This policy describes how your personal information is handled by Unloan.
Unloan is a division of the Commonwealth Bank of Australia (CBA) which along with other CBA divisions and subsidiaries (the CommBank Group) provide or distribute banking, finance, insurance, funds management, financial planning and advice, superannuation, stockbroking and other services. The Group includes Bankwest and Commbank, among others.
For more information about the Group, including a complete list of Group members, see the CBA’s latest Annual Report, available at commbank.com.au/shareholders.
We take privacy seriously and are committed to ensuring the protection of your personal information, no matter where you are located.
Your privacy is important to us
We protect your personal information, and aim to be clear and open about what we do with it. You can find more information in places like our application forms and terms and conditions.
This Policy explains how we handle your personal information. It also includes:
- Our policy on the handling of credit reports and other credit information
- Key information about credit reporting matters.
During your relationship with us, we may tell you more about how we handle your information. For example, when you complete an application, or receive terms and conditions.
What information do we collect?
We collect information about you when you use our products or services, or deal with us. We may also collect information about you from other people and organisations.
Information we collect from you
We collect personal information about you when you contact us, use our products or services, visit our websites or use our mobile apps or deal with us in some other way.
Information we collect from others
We collect information about you from others, such as:
- Service providers
- Companies or bodies that you own shares in or have an interest in
- Family members.
For example, if you apply for credit, we may ask a credit reporting body for your credit report. We may also collect information about you that is publicly available (for example, in public registers or on social media) or provided by businesses we deal with.
We may collect the following types of personal information:
How do we use your information?
We’re careful about how we use your information. We use it to deliver our products and services. We also use your information for other reasons, such as to better understand you and your needs, and to let you know about other products and services you might be interested in.
Here is a list of the ways we may use your personal information.
Bringing you new products and services
From time to time, we may also use your information to tell you about products or services we think you might be interested in. To do this, we may contact you by:
- Social media
- Advertising through our apps, websites, or third-party websites
If you don’t want to receive direct marketing messages from us or want to change your contact preferences, you may adjust your communication preferences in the Unloan App. You can also unsubscribe from any commercial electronic messages to your electronic address by following the instructions set out in our email/text message.
Using data to give you better customer service
We’re always working to improve our products and services and give you the best customer experience.
New technologies let CommBank Group members combine information we have about you and our other customers, for example transaction information, with data from other sources, such as third party websites or the Australian Bureau of Statistics. Our CommBank Group members analyse this data to learn more about you and other customers, and how to improve our products and services.
The Group members use this combined data to help other businesses better understand their customers. When we do, we don’t pass on any personal information about you.
You can choose if and how your computer accepts them by configuring your preferences and options in your browser. If you want to make full use of our website, you may need to set up your browser to accept cookies.
Who do we share your information with?
We may share your information with third parties for the reasons noted in ‘How do we use your information’ or where the law otherwise allows or requires us to. These third parties can include:
Sending information overseas
Sometimes, we may send your information overseas, including to:
- Overseas businesses that are part of the Group
- Service providers or other third parties who store data or operate outside Australia (Unloan uses a number of US based providers)
- Complete a transaction
- Comply with laws, and assist government or law enforcement agencies.
If we do this, we make sure there are appropriate privacy, data handling and security arrangements in place to protect your information.
Credit checks and credit reporting
If you ask us for credit, we may check your credit reports. We get these from credit reporting bodies. We also share your credit information with them so they can provide credit reports to others.
When you apply to us for credit, we may need to check your credit reports.
A credit report gives us information about your credit history. Credit reports are provided by credit reporting bodies, who collect and share credit information with credit providers like us, and other service businesses like phone companies.
The Privacy Act limits the information we can give to credit reporting bodies, and that they can give us. The Act also limits how we can use credit reports.
The information we can share with credit reporting bodies include:
- Your identity
- Type and amount of credit you have – like credit cards, home loans, or personal loans
- How much you’ve borrowed
- If you’ve made all your repayments
- If you’ve committed fraud or another serious credit infringement.
Credit reporting bodies include this information in their credit reports to assist other credit providers assess your credit worthiness.
We can also ask credit reporting bodies to give us your overall credit score, and may use credit information from credit reporting bodies together with other information to arrive at our own scoring of your ability to manage credit.
The credit reporting bodies we use are Equifax Pty Ltd and Experian Australia Credit Services Pty Ltd. You can download a copy of their privacy policies at www.equifax.com.au and www.experian.com.au respectively.
What do we do with credit information?
We use information from credit reporting bodies to:
- Confirm your identity
- Assess your credit applications
- Assess your ability to manage credit
- Manage our relationship with you
- Collect overdue payments.
We keep credit information with your other information. You can view this information or ask us to correct it if it’s wrong (see ‘Accessing, updating and correcting your information’ below) or make a complaint to us (see ‘Making a privacy complaint’ below).
Other rights you have
Direct Marketing – Credit providers like us can ask credit reporting bodies to use your credit information to pre-screen you for direct marketing purposes, but you can tell credit reporting bodies not to (See ‘We’re here to help’ below).
Preventing identity fraud – If you have been or could be a victim of fraud – for example, if someone else may be using your name to apply for credit – you can ask the credit reporting body not to use or give anyone your credit information.
Keeping your information safe
Our staff are trained in how to keep your information safe and secure. We use secure systems and buildings to hold your information. We aim to only keep your information for as long as we need it.
We store your hard copy and electronic records in secure buildings and systems or using trusted third parties. We use a range of physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal information we hold about you.
We aim to keep personal information only for as long as we need it – for example for business or legal reasons. When we no longer need information, we take reasonable steps to destroy or de-identify it.
Accessing, updating and correcting your information
You can contact us and ask to view your information. If your information isn’t correct or needs updating, let us know straight away.
Can you see what information we have?
You can ask us for a copy of your information, like your transaction history, by emailing us (see ‘We’re here to help’ below).
To get a copy of current credit information we have about you, you can email us (See ‘We’re here to help’ below).
Is there a fee?
How long will it take?
We try to make your information available within 30 days after you ask us for it. Before we give you the information, we’ll need to confirm your identity.
Can we refuse to give you access?
In some cases, we can refuse access or only give you access to certain information. For example, we might not let you see information that is commercially sensitive. If we do this, we’ll write to you explaining our decision.
Updating your information
It’s important that we have your correct details, such as your current home and email addresses and phone number. You can check or update your information in the Unloan App, or by emailing us (see ‘We’re here to help’ below).
Can you correct or update your information?
You can ask us to correct or update any information we have (including credit information). See ‘We’re here to help’ below for ways to contact us. If we’ve given the information to another party, you can ask us to let them know it’s incorrect. We won’t charge a fee for this.
If the incorrect information was given to us by a credit reporting body, we may need to check with them or the relevant credit provider before we can change it. We’ll try to do this within 30 days. If we can’t, we’ll let you know why it’s taking longer and agree on a new timeframe with you. We’ll also tell you when we’ve corrected the information.
What if we believe the information is correct?
If we don’t think the information needs correcting, we’ll write to let you know why. You can ask us to include a statement with the information that says you believe it’s inaccurate, incomplete, misleading or out of date.
Making a privacy complaint
How can you make a complaint?
If there’s something we can improve, or you're not satisfied with our products, services, people, or complaint handling process, it's important we hear about it so we can make things right.
We will take your complaint seriously, work with you to address your complaint, and try to find a solution that's fair and reasonable.
If you are concerned about your privacy (including credit information), you can make a complaint by emailing us at [email protected] or via phone on 1300 630 000.
What happens when you make a complaint
We’ll acknowledge your complaint
- Most complaints can be resolved soon after we receive them or within days.
- We’ll let you know we’ve received your complaint (generally by the next business day), give you a reference number, and let you know the name and contact details of the person who’s handling it.
We’ll assess the information and work with you to find a fair outcome
- We’ll assess the information you give us, investigate the issues further at our end if we need to, and work with you to find a fair solution.
- If we're unable to provide you with a final response within 30 days, we'll tell you the reason for the delay, give you a date you can expect to hear an outcome, and continue to update you on our progress.
If you're unhappy with the resolution
- You can lodge a dispute with the Australian Financial Complaints Authority, an external dispute resolution body. AFCA provides a fair and independent complaint resolution service which is free for customers to access.
- You can also contact The Office of the Australian Information Commissioner if your complaint is about your privacy.
Credit information complaints
If your complaint is about your credit information, we may need to check with credit reporting bodies or the credit provider involved. If we can’t resolve your complaint within 30 days, we’ll get in touch to provide reasons for the delay and work out a new timeframe with you.
We're here to help
If you want to update your personal information, or if you have a privacy concern, need more information, or want to update your preferences, simply email us at [email protected]. You can also use the Unloan App to update your information and preferences.
“we”, “us” or “our” means Unloan, a division of Commonwealth Bank of Australia, ACN 123 123 124.
“Unloan App” includes Unloan iOS or Unloan Android Apps downloaded from an official App store and accessed locally on your device, as well as the Unloan web App. The Unloan App may not yet be available for access or download.