On Deck Capital Australia Pty Ltd
Collection of personal information
The personal information that we collect about an individual will usually depend upon the products or services that are being provided, or that may be provided. That product or service may be provided to you or to another person connected to you. The information we may collect about you, where you are an individual, may include some or all of the following:
- your name, address, date of birth and contact details; your business name;
- your e-mail address; your tax file number;
- your unique identifiers, such as user name, password and IP address; information from personal identification documents;
- information required for identity verification purposes;
- details about your financial situation, which may include information about your assets, expenses and any debts you may have (including by the collection of bank statements, credit report information and payments history);
- in some circumstances (for example, in the event that you require financial hardship assistance), we may require you to provide information and supporting documents regarding your financial situation, relevant health or medical information and any other information to help us manage our relationship with you.
- details of any securities you have given to us or another person; information about your business, including its size and business type; and details of specified transactions with which you are involved.
We may also process consumer credit-related personal information about a customer to develop a credit rating or score, which assists us in our assessment of a customer’s credit worthiness. From time to time, we may reach out to you to request additional or updated information, for example, where you wish to take out a new loan or to vary an existing loan, or where we otherwise need such information to better allow us to provide our products and services.
Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
Before OnDeck provides a product or service to you, or to a person connected with you, we may (where you are an individual) be required to collect your personal information in order for OnDeck to comply with its customer identification obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AMLCTF Act). The personal information we collect for this purpose typically includes identification information, such as name, residential address and date of birth. In some cases, we may need to collect information about the political activities and opinions of individuals to determine whether they are politically exposed persons for the purposes of the AMLCTF Act. If we ask for this information, and you provide it to us, we will infer your consent to use and disclose the information for this purpose. In certain circumstances, we may need to clarify and/or update the personal information we previously collected for identity verification purposes, and/or collect further information, including financial information about individuals. Where this is necessary, we will collect the information directly from you and/or from third party sources. As a part of our AMLCTF verification processes we may need to take copies of your personal identification documents in order to verify your identity in accordance with the requirements of that Act. We may also disclose your full name, residential address and date of birth to a credit reporting body for the purpose of providing an assessment of whether this identification information matches (wholly or in partly) personal information held by the credit reporting body. The credit reporting body may compare your details with personal information held by the body (being the names, residential address and dates of birth of other individuals) for the purposes of making this assessment. You have the right to:
- let us know by email at firstname.lastname@example.org if you do not want us to disclose your personal information to a credit reporting body for this purpose; and
- opt for an alternative means of verifying your identity for the purposes of the AMLCTF Act.
How we collect personal information
In most instances, we will collect information about you:
- from an application form completed by you or by a person connected to you;
- from information provide to us by you or by person seeking finance from OnDeck (including through the Website or our mobile application (Mobile App);
- from information you otherwise provide to us, or our agents;
- from information and referrals provided by our business partners; from conducting site visits to obtain information;
- from external data providers used by lenders, for example, credit reporting agencies or other credit providers, as well as other vendors and social media;
- by our accessing public databases, such as those maintained by the Australian Securities and Investment Commission;
- by us seeking verification information in relation to your identity from a third party, such as Equifax Australia Information Services and Solutions Pty Limited;
- by our obtaining other information from third party commercial and business information providers; by email request to you; and/or
- by telephone contact with you.
We will normally collect your personal information directly from you, unless it is unreasonable or impractical to do so. We may collect information from you electronically from our Website and Mobile App. This information collected through our Website or Mobile App may include internet protocol addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We will not collect sensitive information about you without your consent except where we are authorised or required to do so by law.
Uses and disclosure of personal information
We will only use or disclose personal information (including credit related information) we collect about you:
- for the purpose for which it was collected;
- for related purposes for which you would reasonably expect us to use or disclose the information;
- for marketing our products and services to you;
- where you have consented to us using or disclosing the information; and/or
- where we are required or otherwise permitted to do so by law.
We may use your personal information (including credit related information) to:
- identify you, conduct appropriate due diligence, or establish your tax status under any Australian or foreign legislation, regulation or treaty or pursuant to an agreement with any tax authority;
- assess and process your request and application for a financial product or service;
- assess and process a request for the provision of a financial product or service to a person or entity connected with you;
- assess your suitability as a guarantor or potential guarantor;
- operate, maintain, improve and provide a financial product or service to you, or a person or entity connected with you; open and maintain a business loan account for you, or the account of a person or entity connected with you;
- complete and manage our transactions with you, including by deducting periodic payments due;
- communicate with you to send confirmations and to send account update notifications;
- manage our relationship with you, or a person or entity connected with you and respond to customer requests;
- help us to assess products that may suit your financial needs or the needs of a person or entity connected with you; send marketing communications and notify you of any products that may be of interest to you or a person or entity connected with you;
- audit and monitor the services we provide to you or a person or entity connected with you;
- assist us to perform administrative or operational task (including risk management, systems development and testing, credit scoring, staff training and customer research);
- investigate, identify or prevent any actual or suspected fraud or unlawful activity;
- update the personal information we hold about you or the files of a person or entity connected with you;
- enable us to meet our obligations under law, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or under Australian taxation laws;
- post and review your comments on our blog, where you request us to do so; and/or
- produce data analytics and reports containing anonymised summaries derived from personal information and other information that is not personal information (General Information) that we may then share with business partners. (General Information may include personal information that has been aggregated, anonymized and that will not identify you.)
We may disclose your personal information (including credit related information) to:
- our related companies;
- our business partners, service providers, subsidiaries and affiliates that are assisting in the review or processing of a credit application with which you are connected, or with the provision of our services, such as by providing data storage and other similar services;
- our agents, the person who introduced you to us, contractors, advisors or other third party service providers, to enable them to provide administrative and other support services to us;
- credit reporting bodies, such as Equifax or Illion;
- other organisations involved in providing credit to you;
- other financial institutions in connection with a credit application with which you are connected or in connect with your dealings with us;
- your authorised agents or your executor, administrator or legal representative, or to any person who proposes to guarantee or has guaranteed repayment of any credit provided to you;
- government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes, or to any tribunal, coutry or otherwise in connection with any complaint about the approval or management of my loan; and/or
- people with, or considering acquiring an interest in, our business or assets.
While we may use third party service providers to maintain some of our data systems and provide auxiliary services, these entities are authorised to use your personal information only as necessary to provide these types of services to us. We require any person that has access to personal information that we have collected must act in a manner consistent with our obligations under the Privacy Act and with our general privacy standards. Our third party service providers may use this information for the purposes of internal reporting, assessing and improving the customer experience, and for marketing and promotional activities.
Data sharing with our business partners
We may share personal information (including credit-related personal information) and business-related information with our business partners with whom you have an existing business relationship, such as the broker, originator or other introducer who referred you to OnDeck. Our business partners refer your details to us for the purpose of inviting you to apply for a business loan. If you apply for a loan, we will disclose certain personal information (including credit-related personal information) and business-related information to the relevant business partner. The information we disclose to the business partner is collected by us in the course of the application process, and in servicing your loan. Our business partners use this information for the purposes of internal reporting, assessing and improving the customer experience, and for marketing and promotional activities. The types of information we typically share with the relevant business include the following:
- the name of your business and contact details;
- whether we approved or declined your loan, the loan amount and term; your assets reported, liabilities, and turnover; and
- details about failed or late payments, and
For further information about the information we share with our business partners, please contact us using the contact details on our website.
How we hold personal information
We take reasonable steps to ensure that the personal information we collect is protected from loss, misuse and interference, and from unauthorised access, modification or disclosure. The information we collect about individuals will be stored in electronic files and hosted in the United States by our parent company, On Deck Capital, Inc. We use a range of physical and electronic security measures, such as access restrictions, to secure the personal information we hold. We also train our employees to keep our customers’ personal information confidential.
We may disclose your personal information to our business partners, service providers and subsidiaries and affiliates who are located overseas and/or do not carry on business in Australia in order to assist us in delivering our products and services to you, such as providing customer service, processing credit checks or securing data storage and other similar services. Where we do so, we will do so in compliance with applicable laws. It is likely that such disclosures will be made to persons in countries including the United States of America.
While we do not provide our customers with consumer credit, we may use a customer’s consumer credit information to assist us in assessing an application for commercial credit, or an application to act as guarantor in relation to such credit. To this end, we may disclose personal information to, or collect personal information, from a credit reporting body. The credit reporting body to which we disclose the information will include this information in reports that are made available to other credit providers to assist them to assess an individual’s credit worthiness. The credit reporting bodies from which we collect, and to which we disclose, credit information include Equifax Australia Information Services and Solutions Pty Limited and its related companies (Equifax) and Illion Australia Pty Ltd and its related companies (Illion). For contact details and information as to how these bodies manage credit information, please see their privacy policies and credit reporting policies, available here:
You can ask these credit reporting bodies not to:
- use or disclose your credit reporting information for a period if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud; and
- use your credit reporting information for the purposes of pre-screening of direct marketing by a credit provider.
OnDeck does not use credit related personal information for the purposes of direct marketing our products or services to individuals.
Access and correction
We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date. You may, at any time, request access to personal information (including your personal credit information) that we hold about you and, if there is an error (or our information about you is incomplete, inaccurate or out of date), you can advise us about this matter and we will, if needed, correct, amend or add to the information we hold about you. We will not charge you a fee for your access request, but may charge you the reasonable cost of processing your request, including so as to allow us to provide you with access to your personal information. If you would like to request access to the information that OnDeck holds about you, please contact our Privacy Officer c/- Customer Support at: email@example.com or by contacting us by postal mail at the contact address listed below. We will respond to your request within 30 business days. We will retain your information for as long as your account is active or as long as reasonably useful for commercial purposes.
Marketing and option to opt out
OnDeck may contact you to offer you products and services that may be of interest to you. You may choose to stop receiving our marketing material and telephone solicitations or other forms of contact from OnDeck by following the unsubscribe instructions included in our emails or by contacting us by email at firstname.lastname@example.org (and including your full name and business mailing email addresses and account number) or by postal mail to us at the following address: On Deck Capital Australia Pty Ltd PO Box 824 Sydney NSW 2000 You may also opt-out from continuing to share any personal information that you have provide on our Website for public display, such as through contributions to publicly accessible blogs or community forums and testimonials on the Website. You may do this by contacting us on the email address provided above.
Concerns or breaches
Additional information relating to use of our Website
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve marketing, analytics, and Website functionality.
We partner with third parties to display advertising on our Website and manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being presented with advertisements. You will continue to be presented with generic advertisements.
Security of Information
OnDeck takes the security of your information very seriously. OnDeck protects your information using end-to-end encryption: 128 bit-encryption and a Secure Sockets Layer (SSL) protocol. This creates an encrypted connection between your browser and our servers. When you enter Sensitive Personal Information (such as a credit card number) on our order forms, we encrypt the transmission of that information. If you allow OnDeck to see your banking information online rather than in paper form, it is on a read-only basis. We do not have access to change, edit, or modify bank account information in any way. OnDeck employees cannot view your banking username and passwords, and we securely store them in separate encrypted areas with our financial services providers.
Additional Information – Links to third party sites
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us by email at email@example.com or by postal mail at the contact information listed above. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display personal testimonials of satisfied customers on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us by email at firstname.lastname@example.org or by postal mail at the contact information listed below.
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