This business (the Business) is owned and operated by Endpoints Capital Pty Ltd (we, us and our).

By using our Services, you agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, do not use our Services.

This Privacy Policy explains our approach to dealing with your Personal Information. We set out how we collect, hold, manage and use Personal Information.

We may update our Privacy Policy from time to time.

Scope of policy

This Privacy Policy applies to all Personal Information we hold.

“Personal Information” under the Privacy Act 1988 (Cth) (the Privacy Act) is defined to mean information or an opinion (including information or an opinion forming part of a database), 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, from the information or opinion.

Your consent

By accessing our goods and services, you consent to us using any Personal Information that we collect for any of the purposes set out in this Privacy Policy.

Collection of Personal Information

Why do we collect Personal Information?

We collect and hold Personal Information that is reasonably necessary for the services we provide. How do we collect Personal Information?

We will generally collect Personal Information from you directly through your use of our services. 

We may also collect Personal Information through applications, email or other communication with you, or through a face-to-face meeting or telephone conversation with you.

What form of Personal Information do we collect?

We may collect and hold the following types of Personal Information:
(a) Your name;
(b) Your date of birth;
(c) Age range;
(d) Your gender;
(e) Your phone number;
(f) Your nationality;
(g) Your email address;
(h) Your mailing address and delivery address;
(i) Job title;
(j) Organisation with which you are affiliated as an employee, contractor or agent; 
(k) Payment details; and
(l) Information provided by you when you use our services.

In the course of providing our services to you, we may also collect and hold more detailed personal information as required to perform our services.

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

Retaining your Personal Information

We will retain your personal information for the duration of your use of the Services. When you cease use of the Services we will retain your Personal Information for no longer than 7 years or for any such period that we must retain your Personal Information (the Retention Period).

We will make your personal Information available to you if requested.

Destruction of your Personal Information

Once the Retention Period has lapsed, we will ensure the timely and secure destruction and/or disposal of your Personal Information, including both physical information and cyber information.

If at any other time, you request we destroy and/or dispose of your Personal Information, we will comply with your request in a timely matter, to the extent that it does not interfere with the conduct of our business.

Breach of Personal Information

Security of your Personal Information

We will endeavour to protect your Personal Information from unauthorised interference (including access or disclosure).

Informing you of a Data Breach

A data breach will occur if there has been unauthorised interference to your Personal Information, and that interference is likely to result in serious harm to you (Data Breach).

If there is a Data Breach, we will determine if the Data Breach has caused or is likely to cause serious harm. If we determine that serious harm has or will be caused, we will notify you and the relevant reporting body of the Data Breach.

How we use your Personal Information

We collect, use and disclose Personal Information for purposes associated with conducting our business, providing services to you, marketing and promotional efforts, and to improve our content and service offerings, including:
(a) Facilitating services between you and us, entities associated with us and/or third- party individuals and organisations who we work with or alongside to provide services to you;
(b) Improving the quality of our service;
(c) Administrative purposes;
(d) Marketing communications purposes;
(e) Recruitment; and
(f) Complying with the law, including privacy legislation.

Exchanging your personal information with Credit Reporting Authorities (CRAs)

Identity verification – In order to verify your identity, we may exchange your name, residential address, and date of birth with a CRA to assess whether theinformation you provided matches the information in any credit file about you. The CRA may provide us with the results of its identity verification assessmentand may use your personal information, together with personal information it holds about other people, for the purposes of preparing that assessment.You consent to us providing your personal information to a CRA and requesting an identity verification assessment.

Credit reports – Where you apply for credit, we may also need to ask CRAs for your credit report to help us assess your credit application, manage yourloan, collect overdue payments, and act in the event of fraud or serious credit infringement. Where you are considering being a guarantor or security provider, you also consent to us requesting your credit report from a CRA to help us in our assessment.

Other exchanges – Other information we may exchange about you with CRAs includes:
(a) the type and amount of credit you have applied for
(b) if you have missed any repayments
(c) any temporary and permanent financial hardship arrangements that you may have with us
(d) if you have committed fraud or another serious credit infringement

Direct marketing

If you have given us your express consent to:
(a) Provide you with direct marketing communications; or
(b) Provide your Personal Information to third party individuals and organisations who we work with or alongside to provide services to you), we may collect, hold, use and disclose Personal Information in accordance with that consent to enable us (or those third-party individuals and organisations, as the case may be) to provide you information about, and offer you, goods and services.

If you give us consent to provide you with direct marketing communications, you can later request not to receive direct marketing communications. You may also request that we do not provide your Personal Information to any of our third party providers in order for them to provide you with direct marketing communications.

Disclosure

Such information may be shared with others as de-identified data in aggregated form.

Personally-identifiable information or business information will not be shared with third parties except as required by law or where you have given us your express consent to do so.

We may need to provide your Personal Information to third parties who we engage to assist us to provide goods and services to you, such as:
(a) Service providers who we engage to assist us in providing services to you;
(b) Information technology service providers; and
(c) Payment processors.

Where your Personal Information is disclosed to these third parties, they will only be authorised to use your Personal Information for the purpose that we supplied it to them. If those third parties are located overseas, then your Personal Information may be transferred overseas.

Data security and storage

Personal Information collected by us will be stored and processed on servers located within and outside of Australia. To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

In other limited circumstances, we may need to send your Personal Information overseas. These circumstances include:
(a) Where we have a supplier assisting us with the provision of goods and services and our business functions; and
(b) Where a third-party application is being used in connection with our interactions with you.

We will take all reasonable steps to maintain the security of Personal Information in these circumstances in accordance with this Privacy Policy, but our ability to ultimately control where these third-party providers host their applications or process their data may be limited. Legal disclosure of Personal Information

We reserve the right to disclose any Personal Information which identifies you as required by law and when we believe that disclosure is necessary to protect our rights, or to comply with a judicial proceeding, court order, or legal process served on our Business.

How to opt-out or access your Personal Information

If you:

(a) Want to find out what Personal Information we hold about you;
(b) Believe any of your Personal Information held by us is inaccurate, out of date, incomplete or it is not necessary for us to continue to hold it;
(c) Want to request not to receive direct marketing communications or that we do not provide your Personal Information to any of our third party providers in order for them to provide you with direct marketing communications; or
(d) Wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us, please contact us by emailing us at our contact email address at the end of this policy.

If you are not happy with our response, you may complain directly to the Australian Privacy Commissioner.

Complaints and contact

If you believe we have mishandled your personal information in violation of the Privacy Act, including its 13 Australian Privacy Principles or any associated codes like the Credit Reporting Privacy Code, you have the right to lodge a complaint. For any queries, complaints or requests regarding this policy or our handling or use of your Personal Information, please contact us at complaints@endpointscapital.com.au.