On Deck Capital Australia Pty Ltd
Collection of personal information
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. We may be required to do this 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 email@example.com 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.
We may use an electronic identity verification solution to verify our customers’ identities as required under the AMLCTF Act, and to undertake a fraud risk assessment. This solution is provided by our service provider, Equifax Australia Information Services and Solutions Pty Limited and its related companies (Equifax). Conducting these checks may, in some cases, require Equifax to access third party databases on your behalf. If this is necessary, you authorise Equifax to access these databases as your agent for identity verification and fraud assessment purposes.
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 a person seeking finance from OnDeck (including through the Website or our mobile application);
- 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 we use, as well as other vendors and social media;
- from other credit providers and from credit reporting bodies;
- by accessing public databases, such as those maintained by the Australian Securities and Investments Commission;
- by seeking verification information in relation to your identity from a third party, such as a credit reporting body;
- by obtaining other information from third party commercial and business information providers; and/or
- by email request to you or by telephone contact with you.
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
Where we collect your personal information, it will be to allow us to:
- identify you, conduct appropriate due diligence, or establish your tax status;
- 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 AMLCTF Act 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 that we may then share with business partners.
We may disclose your personal 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;
- other organisations involved in providing credit to you;
- other financial institutions in connection with a credit application with which you are connected or in connection 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.
In specific circumstances, we will not disclose your credit-related information without your consent except where we are authorised or required to do so by law.
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 partner include the following:
- the name of your business and contact details;
- whether we approved or declined your loan (including reasons), the loan amount and term;
- your assets reported, liabilities, and turnover; and
- details about failed or late payments, and arrears.
For further information about the information we share with our business partners, please contact us using the contact details on our website.
As is the case with many industries, technology allows for services to be provided by different service providers including some that are located overseas. We rely on overseas service providers for some of our activities and to do so may need to disclose personal information to those service providers. We may also disclose your personal information to our related companies, business partners, and affiliates who are located overseas. This may include a disclosure to entities not established in Australia or that do not carry on business in Australia. It is likely that such disclosures will be made to persons in countries including the United States of America.
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 post to our contact address below.
On Deck Capital Australia Pty Ltd PO Box 824 Sydney NSW 2000
Personal information you provide about someone else
If you give OnDeck personal information about someone else, please show them a copy of this Privacy Statement so that they may understand the manner in which their personal information may be used or disclosed by OnDeck in connection with your dealings with OnDeck.
Last Updated in May 2019