Privacy Policy

1.

PURPOSE

The purpose of this policy is to ensure that:

(a)

all employees and representatives are informed of the policies and procedures of the Company in relation to privacy;

(b)

credit data is shared only for the prevention of over-commitment, bad debt and fraud as well as supporting debt recovery and debtor tracing;

(c)

consumer rights are protected; and

(d)

responsible lending is promoted.

2.

RESPONSIBILITY FOR POLICY

The person identified on the first page of this policy is responsible for the privacy policy and systems and its day to day management.

3.

TERMS USED IN THIS POLICY

In this policy:

Credit Reporting Code of Conduct means the Privacy (Credit Reporting) Code 2014 (CR Code) and the Privacy Regulation 2013 reflected in Part IIIA of the Privacy Act 1988 (Cth); and

Australian Privacy Principles (APPs) means the 13 Australian privacy principles from Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988 (Cth), a copy of which is provided in annexure A to this policy.

4.

CODE OF CONDUCT

4.1

Overview

The Company is bound by the Credit Reporting Code of Conduct and must adhere to the Australian Privacy Principles in its day to day operations.

4.2

Privacy authority

The Company must, before supplying any credit products or services, obtain an authority from each customer about the way in which the Company is permitted to use the customer’s information and these ways must be consistent with the Australian Privacy Principles and the Credit Reporting Code of Conduct.

4.3

Responsible lending

In considering whether or not to provide a credit product or service to a customer or prospective customer, the Company will take into account sufficient relevant information to establish, in the Company’s view whether the customer has the ability to repay the debt without hardship.

5.

MARKETING

The Company must take reasonable steps to identify individuals who may not be appropriate targets of credit marketing and the Company must refrain from targeting direct marketing offers of credit to consumers who may:

(a)

be on low fixed incomes; or

(b)

have poor past credit performance; and

(c)

have difficulty repaying the credit without hardship.

6.

DATA MANAGEMENT

All employees and representatives of the Company must ensure that the Company adheres to its’ Information Technology Policy to ensure that data is managed to protect the rights of consumers.

7.

CODE COMPLIANCE

The Company will ensure its employees and representatives have an understanding of credit reporting and compliance with the Credit Reporting Code of Conduct and Australian Privacy Principles the by ensuring that this policy is explained to them.

8.

CUSTOMER COMPLAINTS

Customer complaints in relation to privacy issues will be dealt with in accordance with the Company’s internal dispute resolution policy.

9.

COMPLIANCE

The Company will ensure that compliance with this policy is monitored on a regular basis in accordance with the company’s policy for monitoring compliance.