Pula Capital Pty Ltd – Privacy and Credit Reporting Policy

Pula Capital Pty Ltd ACN 131 304 115 (referred to as Pula Capital, we, us or our) is a boutique finance company. Pula Capital has implemented this Privacy and Credit Reporting Policy to provide users of our website and our other services with information about how we collect, hold and use personal information (including credit information and credit eligibility information (credit-related personal information) you provide to us. If you wish to make any inquiries regarding this privacy policy, you should contact our Privacy Officer in any of the ways specified in clause 10.

We may, from time to time, review and update this Privacy and Credit Reporting Policy, including to take into account new laws, regulations and technology. All personal information held by us will be governed by our most recent Privacy and Credit Reporting Policy and will be posted on our website.

Pula Capital is constantly improving and enhancing its services to clients, and may update this Privacy and Credit Reporting Policy from time to time. Any changes to the policy will be advised to you by updating the relevant page on Pula Capital’s website.

  1. What personal information and credit-related personal information do we collect?
    • Personal information” is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained. Personal information we collect may include (but is not limited to) the following:
      • name, residential address (including last known address and two previous addresses), postal address and email address
      • driver’s licence number
      • age or date of birth
      • contact details including telephone numbers (landline and mobile)
      • gender
      • payment, bank account and credit account details
      • occupation, employment and salary details, and
      • your buying/spending habits.
    • The Privacy Act describes ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record, and health information about an individual. With your consent we may collect sensitive information. For example, we may collect information about your health where you make a claim for hardship due to medical reasons. If you provide us with sensitive information, we will as a matter of policy only use and disclose the information for the purpose for which it was provided or another directly related purpose, unless you agree otherwise, or where required by law.
    • We may collect credit-related personal information about you. Credit-related personal information includes credit information, credit reporting information and credit eligibility information.
    • Credit information is the basic category of personal information in the credit reporting system. It includes the following types of information that we collect about you and may give to a credit reporting body:
      • identification information
      • consumer credit liability information
      • type and amount of credit sought in a credit application
      • default information
      • payment information if you pay a default previously listed with a credit reporting body
      • new arrangement information if we vary a consumer credit contract that we’ve previously listed default information about
      • repayment history information
      • personal insolvency information
      • publically available information
      • details about court proceedings, and
      • serious credit infringements.
    • We may also collect and hold credit eligibility information about you. The types of credit eligibility information we may hold includes:
      • credit reporting information we receive from a credit reporting body (including repayment history information), and
      • information we derive from this credit reporting information such as a credit score or company credit matrix.

Credit reporting information means credit information (such as the types of information listed in paragraph 1.4) that a credit reporting body holds or personal information a credit reporting body derives from credit information it holds about an individual. We collect this type of information about you when we obtain a credit report from a credit reporting body.

  1. How and why we collect personal information and credit-related personal information
    • We collect your persona information to allow us to conduct our business functions and to market and sell our products and services.
    • We may collect your personal information when you:
      • visit our website (see paragraph)
      • purchase our products or engage our services
      • request information about us, our products or our services
      • provide feedback
      • fill in a form
      • applies for a job with us, or
      • contact us by telephone, fax, email, post or in person.
    • We may also collect personal information about you via third parties (ie other organisations). However we will only collect your personal information in this way if it is unreasonable or impractical to collect this information directly from you or if we are otherwise permitted to do so.
    • We may collect credit-related personal information about you:
      • when you fill out our credit application form
      • when we obtain a credit report from a credit reporting body, or
      • if you have an account with us.
    • If you choose not to provide your personal information or credit-related personal information to us for the purposes set out in this Privacy and Credit Reporting Policy, we may not be able to undertake certain activities for you such as providing you with requested information, products or services, or approve your application for credit.
  2. Information collected via our website
    • We will not collect any personal information about users of our website except when they knowingly provide it or as otherwise described below.
  3. How is your personal information and credit-related personal information used?
    • We use the personal information we collect about you for our business functions and activities, which may include to
      • communicate with you and provide you with information, products or services you have requested
      • assist customers by providing them with information and support
      • personalise and customise your experiences with our website
      • manage and administer any account you may hold with us
      • promote and market our products and services to you or provide you with information that we believe may be of interest to you
      • to help us research the needs of our customers and to market our products and services with a better understanding of your needs and the needs of customers generally
      • process any job application submitted by you
      • allow us to provide advertising material to you regarding us, our clients, and other business partners; and
      • share your personal information with our related entities, business partners and selected third parties, including for the purpose of the provision of credit to you.
    1. To whom we disclose your personal information
      • Depending on the nature of your engagement with us, we may disclose your personal information to our related entities, to third parties that provide products and services to us or through us, or to other third parties including:
        • the person with whom you lodged an application for credit with us;
        • your referee(s) in connection with a job application you have submitted.
      • We may also disclose your personal information to our website host or software application providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner.
      • Unless otherwise specified in this Privacy and Credit Reporting Policy, we or our website host will not disclose any of your personal information to any other organisation unless the disclosure is made with your consent, required by law, or is otherwise permitted by law (including the Australian Privacy Principles).
      • We may, where permitted by the Privacy Act, disclose your credit-related personal information to the following organisations:
        • credit reporting bodies;
        • our related entities;
        • external dispute resolution bodies;
        • our legal representatives;
        • Government agencies (for example, Centrelink);
        • any person in Australia who has, or will, guarantee or provide property as security for the repayment of credit provided to you;
        • another company for the purposes of considering whether to accept an assignment of debt or purchase of an interest in the credit provider;
        • debt collection agencies (for the purpose of collecting overdue payments);
        • another person or body in connection with securitisation arrangements for the purpose of purchasing, funding, managing or processing an application for credit or undertaking a credit enhancement; and
        • another Australian credit provider or enforcement body if we believe that you have committed a serious credit infringement; and
        • our service providers.
      • We may also disclose your personal information and credit information to Veda Advantage Information Services and Solutions Limited (Veda) or other credit reporting bodies as set out in this Privacy and Credit Reporting Policy from time to time. A copy of Veda’s Credit Reporting Policy can be obtained by contacting Veda:
        • by mail to Veda Information Services & Solutions Ltd, PO Box 964, North Sydney NSW 2059; or
        • via their website at www.veda.com.au/privacy.
      • You should be aware that:
        • credit reporting bodies may include credit information we provide to them about you in reports provided to other credit providers to assist them to assess your credit worthiness;
        • if you fail to meet your payment obligations in relation to consumer credit, or commit a serious credit infringement, we may disclose this to a credit reporting body;
        • you can request a credit reporting body not to use your credit reporting information for the purposes of pre-screening or direct marketing by us; and
        • you can request a credit reporting body not to use or disclose your credit reporting information if you believe on reasonable grounds that you have been (or are likely to be) a victim of fraud.
    1. Overseas disclosure
      • We are not likely to disclose your personal information or credit-related personal information to overseas entities or entities that do not have an Australian link.
    2. Marketing
      • You consent to us using your personal information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of mail, telemarketing, email, SMS and MMS messages. You can contact us using the contact details specified in paragraph 10 if you do not want to receive marketing information from us or if you want to stop receiving telemarketing.
    3. Accessing and updating your personal information and credit-related personal information
      • You are entitled to access personal information and credit-related personal information that we hold about you. If you request access to your personal information or credit-related personal information, in ordinary circumstances we will give you full access to your personal information or credit-related personal information. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your personal information or credit-related personal information, we will provide you with reasons for the refusal.
      • A request for access can be made by contacting our Privacy Officer in any of the ways specified in paragraph 10.
      • We take all reasonable steps to ensure that any personal information or credit-related personal information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete. Please contact us in any of the ways specified in paragraph 10 if you believe that the personal information is inaccurate or incomplete, and we will use all reasonable efforts to correct the information.
    4. Storage and security of personal information held by us
      • We aim to keep your personal information secure. Any personal information that is collected via our website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.
      • We do not collect sensitive or financial information about our users via our website.
      • If we find that we have no further need for your personal information or credit-related personal information we may remove it from our systems and destroy all record of it.
    5. What to do if you have a question, problem or complaint about our use of your personal information or this Privacy and Credit Reporting Policy
      • If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy and Credit Reporting Policy, or for any other queries in relation to this Privacy and Credit Reporting Policy, please first contact our Privacy Officer in any of the following ways:
      • If your query or complaint is in relation to personal information that is not credit-related personal information, we will investigate your query or complaint and will notify you of the outcome of our investigation within a reasonable period of time.
      • If your query or complaint is in relation to credit-related personal information, we will give you a written acknowledgement of your query or complaint within 7 days of your query or complaint being made and notify you of our decision within 30 days of your query or complaint unless a longer period is agreed to in writing. If you are seeking the correction of credit-related personal information we hold about you, we will acknowledge your correction request and respond to it as soon as practicable.
      • If you are not satisfied with our response you may also address your query or complaint to:
        • the Credit Investments Ombudsman Ltd
          • by phone: 1800 138 422
          • through its website: www.cio.org.au
          • in writing: Credit Investments Ombudsman Ltd, PO Box A252, South Sydney NSW 1235; or
        • the Office of the Australian Information Commissioner:
          • by phone: 1300 363 992
          • by email: enquiries@oaic.gov.au
          • in writing: GPO Box 2999, Canberra, ACT 2601 or GPO Box 5218, Sydney, NSW 2001.