Privacy and Credit reporting policy

We, Plenti Group Limited ACN 643 435 492, Plenti RE Limited ABN 57 166 646 635, Plenti Pty Limited ABN 29 161 376 638, Plenti Finance Pty Limited ABN 82 636 759 861, Plenti Services Pty Limited ABN 55 672 878 018, and Perpetual Corporate Trust Limited ABN 99 000 341 533 (as custodian of the Plenti Lending Platform (ARSN 169 500 499) and Plenti Wholesale Lending Platform (together our ‘lending platforms’) (Custodian), collect, use and handle your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), and the Australian Privacy Principles.

This Privacy Policy sets out our policy for the collection, use, disclosure and storage of your personal information and information relating to you, your business (where relevant), including credit-related information.

Use of the terms ‘you’ or ‘your’ in this policy means both you as an individual, and where you interact with us as a representative of a business, your business.

1. What information we collect about you

(a) Information you provide us directly

We ask for information about you directly from you when you apply (i) for credit with us (including, where relevant, credit provided by National Australia Bank Limited (NAB)), or (ii) to become a member of our lending platforms. This includes but is not limited to, your name; address; contact details; passport or driver's licenses; financial and related information such as bank statements, bank account details and utility bills. This may also include your biometric information including a photo of your face. We request this information to verify your identity, to assess your application, and should your application be approved, to manage any credit facility provided to you and/or your membership to our lending platforms.

We may also collect information about you if you are a person who proposes to guarantee or has guaranteed repayment of any application for credit made with us.

We may also collect information about you when you contact us directly by telephone, via our website, email or a social media platform managed by us.

(b) Information we receive from third parties

If you engage a third party to assist you with your application for credit with us (for example, a loan broker), we may obtain information about you set out in (a) above from that third party.

We may also obtain information about you from third parties to verify your identity before processing any application for credit with us or to become a member of our lending platform.

When you apply for credit facilitated by us, we may obtain credit-related information about you from third parties for the purposes of assessing and processing your application for credit. Credit-related information is a type of personal information that includes information about your credit history or creditworthiness. This includes information, but is not limited to, about your loan experience with us and other lenders; the kinds of credit products you have had or sought; how you have managed your credit obligations such as your repayment history and arrears; and a credit report which we obtain from a credit reporting body which contains information about your creditworthiness. We also obtain credit information as we are required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the National Consumer Credit Protection Act 2009 (Cth) to ascertain and verify a prospective borrower’s financial situation.

If you apply for credit provided by NAB facilitated by us, we will obtain information (including personal information) about you from NAB, which may include:

the information described in (a);
information about a complaint you have made (including, where relevant, complaints to AFCA or another external dispute resolution provider);
information about your prior transactional or borrowing history with NAB; and
information about hardship applications you have made.

We may directly collect analytics data, or use third party analytics tools, to help us analyse traffic and user behaviours when engaging with us through our website (including our borrower portal) and lending platform. These tools collect information sent by your browser or mobile device, including the pages you visit (such as information about web request, internet protocol (IP) address, browser types etc) and other information. Some of these tools and applications may also collect information about where you are located. We use this information to operate, maintain and provide features and functionalities of our website and lending platform to you, to correspond with you, and to address any issues you raise about our website or lending platform.

When you visit our website, we will send cookies to your computer that uniquely identifies your browser and allows us to do things like remembering your preferences and to improve user experience. Cookies convey information to us about how you interact with our website or lending platform (such as pages you viewed, links you clicked and other actions taken on our website or lending platform), and also allow us to track your usage of the website or lending platform overtime. This allows us to enhance your user experience when interacting with us via those mediums.

You can control (including delete or disable) or reset your cookies and similar technologies through your web browser by customising your cookie preferences. Depending on your device, it may not be possible to delete or disable tracking mechanisms. Note that disabling cookies and/or other tools may mean that some features of our website and lending platform may not function properly.

(d) 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, or your biometric information such as a photograph of your face to verify your identity).

You understand that references in this Privacy Policy to personal information include sensitive information such as your medical and health-related details, and you agree that we may exchange such information with other parties listed in this Privacy Policy for the purpose of assessing or processing credit applications or hardship applications, and may seek further information from any medical attendant consulted by you.

We may not be able to process your credit or membership application without the information requested.

2. How we use your information

We collect the information we collect about you for purposes set out above and which is described in more detail below:

(a) Assessing application: We primarily use your personal information to assess your application for credit and/or membership to our lending platforms. This may include helping you obtain a quote for credit from a credit provider including the Custodian or NAB; corresponding with third parties in relation to your credit facility including obtaining a credit report; and to assess, process, provide and administer your application for credit and associated credit facility.

(b) Providing you with our products and services and to administer the products and services: If your application is accepted by us, we will primarily use your information to provide you with our products and services and to administer our products and services– that is the provision and management of any credit facility offered and accepted by you, or your membership to one or both of our lending platforms. This includes allowing you to log into the borrower or lending portals online, operating and maintaining your credit facility and/or membership to our lending platforms, to collect repayments including overdue payments from you, to carry out your instructions, for internal processes (including risk management and pricing and analysis of referral, introduction or other similar business arrangements) and/or to communicate with you with regards to your credit facility, membership to our lending platform or generally about our products and services. Your personal information may also be used for the provision of custodial services by the Custodian to Plenti RE Limited or Plenti Pty Limited.

(c) Managing your credit facility with NAB: If you apply for credit provided by NAB facilitated by us, we will primarily use your information for the provision and management of any credit facility applied for and entered by you. This includes to process your application, allow you to manage your credit facility online, to collect repayments including overdue payments from you, to service your credit facility (for example, handle any complaints or enquiries you may have), to carry out your instructions, for internal processes (including risk management) and/or to communicate with you with regards to your credit facility or generally about our products and services. We also use information to keep NAB informed about the status of your loan application or credit facility.

(d) Providing referral partners with information: Where you are referred to us by a broker or introducer for credit, or you have elected to be referred to another broker for credit, we will share your personal information with that broker or introducer or their affiliated entities, for the purpose of administering and servicing their products and services and/or our products and services, data analytics and generating insights.

(e) Providing you with services in connection with the Empowering Homes Program or the Home Battery Scheme: If your application for credit was in connection with the Empowering Home Program, the Home Battery Scheme or one of Plenti’s bundled energy programs, we collect your information for the purposes of facilitating the installation of a solar battery system, facilitating the payment of any such subsidy, and administering and monitoring the Program and/or Scheme. We may additionally collect information about you or your installed solar and/or battery system, including energy generation and consumption, from you, the supplier or manufacturer of the relevant product, or your installer. We will use this information to administer and monitor the performance of the Program or Scheme.

(f) For data analytics: We use information about you to improve our products and services and your experience with our website and platforms such as monitoring the total number of visitors, traffic and site usage patterns.

(g) To communicate with you: In addition to communicating with prospective and existing borrowers and lenders, we will also use personal information provided to communicate with you including in response to any request from you, to gain feedback about your experience with us, for marketing and promotional purposes. This includes contacting you by telephone or in writing, and by sending commercial electronic messages to any electronic address which you provide or for which you are responsible. In that regard, until you withdraw your consent by providing written notice to us or using an unsubscribe facility in the message as set out below, you consent and agree (either as or on behalf of the electronic account holder) that we may continue to send commercial electronic messages to those addresses.

(h) For matters that you have specifically consented to: From time to time we may seek your consent to use your information for a particular purpose. Where you consent to us doing so, we will use it for that purpose only. Where you no longer want us to use your information for that purpose, you may withdraw your consent for that use.

(i) Where required by law: We may use or disclose your information where we (a) are required to by law or in order to comply with the law including reasonable requests from law enforcement and/or (b) to exercise or protect the rights and property of us, our borrowers and/or lenders, or others.

3. Sharing your information

(a) Sharing your information with Third Parties

We may disclose your information for any of the reasons mentioned above with third parties.

These third parties 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 with whom proposes to guarantee, or has guaranteed repayment of any credit provided to you;
any person or business who referred you for credit, or your application for credit, to us, or has on your behalf submitted a request for a quote for credit or an application for a credit facility to us, or to any person or business to whom you have elected for us to refer for credit, or their affiliated entities;
our external service providers and contractors (such as any mail house, commercial agent, consultants, or entities that help us to verify your identity or identify illegal activities and prevent fraud);
our related entities, assignees, agents and external advisers;
law enforcement, regulatory, government and dispute resolution bodies including where compelled by law;
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 credit providers and financial institutions;
credit reporting bodies;
debt collection agencies;
the Custodian and related entities of the Custodian;
NAB or NAB’s service providers, where you have applied for credit provided by NAB;
the Government of New South Wales or their appointed advisors or auditors or auditors in respect of any Quote Record or application for credit in respect of the Empowering Homes Program;
the Government of South Australia or their appointed advisors or auditors or auditors in respect of any Quote Record or application for credit in respect of the Home Battery Subsidy Program;
energy retailers with whom Plenti partners with as part of Plenti’s bundled energy programs;
anyone who obtains an interest in a credit facility we provide to you or is considering doing so, and their advisers; and
organisations involved in a transfer or sale of our assets or business.

(b) Sharing your information with Credit Reporting Bodies (CRB)

We may obtain a credit report about you from a CRB and in order to do so, we may give a CRB your personal information including, but 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;
your businesses’ ABN or ACN 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;
details of payments which 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; and
repayment history information for a 2-year period.

A credit report will provide us with information about you that is held by the CRB and which has any bearing on your creditworthiness in both your capacity as a consumer and as a commercial entity. We may obtain this information on your behalf, for the purposes of helping you obtain a quote for credit from a credit provider including the Custodian or Plenti Finance Pty Limited, or you propose to act as a guarantor in relation to an application for credit.

We may use this information 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 use are:

(i) Equifax Pty Ltd, whose privacy policy and contact details are set out at https://www.equifax.com.au/

(ii) illion Australia Pty Limited and its related parties, Dun & Bradstreet (Australia) Pty Limited and DBCC Pty Limited, whose privacy policy and contact details are at https://www.illion.com.au.

Additionally, where you enter a loan with NAB, we may provide information to Experian Australia Credit Services Pty Ltd on behalf of NAB, whose privacy policy and contact details are set out at https://www.experian.com.au/consumer/credit-report-scores/experian-credit-report.

To assist in verifying your identity as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the National Consumer Credit Protection Act 2009 (Cth), we may use a CRB to provide an assessment of whether personal information you have provided matches (in whole or in part) personal information contained in a credit information file in the possession or control of the CRB.

In verifying your identity, the CRB may prepare and provide us with such an assessment and may use your personal information including the names, residential addresses and dates of birth contained in credit information files of you and other individuals for the purposes of preparing such an assessment.

CRBs may include information, which we provide in reports to other credit providers to assist them to assess your creditworthiness.

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. When you apply for credit, you agree to us accessing your personal information (including credit-related information) 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.

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) that has not been “pre-screened.”

4. How we transfer, store and protect your data

We keep hard copy and electronic records on our premises and systems, or offsite using trusted third parties. We may transfer information that we collect about you, including personal information, to:

our service providers located in the Philippines, the United States of America, India, and Vietnam;
where your request for credit is referred under a referral arrangement with a broker or introducer with affiliated entities located in the United States of America and United Kingdom, to those entities in those locations; and
NAB, where you have applied for credit provided by NAB. NAB’s privacy policy is available on its website at https://www.nab.com.au/common/privacy-policy.

By agreeing to this Privacy Policy, you acknowledge and agree that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in Australia.

We take reasonable steps, and use appropriate safeguards, to ensure that any personal information we hold and transfer about you is always secure, including ensuring that it is protected from misuse, interference and loss, unauthorised access and disclosure. You are responsible for maintaining the secrecy of your unique password and account information, and controlling access to your communications with Plenti, at all times. We cannot ensure or warrant the security of any information you transmit to us, or guarantee that information on may not be accessed, disclosed, altered or destroyed during transmission however we have security protocols in place to protect your communications with us. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

5. Your options about your information

(a) Account information

You may update your account information either through your account online or by contacting our customer support team at contact@plenti.com.au.

You may not opt out of certain account-related communications (such as invoicing and payment reminders, changes/updates to your account, technical and security notices etc).

(b) Direct Marketing

We may use your information to advertise or promote products, services, or business or investment opportunities we think may interest you, including by email or telephone. We may also provide your information to other organisations for specific marketing purposes. However, we will not do so where you tell us not to. You can ask us not to contact you about products and services and not to disclose your information to others for that purpose by calling us on 1300 768 710 or contacting us at contact@plenti.com.au.

You can opt-out of any promotional or marketing communications by clicking the ‘unsubscribe’ link at the bottom of those communications. We will endeavour to promptly process all unsubscribe requests.

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 rights 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 time. 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 information.

If we refuse to give you access to any of your personal 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. 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 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 which has been provided to us by a 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.

6. How to contact us

If you have any questions or concerns about this Privacy Policy, you may contact us by emailing us at contact@plenti.com.au or calling us on 1300 768 710.

Additionally, if you believe that in handling your personal information we have breached the Australian Privacy Principles, Part IIIA of the Privacy Act or the Credit Reporting Privacy 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

Either of these entities may forward your complaint to another external dispute resolution body if they consider that the complaint would be better handled by that other body.

(June 2024)