Our Privacy Policy as at September 2018

 

Protecting your privacy

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Bear Loans Pty Ltd (Bear Loans) is committed to providing you with the highest levels of customer service. This includes protecting your privacy. Set out below is information that we are required to communicate to our customers. We have also supplied additional information about our company.

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We may, from time to time, review and update this policy, including taking account of new or amended laws, new technology and/or changes to our operations. All personal information held by us will be governed by the most recently updated policy. Your privacy matters to us, so whether you are new to Bear Loans or are a long-time user, please take the time to get to know our practices.

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About us

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Bear Loans is the trading name of Bear Loans Pty Ltd ACN 621 583 999.

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Bear Loans is a credit representative and related body corporate of Australian Finance Group Ltd ACN 066 385 822 (AFG). AFG is the holder of Australian Credit Licence 389087.

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In this document, ‘Bear Loans’, ‘we’, ‘us’ and ‘our’ are references to Bear Loans, AFG and any related bodies corporate (collectively the AFG group of companies).

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Our brokers are authorised to engage in credit activities by Australian Finance Group Ltd. The licensee shares responsibility in the conduct of your broker.

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We provide a range of direct and broker services in the credit and financial services industry. This includes products and services such as home loans, commercial loans, debtor finance and car finance.

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Your personal information

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When we refer to personal information, we mean information or an opinion from which your identity is apparent or can reasonably be ascertained. The personal information we hold about you may also include credit information. Credit information is a sub-set of personal information and is information, which is used to assess your eligibility to be provided with finance. It may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies (CRBs).

Your personal information and its protection are of utmost importance to us. Personal information held by us may include your name, age or date of birth, current and previous addresses, telephone or mobile phone number, email address, bank details, professional job title or occupation, driver’s licence number and financial details. We may hold details of your products and services you have acquired from us or have enquired about (including their status) together with any additional information necessary to deliver those products and services and to respond to your enquiries.

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If you choose not to provide certain personal information (i) we may not be able to provide you with the services you require or the level of service on which we aim to offer, (ii) we may be unable to tailor our offering to your preferences and (iii) your experience of our offering may not be as enjoyable or as useful.

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You may need to provide personal information about other individuals to us (e.g. about your authorised representatives). If so, we rely on you to inform those individuals that you are providing their personal information to us and to advise them that we can be contacted for further information (see ‘How to contact us’ at the end of this statement).

 

About credit information and 'notifiable matters'

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The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit information. You may request to have these notifiable matters (and our privacy policy) provided to you in an alternative form, such as a hard copy.

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We exchange your credit information with CRBs. We use the credit information that we exchange with the CRBs to assess your creditworthiness, assess your application for finance and manage your finance. If you fail to meet your payment obligations in relation to any finance that we have provided or arranged, or you have committed a serious credit infringement, we may disclose this information to a CRB.

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You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information if needed. We explain how you can do this below.

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Sometimes, your credit information will be used by CRBs for ‘pre-screening’ credit offers on the request of other credit providers. You can contact the CRB at any time to request that your credit information is not used in this way.

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You may contact the CRB to advise them that you believe that you may have been a victim of fraud. For 21 days after the CRB receives your notification, the CRB must not use or disclose that credit information. You can contact any of the following CRBs for more information: Dun & Bradstreet (Australia) Pty Ltd (www.dnb.com.au), Experian (www.experian.com.au) and Equifax Pty Limited (www.equifax.com.au).

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How we collect personal information

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We collect personal information in a number of ways, including: directly from you, for example, when you provide information by phone, in application forms or other agreements, or when you submit your personal details via our websites (e.g. during an application or via bearloans.com.au); from third parties such as our survey or competition websites, marketing websites, related companies, government entities, CRBs or your representatives. If we obtained your information through any of these methods and you would like a list of these entities or websites, please contact us via privacy@bearloans.com.au.

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How we use your personal information

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The primary purpose for which we collect information about you is to enable us to perform our business activities and functions and to provide the best possible quality of customer experience. Your personal information may be used to: verify your identity; assist you to gain approval or provision of a product or service; provide the services you require; administer and manage those services such as payments; inform you of ways the services provided to you could be improved or additional services that you may benefit from; Marketing Services (explained below); conduct appropriate checks for credit-worthiness and for fraud; research and develop our services provided, either directly or referred; gain an understanding of your information and credit or financial needs in order for us to provide you with a better service.

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Also, your personal information is collected so that we, and our related entities can promote and market services to you (including by way of direct mail, telemarketing, email, SMS and MMS messages) (Marketing Services) in accordance with any applicable marketing laws. This is to keep you informed of products, services and special offers and we may continue after you cease holding an active product or service through us. If you do not wish for this to take place or continue, please contact us via privacy@bearloans.com.au.

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When we disclose your personal information

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We will never sell your information to any party outside of the AFG group of companies. In order to deliver the services you require, we may disclose your personal information to organisations outside of the AFG group of companies. Your personal information is disclosed to these organisations only in relation to us providing our services to you, these partners may include:

 

Disclosure to external organisations

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We may use external organisations for customer enquiries; mailing operations; billing and debt-recovery functions; information technology services; marketing and telemarketing market research; and website usage analysis. This means we disclose your personal information (such as name and address) to them. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

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In addition, we may disclose your personal information to sponsors, or promoters of any competition that we conduct or promote via our services; the police, any relevant authority or enforcement body, or your internet service provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary.

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Transfer of information overseas

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In order to supply you with the best service possible and pursuant to the Australian Privacy Principles, we may transfer personal information we have collected about you to someone in a foreign country only if such transfer is permitted by the Australian Privacy Principles.

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We do not utilise offshore personnel for the purposes of marketing or sales. We will not share any of your credit information with a credit reporting body, unless it has a business operation in Australia.

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Sensitive information

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Sensitive information is any information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information. We may seek, collect, use or disclose sensitive information about you but only if that sensitive information relates directly to our ability to arrange or provide credit to you or manage the credit provided to you (including, for example, assessing hardship applications and collecting overdue payments).

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Unsolicited information

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Sometimes people share information (including sensitive information) with us we have not sought out. This could be through using our website or, for example, requesting us to assess or assist in a hardship application. If we receive unsolicited personal information (including sensitive information) about you, we will determine whether we would have been permitted to collect that information. If yes, then we will handle this information the same way we do with other information that we seek from you. If no, and the information is not contained in a Commonwealth record, then we will destroy or de-identify it as soon as practicable, but only if it is lawful and reasonable to do so. Often, it is not possible for us to neatly unbundle this information then destroy or de-identify only certain sections or parts of it, and we may need to store this information for future use, such as to help resolve disputes between us or assess future applications by you. We have many security safeguards in place to protect the information from interference, misuse, loss, unauthorised access, modification or disclosure.

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Sharing with CRBs

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Bear Loans will disclose information about you to a CRB when you are applying for credit, you have obtained credit from us, or if you guarantee or are considering guaranteeing the obligations of another person to us. When we give your information to a CRB, it may be included in reports that the CRB gives other organisations (such as other lenders) to help them assess your credit worthiness. Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get credit from other lenders.

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Direct Marketing

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We take pride in the products and services that we offer. And we love keeping you informed as to the best offers in the credit and financial market place. However, first and foremost we respect your privacy and understand that not everyone wants to be contacted regarding sales and marketing. If you do not wish to be contacted by Bear Loans, we invite you to contact us via privacy@bearloans.com.au. We may conduct marketing activities via email, telephone, SMS, IM, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites). We will always let you know that you can opt out from receiving our third-party marketing. Where we market to prospective customers, we will always provide an easy way to opt-outs. With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We will never sell your personal information to any external organisation. We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.

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Opt-Out

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You can let us know at any time if you no longer wish to receive direct marketing offers from Bear Loans. We will process your request as soon as practicable.

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Cookies and web beacons

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Cookies

A ‘cookie’ is a small text file placed on your computer by a webpage server that may later be retrieved by webpage servers. We use cookies on our website to provide you with a better website experience. When you visit the Bear Loans website or related landing pages to read, browse, submit or download information, our system will record/log your IP address, date and time of your visit to our site, the pages viewed and any information downloaded. We may automatically collect non-personal information about you such as the site from which you linked to our websites. We do not personally identify you by this information. You can configure your browser to refuse cookies or delete existing cookies from your hard drive. Rejecting cookies may have the effect of limiting access to or functionality of parts of our website.

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We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services.

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Web beacons

A web beacon is typically a transparent graphic image invisible to the user that is placed on a website. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel. We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and “advertising/marketing personalisation”. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing third party networks and websites (Third-Party Websites) such as Google and Facebook.

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Information from third parties

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Our website may contain links to Third Party Websites (e.g. third-party providers of goods and services). We make no representations or warranties in relation to the privacy practices of any Third-Party Website and we are not responsible for the privacy policies or the content of any third-party website. Third Party Websites are responsible for informing you about their own privacy practices. If you accessed Third Party Websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties. Where you access a Third-Party Website from our website, cookie and web beacon information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.

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Advertising and tracking

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We may advertise on Third Party Websites. When you view our advertisements on Third Party Websites, the advertising company may use cookies, and in some cases, web beacons, to collect information such as the server your computer is logged onto, your browser type, the date and time of your visit and the performance of their marketing efforts. When you access our website after viewing one of our advertisements on a Third-Party Website, the advertising company may collect information on how you utilise our website (e.g. which pages you view) and whether you commenced or completed an online application.

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Online applications

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When you send a completed online application to us, we retain the information contained in that application. We are able to then use that information to provide any services that you require. You may also be able to suspend and save online applications, so you can complete and send the applications at a later time. If you suspend or save your application, the information that you have entered will be retained in our systems so that you may recover the information when you resume your application. Online applications that have been suspended or saved may be viewed by us.

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E-consent

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By providing your email address and then clicking submit on any online application, calculator, tool or query, you consent to receiving notices and other documents from us by email to the email address provided, and you understand that that if you give this consent: we may no longer send you paper copies of notices and other documents; you should regularly check your email address for documents; and you may withdraw your consent to receiving documents by email at any time. You also confirm that you have the facilities to print any notice or document that we send you by email, if desired.

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Accurate information

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We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you or others provided to us.

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If you wish to make any changes to your personal information, please contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete. You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable period. We will give access in the manner you have requested if it is reasonable to do so. We may charge you a fee to access the information. The fee will not be excessive and will not apply to the making of the request. We may deny you access to your personal information in certain circumstances, for example, if required or authorised by or under an Australian law or a court/tribunal order, or it would be likely to prejudice enforcement related activities by an enforcement body, if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If we decide not to give you access, we will provide reasons for the refusal and information on how you can complain about the refusal.

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Storage and security

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We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are: confidentiality requirements of our employees; document storage security policies; security measures for access to our systems; only giving access to personal information to a person who is verified to be able to receive that information; control of access to our buildings; and electronic security systems, such as firewalls and data encryption on our websites. We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from anywhere via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed here or those we referred to from time. In addition to the above, we also regularly review developments in security and encryption technologies. However, it is important to remember that the use of email and the internet may not always be secure, even with these safeguards in place. When we no longer require your information, and we are legally permitted to, we take reasonable steps to destroy or de-identify the information. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in our privacy policy.

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Doing business without identifying you

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In most circumstances, it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will provide you with the option to remain anonymous or to use a pseudonym, for example, when you make general inquiries about our business or current promotional offers. We do not adopt a government related identifier (such as your tax file number or your driver’s licence number) as a means of identifying you.

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How to contact us

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You may contact us during EST business hours by telephone or email: privacy@bearloans.com.au.

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Complaints and further information

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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 let us know about your complaint or feedback by contacting us at:

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Managing Director 
Bear Loans
Email: privacy@bearloans.com.au
Tel: 0402 042 061

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We have a formal procedure for investigating and dealing with privacy breaches. Once the Privacy Officer receives a complaint, whether it is in writing or verbal means, the Privacy Officer will commence an investigation with the relevant business unit from which the alleged breach stemmed. The investigator will endeavour to determine the nature of the breach and how it occurred. We may contact you during the process to seek any further clarification if necessary. If a breach is found, the Privacy Officer will escalate the matter to management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time. By giving us as much information as possible, you will help us resolve things faster. And if you have any supporting documentation, please have it handy when you raise your concern. Most complaints are resolved quickly and you should hear from us within five business days.

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If you are dissatisfied with our response, you may make a complaint to AFG’s Complaints Officer who can be contacted on either compliance@afgonline.com.au or 08 9420 7888. You may request further information about the way we manage your personal information by contacting us.

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Although we try hard to resolve a customer’s concern in the most considerate and direct manner, if you are not completely satisfied after the above steps have been attempted, you still have other avenues available to resolve the dispute. This is then managed externally and independently.

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This external dispute resolution (EDR) process is available to you, at no cost. The Credit Representative and their authorising Licensee are both required to be members (independently) of an ASIC approved EDR scheme, which is Australian Financial Complaints Authority Limited (AFCA). Please contact AFCA on 1800 931 678 for complaint escalation.

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Change in our privacy policy

We are constantly reviewing all of our policy and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices. As a consequence, we may change this privacy policy from time to time or as the need arises.