and pricing;
carry out your instructions, or assist with your inquiries;
collect overdue payments;
do anything we are required or authorised by law to do; and
identify and (unless you tell us not to) tell you about our products and services, and those of third parties, that might interest you.

Generally, we will not use or exchange your information for any purpose other than one that is set out in this Policy, or for a purpose that is disclosed to you or for the purposes to which you have consented.

Who do we exchange your information with?

We may disclose and exchange your personal and credit-related information for any of the reasons mentioned above with third parties. Third parties may include:

other persons (for example, your referee or employers) to verify that information you provide is correct;
any person with whom you make a joint application for credit;
any person who referred you, or your application for credit, to us;
our external service providers and contractors (such as any mail house, a custodian, commercial agent or entities that help us to verify your identity or identify illegal activities and prevent fraud);
our employees, related entities, assignees, agents and external advisers;
law enforcement, regulatory, government and dispute resolution bodies;
any person we consider necessary to execute your instructions;
any financial institution to or from which a payment is made in relation to any account you have or operate;
other organisations who provide products or services to you jointly with us, or who we believe can offer products or services that will be of use to you;
other credit providers and financial institutions;
CRBs;
debt collection agencies;
anyone who obtains an interest in a credit facility we provide to you or is considering doing so, and their advisers;
organisations involved in a transfer or sale of our assets or business;
our funders and any organisation providing credit support or repayment support relating to your credit facility;
our advertising and technology partners;
our insurers; and
third parties authorised by you to receive information held by us.

Do we disclose personal information overseas?

In some circumstances, we may disclose your personal and credit-related information to recipients located outside Australia for the purposes of processing certain international transactions. Our service providers may be located in the United States and/or India.

The countries we disclose your information to will depend on the details of the transaction you ask us to carry out.

If we disclose your information to entities that are located overseas, we will take reasonable steps ensure that the overseas entity does not breach the Australian Privacy Principles in relation to your information. While we attempt to select and secure reputable offshore service providers, we are not liable for any breach or misuse of information sent offshore. An overseas entity may not be subject to privacy laws or principles similar to those that apply in Australia. Any information disclosed to an overseas entity may not have the same protection as under Australian privacy laws. You may not be able to seek redress for any breach of your privacy which occurs outside of Australia.

Which CRBs do we exchange credit-related information with and what information is exchanged?

For the purposes of obtaining a quote for credit, or if you are applying for credit with us, we may give a CRB your personal information and credit-related information which may include but is not limited to:

your full name, including any known aliases, your sex and your date of birth;
your most recent three addresses;
the name of your current or last known employer;
your driver’s licence number;
details of any payment default amount of over $150;
the fact that you have applied for credit and the amount;
the fact that we are a current credit provider to you;
the amount of credit provided to you;
the type of credit you are applying for or have obtained and the account number;
the date the credit account is opened or closed;
details of payments that are more than 60 days overdue where debt collection action has commenced;
advice that payments are no longer overdue;
the fact that the credit we provide has been paid or discharged;
that in certain circumstances, you have committed fraud or other serious credit infringement;
court proceedings information such as judgements which relate to credit;
personal insolvency information such as information relating to bankruptcy;
repayment history information, which includes details as to whether or not you have met your repayment requirements under a credit contract; and
financial hardship information.

We may seek information about you from a CRB in connection with an application for credit made by you (known as a ‘credit enquiry’). Your consent to the credit enquiry is not required. A record of the credit enquiry may be used and, as relevant, disclosed for the purposes of the CRB or a credit provider assessing your credit worthiness, including calculation of a credit score or credit rating (subject to any other use or disclosure limitations under the Privacy Act and associated regulations, and the CR Code). Credit enquiries on your credit report may impact your credit score or credit rating (for example, if multiple credit enquiries have been recorded over a short period, that may lower your credit score). The impact on your credit score or credit rating will depend on the type and amount of credit you apply for, the frequency of credit enquiries and your credit history.

You acknowledge that OMM Services as a credit representative entity, may (if you authorise OMM Services to) obtain this information on your behalf, for the purposes of helping you obtain a quote for credit from a credit provider (including OMM Lending). OMM Lending may then collect this information from the credit representative entity in our capacity as a credit provider.

We may use the information obtained from your credit report to confirm your identity, assess an application for credit (including arriving at our own assessment of your creditworthiness), manage our relationship with you and collect overdue payments.

The CRBs we may use are:

Equifax (Equifax Australia Information Services and Solutions Limited), whose privacy policy (which explains how it manages credit information) and contact details are at www.equifax.com.au; and
Experian Australia Credit Services Pty Ltd, whose privacy policy and contact details are set out at www.experian.com.au.

You can ask a CRB not to use or disclose credit information it holds about you for a period of 21 days (called a “ban period”) without your consent if you believe on reasonable grounds that you have been or are likely to be a victim of fraud, including identity fraud.

CRBs may use credit information they hold to respond to requests from us or other credit providers to “pre screen” you for direct marketing. You can ask a CRB not to do this. However, if you are a borrower you may still receive direct marketing from us (unless you ask us not to by using the unsubscribe facility in the message, replying STOP to an SMS, or calling us on 1300 990 115) that has not been “pre-screened”.

As a credit applicant, you agree to us accessing your personal information (including consumer credit and commercial credit information, if applicable) held with a CRB, even if there is a ban period in place, for the purposes of assessing an application for credit or in order to collect overdue payments.

How do we store information collected?

We keep a hard copy and electronic records on our premises and systems or offsite using trusted third parties. We ensure the personal and credit-related information we hold on you is secure at all times, including ensuring that it is protected from misuse, interference and loss, unauthorised access, disclosure and modification.

Your information is only accessible by you and those authorised to access it. Employees and third parties who deal with your information are bound by confidentiality obligations and are required to complete training about information security and privacy.

When we no longer need your information, including when we are no longer legally obliged to keep records relating to you, we will destroy it or de-identify it.

Security

We take reasonable steps to protect your personal and credit-related information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, we cannot guarantee the security of your personal and credit-related information.

How can you access, amend and correct your information?

We take all reasonable steps to ensure that the information we may collect, use or disclose is accurate, complete and up-to-date. You have the right to access your information and correct it if it is inaccurate, out of-date or incomplete.

You may request access to the information we hold about you at any time by contacting us. We will respond to your request within a reasonable timeframe. There is no fee for making a request but we may charge you the reasonable costs of providing our response to a request for access to personal and credit-related information.

If we refuse to give you access to any of your personal and credit-related information, we will provide you with reasons for the refusal and the relevant provisions of the Privacy Act on which we rely to refuse access.

You may also ask us to correct any information we hold about you by contacting us, alternatively you can make any changes to your personal details via your personal account. We encourage you to advise us as soon as there is a change to your contact details, such as your phone number or

address. We will deal with your request to correct your information in a reasonable time. If we correct your information and it is the information we have provided to others, we will notify them of the correction where we are required to do so by the Privacy Act.

If your request to correct your information relates to information that has been provided to us by a CRB or another credit provider we may need to consult with them about your request. We will correct information, where we decide to do so, within 30 days of your request, or longer if you agree.

If we do not agree with the corrections you have requested, we are not obliged to amend your information accordingly, however, we will give you a written notice which sets out the reasons for our refusal.

There are various ways you can contact us to alert us to changes to vital personal information (such as a residential address, home phone, etc). Our contact details are shown below. Your pro-active approach ensures the information we hold on you remains accurate and up-to-date. You can also request access to this information which we must grant except in limited circumstances.

Questions and complaints

If you have any questions, you may contact us by emailing us at [email protected] or calling us on 1300 990 115.

Additionally, if you believe that in handling your personal and credit-related information we have breached the Australian Privacy Principles, the Privacy Act or the CR Code and you would like to make a complaint, you may use these same contact details noted above to lodge a complaint.

Once we receive your complaint, we will respond to you as soon as possible and will let you know if we need any further information from you. We will notify you of our decision within 30 days, however, if we are unable to do so, we will let you know the reason for the delay and the expected timeframe to resolve the complaint.

If you are not satisfied with our response to your complaint, or the way in which we have handled your complaint, you may contact the Australian Financial Complaints Authority, our external dispute resolution scheme, or the Office of the Australian Information Commissioner. The contact details of these entities are as follows:

Australian Financial Complaints Authority
GPO Box 3 MELBOURNE VIC 3001
1800 931 678
www.afca.org.au

Office of the Australian Information Commissioner
GPO Box 5218 SYDNEY NSW 2001
1300 363 992
www.oaic.gov.au