Privacy Policy

1. Your Rights in Relation to Privacy

§  Brefwick Pty Limited (ABN 93 002 661 869) and the trading names Coffs Cash Exchange & Coast Country Pawnbrokers (“we”, “us” and “our”) understands the importance of protecting the privacy of an individual’s personal information. This statement sets out how we aim to protect the privacy of your personal information, including credit related personal information, how we collect, hold, use and disclose your personal information and your rights in relation to your personal information managed by us.

§  In handling your personal information, we will comply with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles in the Privacy Act. To the extent we handle your credit related personal information, we will also comply with the Credit Reporting Code. This privacy statement may be updated from time to time.

2. What Kinds of Personal Information Do We Collect?

§  Personal information is information or an opinion about an identified, or reasonably identifiable, individual. As a necessary part of conducting business and in the provision of our products and/or services, we may collect your personal information.

§  Generally, the kinds of personal information we collect are contact and identification information such as your name, address, telephone number, email address, bank account, credit card details, financial information and information about customer preferences.

§  When providing, or assessing an application for, commercial credit, and if you are guaranteeing or applying to guarantee commercial credit provided by us, we may also collect your credit information, being credit related personal information lawfully created and accessible within the Australian credit reporting system, and credit eligibility information which we obtain from Veda Advantage Information Services Solutions Limited (“Veda Advantage”) (the details of which are set out in paragraph 5) together with information we derive from such information based on our own analysis including internally generated scores, ratings and other assessments used to evaluate credit worthiness. Such credit information and credit eligibility information may include:

1.     identification information;

2.     consumer credit liability information which includes information about your credit providers and credit accounts, including the dates on when the accounts were opened and closed, their limits, and their terms and conditions (or any changes to their terms and conditions);

3.     whether you have or have not met any monthly repayment obligations;

4.     whether you have defaulted on a payment (i.e. a payment that is at least 60 days overdue and over $150 in value) provided we have notified you in accordance with the Privacy Act;

5.     whether you have paid any amount previously reported as being in default;

6.     that another credit provider has sought credit-related personal information about you from a credit reporting body;

7.     information about the types of consumer or commercial credit, and the amounts of credit, you have sought from a credit provider;

8.     information about court proceedings related to credit provided to you or for which you have applied;

9.     personal insolvency information and other publicly available information relating to your credit worthiness;

10.  a credit provider’s reasonable belief that you have committed a serious credit infringement; and

11.  any other information lawfully obtainable within the Australian credit reporting system.

§  We may also collect sensitive information including information about any criminal record or driving offences where relevant to your ability to carry out the inherent requirements of a franchisee, contractor or supplier of ours, as applicable.

§  In some circumstances we may also hold other personal information provided by you.

3. How Do We Collect Personal Information?

§  Generally, we collect your personal information directly from you, through completion of a hard copy or online form, an interaction or exchange in person or by telephone, facsimile, email or post or through the use of our website. There may be other occasions when we collect your personal information from other sources such as from Veda Advantage, an information services provider or a publicly maintained record. Generally, we will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

4. Why Do We Need Your Personal Information?

§  We collect hold, use and disclose your personal information where it is reasonably necessary for the purposes of:

1.     providing our services including parcel collection and delivery throughout Australia and managing freight;

2.     identifying and informing you of products and/or services that may be of interest to you from us or selected third parties;

3.     offering, facilitating and managing franchise opportunities and arrangements;

4.     providing, or assessing an application for, commercial credit;

5.     assessing your application to guarantee any commercial credit provided by, or for which an application has been made to, us;

6.     accounting, billing, debt collection and other internal administrative purposes;

7.     facilitating the provision and management of insurance cover and insurance claims;

8.     assessing your application for employment with us, engaging you as a contractor or consultant or otherwise in connection with an application for employment or to become a franchisee, supplier or customer of ours; and

9.     any other legal requirements.

§  If you are a contact person for one of our business partners, including a franchisee, supplier and/or customer, your personal information may be used by us to administer and develop our business relationship with the organisation you represent and our other business partners.

§  We may also use your personal information for purposes related to the above purposes and for which you would reasonably expect us to do so in the circumstances, or where you have consented or the use is otherwise permitted by law.

§  You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide our products and/or services to you.

5. To Whom Do We Disclose Your Personal Information?

§  We disclose your personal information for the purpose for which we collect it (for example, to facilitate the transaction for which it was collected). In other words, we will only disclose your personal information for a purpose set out at paragraph 4 or a purpose related to the purpose of collection. This may include disclosing your personal information to:

§   

§  third parties engaged to perform administrative or other services, including stationery printers and mailing houses;

§  franchisees within our network;

§  agents and contractors within our network;

§  our professional advisors, contractors, consultants and related bodies corporate;

§  mercantile agencies;

§  insurance providers;

§  regulatory authorities; and

§  persons or entities looking to acquire an interest in our enterprise or assets.

§  We may also disclose your personal information, including your credit information, to Veda Advantage (contactable on the details set out below). In particular, we may disclose to Veda Advantage information about you failing to meet your payment obligations or if you commit a serious credit infringement. Veda Advantage may include any information provided by us in reports it provides to other credit providers for the purpose of such credit providers assessing your credit worthiness.

§  Such disclosures are always on a confidential basis or otherwise in accordance with law. We may also disclose your personal information with your consent or if disclosure is required or authorised by law.

§  Veda Advantage can be contacted by writing to Veda Public Access, PO Box 964, North Sydney NSW 2059 or by ordering an online copy of credit reporting information Veda Advantage holds about you through www.veda.com.au/understanding-your-credit- file.

§  Veda Advantage’s policy on its management of credit related personal information can be accessed through its website at www.veda.com.au.

6. Overseas Disclosure

§  We are part of a global organisation which has a presence in many parts of the world. We may disclose personal information, including credit related personal information, to overseas recipients in order to provide our products and/or services and for administrative or other business management purposes. We are likely to make such disclosures to our business affiliates in New Zealand.

§  Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, we take steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.

7. Security of Your Personal Information

§  We take steps reasonable in the circumstances to ensure that the personal information, including credit related personal information, we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold personal information in both hard copy and electronic forms in secure databases on secure premises.

§  We will destroy or de-identify personal information in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.

§  If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you may request Veda Advantage not to use or disclose credit related personal information it holds about you by contacting Veda Advantage on the details set out in paragraph 5.

8. Access and Correction

§  We take reasonable steps to ensure the personal information we hold is accurate, up- to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by us.

§  If at any time you would like to access or correct the personal information that we hold about you, or you would like more information on our approach to privacy, please contact us via the contact details in paragraph 9 below. We will grant access to the extent required or authorised by law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

§  Where necessary to resolve a request for correction of your credit related personal information, we may also consult with other relevant entities including, but not limited to, Veda Advantage.

§  To obtain access to your personal information:

1.     third parties engaged to perform administrative or other services, including stationery printers and mailing houses;

2.     you may be asked to put your request in writing and to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;

3.     we ask that you be reasonably specific about the information you require; and

4.     we may charge you a reasonable administration fee which reflects the cost to us for the retrieval and supply of information in accordance with your request.

§  Alternatively, if you would like to access personal information held about you by Veda Advantage, please contact Veda Advantage on the contact details set out in paragraph 5.

§  We will endeavour to respond to your request for access or correction within 30 days from your request. Where we are able to grant your request, we will provide access to the information in the manner you request where reasonable and practicable to do so.

§  If we refuse your request to access or correct your personal information, we will, where reasonable to do so, provide you with written reasons for the refusal. We will also provide details of complaint mechanisms.

9. How to Contact Us

§  For further information or enquiries, or if you would like to opt out of receiving any promotional or marketing communications, please contact our Privacy Compliance Officer by email at privacy-@coffscashexchange.com.au or by mail addressed to the Privacy Compliance Officer, Brefwick Pty Ltd, 224 Harbour Drive, COFFS HARBOUR NSW 2450.

10. Privacy Complaints

§  Please direct all privacy complaints to our Privacy Compliance Officer. At all times, privacy complaints:

1.     will be treated seriously;

2.     will be dealt with promptly;

3.     will be dealt with in a confidential manner; and

4.     will not affect your existing obligations or affect the commercial arrangements between you and us.

§  Specifically, if your complaint relates to credit related personal information and/or our failure to comply with our obligations regarding credit related personal information under the Privacy Act and/or Credit Reporting Code:

1.     we will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless we inform you otherwise and seek your agreement in writing;

2.     we may consult with relevant third parties, such as Veda Advantage or other credit providers, in order to sufficiently and expeditiously resolve the complaint; and

3.     if your complaint relates to a refusal to provide access to, or correct, your personal information, you may complain directly to the Office of the Australian Information Commissioner.

§  Our Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Federal Office of the Australian Information Commissioner.

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