Privacy policy

Kubio Group Pty Ltd (Kubio Group) respects the privacy of the people we deal with and we uphold high standards of privacy practice and security. This policy explains how we handle personal information and how we interact with you online.

Whenever we handle personal information, we take steps to ensure that appropriate standards of privacy practice and security are applied.This Privacy Policy sets out why we need to collect personal information, how we collect it, what we do with it, how it’s stored and who we might share it with.  The Policy also describes how you can access or correct information we hold about you, how you can ask further questions or make a complaint, and information about our websites and online activities.

The information we collect

Sometimes it is necessary for us to collect ‘personal information’ such as names, identity details, photos, contact details, transaction information and other personal details where required (such as gender, marital status and financial information).

Credit Information

Your broker may instruct us to collect and retain your credit information on their behalf.  We may do this through a credit reporting body (only where you have provided consent for your broker to do so). References to ‘personal information’ throughout this policy includes your credit information. Please refer to the Credit Information annexure for further details relating to our handling of personal and credit information obtained from credit reporting bodies.

Health Information

We may collect health information provided to us by you or your broker in assessing certain claims, such as hardship.  We do not use or share that information for any purpose other than for storage and customer maintenance on behalf of your broker.

Sensitive Information

Generally, we do not collect sensitive information about you unless required by law or where you consent for us or your broker to do so. Sensitive information includes information relating to:

  • race
  • political or religious beliefs
  • sexual preferences
  • criminal convictions
  • membership of professional or trade associations or unions
  • biometric and health information

We may collect information about your affiliation with certain organisations, such as professional associations.

Personal information about others – your assurance to us

Where you provide us with personal information about someone else, you must first obtain their consent to provide it based on this Privacy Policy. By providing this information to us, you are assuring us that you have such consent.

Why we collect personal information

We collect personal information about you which is reasonably necessary to:

  • assist in the provision of products or services sought by you
  • consider applications and approaches you make to us
  • conduct marketing and social functions
  • maintain your contact details
  • fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter-terrorism financing or as otherwise authorised by you.

Without such information, we may not be able to process your application or provide you with an appropriate level of service.

How we collect your information

We collect personal information about you directly from you – this can be in person, in documents you give us, from telephone calls, emails, competitions you enter, your access to our website or from transactions you make.

We also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).

How we store your information

We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.

We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints – this includes interactions you make with your broker.

How we use your information

We use personal information about you for the purpose for which it was provided to us, including to:

  • assess, process or refer applications by you for consumer or commercial credit (or to be a guarantor)
  • administer and manage any products and services acquired by you (including monitoring, auditing, and evaluating those products and services)
  • model and test data (in a controlled environment)
  • develop scores, risk assessments and related analytical tools for ourselves or your broker (including benchmarking statistics)
  • assessing certain claims including hardship
  • communicate with you and deal with or investigate any complaints or enquiries.

We may also:

  • de-identify your data for our own purposes including market research, new product development, fraud mitigation or statistical analysis
  • use your personal information for related purposes which would reasonably be expected without your permission.  For example, we may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, if you don’t want to receive such communications you can tell us by using any of the methods listed below.

While we may sometimes share personal information with companies we do business with (e.g. for product development, joint venture or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.

When your information is disclosed

While we typically only share personal information within Kubio Group and with your nominated broker or adviser, we may disclose personal information outside Kubio Group:

  • as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator
  • to our service providers, who provide services in connection with our products and services (including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information     broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, website and technology services)

We may also disclose your personal information (on a confidential basis) in connection with proposed acquisitions, mergers, divestments, and the management of any parts of our business or assets.

In some circumstances the parties to whom we disclose personal information may operate outside of Australia – this includes locations in the countries listed in the Appendix. Where this occurs, we take steps to protect personal information against misuse or loss.

Keeping information accurate and up to date

We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

Keeping information secure

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Kubio Group seeks to prevent misuse or unlawful disclosure of the information – this includes appropriate information technology infrastructure to segregate and control data as well as internal policies, auditing, training and monitoring of staff. If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.

Where the personal information we collect is no longer required, we delete the information or permanently de-identify it in accordance with relevant laws and our records management policy.

How you can access or correct your information

You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

Dealing with Kubio Group online

When you visit Kubio Group’s websites you will browse anonymously unless you have logged into a client portal or accessed the website from a personalised communication from Kubio Group.

For all visitors to our web site, we use cookies to collect anonymous information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), and your IP address. (An IP address is a number that is assigned to your computer automatically and required for using the Internet). We may also derive the location associated with an IP address.

Once you have logged into a Kubio Group portal, accessed our website from an e-mail or other personalised communication sent to you, or provided us with personal information by completing a form online, we may be able to identify you and we may combine that with other information in order to provide you with a better online experience. If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).

Cookies

A 'cookie' is a packet of information placed on a user's computer by a website for record keeping purposes. While cookies are not considered personal information, they are generally used on Kubio Group sites to:

  • access online services - if you log into our secure areas on our website we will use cookies to authorise your access and save your preferences
  • manage advertising - when you see one of our ads on a third party website, cookies are sometimes used to collect anonymous information about the page you visit and the type of software you are using
  • monitor traffic - we use anonymous information to track how people are using the Kubio Group site. This may include time of visit, pages visited and some system information about the type of computer you are using
  • monitor your use of our website - if we have identified you as a result of you logging into a Kubio Group portal, accessing our website from a personalised communication or providing us with personal information by completing a form online, we may use cookies to collect personal information about you.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check ‘Help’ menu of your browser to learn how to change your cookie preferences).

If you disable the use of cookies on your web browser or remove or reject specific cookies from Kubio Group websites or linked sites, then you may not be able to gain access to all of the content and facilities on those websites.

Contact us

If you have any questions or complaints regarding privacy or information handling, please write to admin@kubio.com.au or contact us by phone on 0400 255 349. Please mark communications to the attention of our Privacy Officer. We will respond to let you know who will be handling your matter and when you can expect a further response.

If your concerns are not resolved to your satisfaction, you may be able to escalate your complaint to an external dispute resolution scheme or to a regulatory authority. We can provide details of the appropriate scheme/regulator for you, as these may vary by jurisdiction or product.

You may also contact the Office of the Australian Information Commissioner as follows:

Phone: 1300 363 992 Address: GPO Box 5218, Sydney NSW 2001

Email: enquiries@oaic.gov.au

Website: www.oaic.gov.au

Policy updated  July  2016

Appendix – Disclosure to other countries

Personal information may be disclosed to third parties in jurisdictions including: Australia; India; Japan; Malaysia; New Zealand; Philippines; Singapore; United Kingdom; United States of America.

Annexure – Credit Information

Our role in the credit reporting process is limited to requesting a credit report on behalf of your broker. Your lender will have further details about what information they report and avenues for dispute resolution that may be available. While we don’t report your credit information to credit reporting bodies, you should be aware of the following.

The credit information we collect and hold

The types of credit-related personal information (“credit information”) we collect may include:

  • permitted identification information such as names, date of birth, sex, 3 most recent addresses, employer and driver's licence number
  • the fact that any consumer or commercial credit has been applied for and the amount and type of credit
  • details of your current and previous credit providers
  • credit limits and certain terms and conditions relating to credit arrangements
  • start/end dates of particular credit arrangements
  • records of previous requests made by credit providers to credit reporting bodies for information about you in connection with consumer or commercial credit applications, guarantees and securitisation arrangements
  • repayment history
  • ‘default information’ (in addition to and without limiting repayment history information), i.e. payments overdue for more than 60 days in specified circumstances
  • in relation to those overdue payments, advice about new payment arrangements or that those payments are no longer overdue
  • information about adverse court judgments, personal insolvency records and publicly-available information related to your credit worthiness
  • in specified circumstances that, in the opinion of a credit provider, there has been a serious credit infringement (e.g. fraud)
  • information derived by credit reporting bodies from any of the above information (e.g. credit scores, ratings and assessments)
  • information we derive from the above information (e.g. our own credit scores, ratings and assessments).

This includes information about your arrangements with other credit providers.

We collect this information from you, your broker, your account activity and from third parties including public sources, our related companies, referrers, agents, your adviser(s) and our service providers including credit reporting bodies and information service providers.

Credit reporting bodies

Credit reporting bodies may use credit information to maintain information about individuals and provide that information to credit providers for their credit assessments. Your credit provider may also report to a credit reporting body where you fail to meet your payment obligations in relation to consumer credit or you commit a serious credit infringement.

We may exchange credit information with the following credit reporting bodies:

You can contact those credit reporting bodies or visit their websites to see their policies on the management of credit information, including details of how to access the credit information they hold about you. You also have the right to request credit reporting bodies not to:

  • use your credit information to determine your eligibility to receive direct marketing from credit providers; and
  • use or disclose your credit information if you have been or are likely to be a victim of fraud.