Finkey Privacy Policy and Credit Reporting Policy

Finkey Privacy Policy and Credit Reporting Policy

In this Privacy Policy, ‘us’, ‘we’ or ‘our’ means Finkey Capital Pty Ltd ABN 37 662
168 916 an is an authorised holder of Australian Credit Licence no.550288. We are
committed to respecting your privacy. Our Privacy Policy sets out how we collect,
use, store and disclose your personal information (including for consumer or
commercial credit). We are bound by the Australian Privacy Principles contained in
the Privacy Act 1988 (Cth) (‘Privacy Act’)

We may change our Privacy Policy from time to time by publishing changes to it on
our website. We encourage you to check our website periodically to ensure that you
are aware of our current Privacy Policy. By providing personal information to us, you
consent to our collection, use and disclosure of your personal information in
accordance with this Privacy Policy and any other arrangements that apply between
us.

Personal information includes information or an opinion about an individual that is
reasonably identifiable. For example, this may include your name, age, gender,
postcode and contact details. It may also include financial information, including your
credit card information.

We may collect, use, disclose, hold or manage personal information or do any things
set out in this document on our own behalf or as agent of a principal (whether
disclosed or not). The information given in this document is given by both us and any
principal (whether disclosed or not). Principal’s identity is available on request.

What personal information do we collect?

We may collect the following types of personal information:
• name;
• mailing or street address;
• email address;
• telephone number and other contact details;
• age or date of birth;
• credit card information;
• bank details;
• identification information, such as your driver’s licence or passport
number;
• your device ID, device type, geo-location information, computer and
connection information, statistics on page views, traffic to and from the
sites,
• ad data, IP address and standard web log information;
• details of the products and services we have provided to you or that you
have enquired about, including any additional information necessary to
• deliver those products and services and respond to your enquiries;
• any additional information relating to you that you provide to us directly
through our website or app or indirectly through your use of our website
or app or online presence or through other websites or accounts from
which you permit us to collect information;
• information you provide to us through customer surveys;
• current and historical energy usage, load and consumption data, meter
type and model and other statistics on your use of energy products and
associated metering software, including products and software which are
financed by us, where we have obtained your consent; or
• any other personal information that may be required in order to facilitate
your dealings with us.

Use of the Document Verification Service (DVS) to Verify Your Identity

Finkey Capital Pty Ltd uses the Australian Government’s Document
Verification Service (DVS) to verify identification information you provide to us,
such as driver’s licence, passport or other government-issued identity
document details.
We are a DVS Business User under the Identity Verification Services Act
2023 (Cth) and the DVS Participation Agreement administered by the
Attorney-General’s Department.
When you consent to an identity check, we will send your identification
information (such as your name, date of birth and document number) through
a secure system to the DVS to confirm that the information matches the
corresponding record held by the issuing authority (e.g. passports, state and
territory driver licensing authorities, or Births, Deaths and Marriages
registries).

The DVS returns only a match or non-match result — no record or image of
your identification document is stored or shared by the DVS.

Your information is used solely for verifying your identity to assess or manage
your credit or finance application and is handled in accordance with the
Privacy Act 1988 (Cth) and the Australian Privacy Principles.
Your rights and choices:
• You may decline to consent to a DVS check. However, if you do not
provide consent, we may be unable to verify your identity electronically
and may require certified identity documents through alternative
means.
• You have the right to access and correct any personal information we
hold about you.
• You can obtain further information or make a privacy complaint about
our handling of your identification information by contacting:
The Privacy Officer – privacy@finkey.co | 1300 346 539 |
PO Box 765 Ryde 2112 NSW
or the Office of the Australian Information Commissioner
(www.oaic.gov.au)

Disclosure to Vendors:
You consent to Finkey sharing relevant information about the status of your
application, including the outcome, credit limits, and finance purpose, with the
Vendor engaged for your project. This disclosure is necessary to ensure the
Vendor’s ability to deliver the goods and services financed through the application.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing
communications and information about our financial products and services. This may
take the form of emails, SMS, mail or other forms of communication, in accordance
with the Spam Act 2003 (Cth) and the Privacy Act. By providing us with your
personal information, you consent to us and our business partners using your
information to contact you on an ongoing basis for this purpose, including by mail,
email, SMS and telephone. You may opt-out of receiving marketing materials from
us by contacting us using the details set out below or by using the opt-out facilities
provided (e.g., an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy
Policy to:
• our employees and related bodies corporate;
• your agents;
• referrers and other intermediaries;
• credit and debt agencies
• third parties for securitisation purposes
• third party organisations that carry out functions on our behalf;
• third party suppliers and service providers (including providers for the
operation of our websites, platform, CRM, application processing and/or
our business or in connection with providing our products and services to
you);
• professional advisers, dealers and agents;
• payment systems operators (e.g. merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our
services;
• anyone to whom our assets or businesses (or any part of them) are
transferred;
• specific third parties authorised by you to receive information held by us;
and/or
• other persons, including government agencies, regulatory bodies and law
enforcement agencies, or as required, authorised or permitted by law

We may also disclose your personal information to a trusted third party who also
holds other information about you. This third party may combine that information in
order to enable it and us to develop anonymised consumer insights so that we can
better understand your preferences and interests, personalise your experience and
enhance the products and services that you receive.
By providing us with your personal information, you consent to us disclosing your
information to such entities without obtaining your consent on a case-by-case basis.

Disclosure of personal information outside Australia

We may disclose personal information outside of Australia to credit check companies
and cloud services providers located in the US, UK, Philippines, Singapore, Spain,
Costa Rica, Finland, Mongolia, Israel, Bulgaria, Canada, India, Japan, Mexico and
New Zealand.

When you provide your personal information to us, you consent to the disclosure of
your information outside of Australia and acknowledge that we may not be required
to ensure that overseas recipients handle that personal information in compliance
with Australian privacy law. Where possible, we will endeavour to take reasonable
steps to ensure that the overseas recipient complies with the Australian Privacy
Principals. You accept that we will not be liable for the information once it is
disclosed overseas, and you waive your right to make any claim against us under the
Australian privacy law in the event of any breach.

Using our website and cookies

We may collect personal information about you when you use and access our
website.

While we do not use browsing information to identify you personally, we may record
certain information about your use of our website, such as which pages you visit, the
time and date of your visit and the internet protocol address assigned to your
computer

We may also use ‘cookies’ or other similar tracking technologies on our website that
help us track your website usage and remember your preferences. Cookies are
small files that store information on your computer, TV, mobile phone or other
device. They enable the entity that put the cookie on your device to recognise you
across different websites, services, devices and/or browsing sessions. You can
disable cookies through your internet browser but our websites may not work as
intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal
information. For example, where a cookie is linked to your account, it may be
considered personal information under the Privacy Act. We will handle any personal
information collected by cookies in the same way that we handle all other personal
information as described in this Privacy Policy.

Security

We may hold your personal information in either electronic or hard copy form and
your personal information may be stored on behalf of third- party service providers.
We take reasonable steps to protect your personal information from misuse,
interference and loss, as well as unauthorised access, modification or disclosure and
we use a number of physical, administrative, personnel and technical measures to
protect your personal information. However, we cannot guarantee the security of
your personal information.

Measures that we may take to protect your personal information include, but are not
limited to:

• using appropriate information technology and processes;
• restricting access to your personal information to our employees and
those who perform services for us who need your personal information to
do what we have engaged them to do;
• protecting paper documents from unauthorised access or use through
security systems we deploy over our physical premises;
• using computer and network security systems with appropriate firewalls,
encryption
• technology and passwords for the protection of electronic files;
• securely destroying or “de-identifying” personal information if we no
longer require it
• subject to our legal obligations to keep some information for certain
prescribed periods; and
• requesting certain personal information from you when you wish to
discuss any issues relating to the products and services we provide to
you.

Links

Our website may contain links to websites operated by third parties. Those links are
provided for convenience and may not remain current or be maintained. Unless
expressly stated otherwise, we are not responsible for the privacy practices of, or

any content on, those linked websites, and have no control over or rights in those
linked websites. The privacy policies that apply to those other websites may differ
substantially from our Privacy Policy, so we encourage individuals to read them

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using
the information below. Sometimes, we may not be able to provide you with access to
all of your personal information and, where this is the case, we will tell you why. We
may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please
contact us and we will take reasonable steps to ensure that it is corrected. We will
generally rely on you to assist us in informing us if the information we hold about you
is inaccurate or incomplete

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint
about the way we have handled your personal information, you can contact us using
the details set out below. Please include your name, email address and/or telephone
number and clearly describe your complaint. We will acknowledge your complaint
and respond to you regarding your complaint within a reasonable period of time. If
you think that we have failed to resolve the complaint satisfactorily, we will provide
you with information about the further steps you can take.

Contact Us

 

For further information about our Privacy Policy or practices, or to access or correct
your personal information, or make a complaint, please contact us using the details

set out below:
The Privacy Officer
Finkey Capital Pty Ltd
Phone: 1300 346 539
Email: privacy@finkey.co
Mail: PO Box 765 Ryde 2112 NSW

If you require further information about Privacy laws generally, please contact:

The Privacy Commissioner
Office of the Federal Privacy Commissioner
Mail: GPO Box 5218, Sydney NSW 1042
Phone: 1300 363 992
Fax: (02) 9284 9666
Internet: www.oaic.gov.au

See the separate Finkey Statement of Notifiable Matters

You Accept ALL Our Terms

By checking any box or highlighting any responsive buttons titled ‘I accept the
Privacy Policy, Privacy Statement and Electronic Communication Consent’, ‘I accept
all Privacy, Terms and Conditions, Terms of Use, Consents, Advice, Statements,
and Notices available on Finkey’s website finkey.co, clicking any ‘acknowledgement’
or ‘acceptance’ buttons after inputting your personal information, clicking buttons
labelled ‘apply’, ‘apply now’, ‘submit’, ‘submit application’, ‘agree’, ‘send’, or
providing consent to your Vendor, third-party or accredited organisation obtaining
your contact information to recommend you to Finkey, you agree to the collection,
use and disclosure of your personal information as outlined in this statement.