Compliance with Australian Privacy Principles

1.1) WHITE PICKET FENCE HOLDINGS PTY LTD ABN 63 653 292 605 t/as White Picket Fence respects and acknowledges the importance of privacy. White Picket Fence complies with the Australian Privacy Principles (APP) as contained within the Privacy Act 1988 (Cth) (Act) along with the Credit Reporting Privacy Code (Code), when collecting, using, disclosing and managing your personal information.

1.2) This Privacy Policy contains information in relation to our management of your personal information in accordance with the APP and the Code.

1.3) For the purposes of this Privacy Policy, the term “personal information” has the meaning given to it in the Act.

Use of personal information

2.1) White Picket Fence may collect and use your personal information for a variety of reasons, which may include but is not limited to the following:

• to enable you to access and use White Picket Fence’s online services;
• to fulfil your requests for White Picket Fence’s products and/or services;
• to complete your requested transactions, to verify the existence of and any conditions attached to your accounts or to assist with a transaction;
• to process transactions and send notifications about your transactions;
• for identity verification purposes that may involve the use of third-party systems, and the cross-referencing of supplied information against government or official identification sources;
• confirming identity for the purposes of anti-money laundering and counter-terrorism laws to determine whether you are suitable to engage White Picket Fence for our services;
• to manage and minimise risks and identify or investigate fraud and/or other illegal activities;
• responding to customer enquiries that includes the processing of complaints made to White Picket Fence;
• the resolution of disputes, collection of fees and troubleshooting problems;
• where it is necessary to evaluate your financial position and/or suitability for a product or service;
• dealing with credit infringements;
• to resolve disputes, collect fees, and troubleshoot problems;
• enforcement of our terms and conditions;
• deliver targeted marketing and various other notices and promotional communications based on your selected communication preferences;
• in the performance of data analytics to improve our services and your experience with White Picket Fence;
• protecting White Picket Fence and White Picket Fence’s assets (including against fraud) and selling White Picket Fence’s assets (including any assignment of debts); enforcing White Picket Fence’s rights (including undertaking debt collection) in connection with products and services provided by White Picket Fence to you;
• monitoring data, usage, records and statistics derived from your use of products and/or services provided by White Picket Fence for the furtherance of White Picket Fence business, for general market research and to be disclosed to third parties in relation to the aforementioned;
• to contact you through the use of various means e.g. telephone, text (SMS) or email messaging, advertising through our apps, websites, or third-party websites, mail, and/or any other means as authorised by our terms and conditions; White Picket Fence’s business development, including sending of updates and publications;
• to send you marketing and promotional messages and materials, and other information that may be of interest to you;
• to improve and personalise our services, optimise our website, applications, business and to learn about your level of satisfaction to ensure client satisfaction throughout the future operation and services provided by White Picket Fence;
• auditing and managing the use of White Picket Fence’s website; or
• in order for White Picket Fence to comply with legal and regulatory obligations.

2.2) You may withdraw your consent to receive marketing materials from White Picket Fence by contacting White Picket Fence’s Privacy Officer, details of which are contained within this Privacy Policy.

Collection of personal information

3.1) White Picket Fence collects personal information through a variety of methods, which may include the following:

• directly from you;
• from your employer;
• from brokers;
• through your access and use of White Picket Fence’s website;
• through your access and use of White Picket Fence’s applications;
• through your access of surveys commissioned by White Picket Fence;
• when you subscribe to receive information from White Picket Fence;
• when you communicate with White Picket Fence, by email, post or otherwise;
• through publicly available information; or
• in relation to credit matters:
  • by contacting the relevant credit reporting body and other credit providers who may hold information about you that may be relevant to White Picket Fence;
  • your employer;
  • your referees; or
  • professionals that you have had dealings with, including accountants, lawyers or financial advisers.

3.2) In the event that White Picket Fence is unable to obtain personal information from you as outlined above, this may result in White Picket Fence being unable to:

• assess your suitability, both financial or otherwise, in order for White Picket Fence to provide you with products or services; or
• provide you with marketing material.

Types of personal information and storage

4.1) The type of personal information that White Picket Fence may hold includes the following:

• identification information including your name, date of birth, occupation, phone number, address and other contact information;
• registration information including an email address and password;
• financial and related information, including assets, expenses, income and employment history;
• employment information including commencement date, salary, salary pay dates, hours or days worked, accrued employee entitlements and any other matters related to your employment;
• your tax file number and/or tax residency status;
• health information;
• passport number, medicare number, drivers license number or other identification information or documents;
• your transaction history, including details of any products or services that you have purchased from White Picket Fence, or that you have enquired about; and
• any other information provided by you in using White Picket Fence’s website and/or apps.

4.2) White Picket Fence may collect various financial information such as the full bank account details or credit card numbers that you link to your account with us.

4.3) The personal information referred to in clause 4.1 above may be held by White Picket Fence in both hardcopy files and also in an electronic form.

Personal information in relation to credit

5.1) In the event that White Picket Fence is required to collect personal information about you in relation to credit matters, such information may include:

• your credit application history with us and other credit providers;
• your repayment history for any lines of credit;
• any Court proceedings against you;
• any default information in relation to you; or
• publicly available information about you that relates to your credit worthiness.

5.2) By submitting an application for products and/or services with White Picket Fence, you agree and acknowledge that White Picket Fence may:

• obtain credit reporting information about you and credit reports from a creditor reporting body for the purposes of:
  • assessing your financial ability to obtain products and services from White Picket Fence; or
  • collecting payments that may be overdue.
• disclose your name, residential address and date of birth to a credit reporting body so that the credit reporting body can provide an assessment of whether the information provided by you matches (in whole or in part) the information in the possession of the credit reporting body’s possession or control.

5.3) White Picket Fence may disclose information about a payment (including part payment) owing by you that is:

1. at least 60 days overdue;
2. an amount of $150.00 or over; and
3. entitled to be recovered by White Picket Fence,

(Default Information). White Picket Fence may disclose Default Information about you to a credit reporting body after giving you any notices that White Picket Fence is required to give you in accordance with any laws or regulations. The Default Information provided to the credit reporting body may have the effect of altering your credit score and/or impacting your ability to access future credit.

Disclosure of personal information

6.1) White Picket Fence may be required to disclose your personal information to the following third parties:

• your employer in order to assess and confirm details of your employment, including commencement date, salary, salary pay dates, hours or days worked, accrued employee entitlements and any other matters related to your employment;
• external service providers so that the third party can carry out the service that they have been engaged by White Picket Fence for;
• our partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;
• guarantors and other security providers to your transaction;
• third parties who have instructed us to provide services;
• financial institutions partnered with White Picket Fence to create a product or promotion;
• other financial institutions (e.g. in the event a claim for a mistaken payment must be lodged);credit reporting bodies and collection agencies that are authorised to use information for credit reporting services;
• organisations that provide products or services used by White Picket Fence;
• organisations that help identify illegal activities and prevent fraud;
• our professional advisors, including our accountants, lawyers, business advisors and consultants; or
• any legal industry regulatory body in any of the states and territories that White Picket Fence operates in.

6.2) White Picket Fence may be required to disclose your personal information in order to respond to subpoenas, court orders, or to investigate, prevent, defend against, or take action regarding violations of our terms and conditions, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, customers/users or services.

6.3) Where the Act permits, White Picket Fence may also disclose personal information to third party suppliers and service providers located overseas for some of the purposes listed above.

Cross-border disclosure of personal information

7.1) White Picket Fence has affiliated offices operating in the Philippines. White Picket Fence may send your personal information to these offices for one or more of the purposes listed in clause 2.1. If White Picket Fence’s overseas offices are operated by ‘related body corporates’ of White Picket Fence, White Picket Fence will take such steps as a reasonably required to ensure that there is appropriate data handling of your personal information and proper security arrangements are in place

7.2) From time to time, White Picket Fence may also send your personal information overseas for the following reasons:

1. to third party service providers who store data or operate outside of Australia;
2. to complete a transaction involving an international financial institution; or
3. as required by laws and regulations of Australia or another country.

7.3) Before White Picket Fence discloses personal information about you to an overseas recipient who is not a related entity of you, White Picket Fence will take such steps as a reasonably required to ensure that there is appropriate data handling of your personal information and proper security arrangements are in place.

Cookies

8.1) Cookies are used by White Picket Fence in order to maximise our user experience and enhance the service that is provided.

8.2) When accessing White Picket Fence’s websites, applications or by engaging our services, small files of data may be placed on your device that enable White Picket Fence to recognise you as a White Picket Fence customer each time you return to our website or use our application to access our services. As a result of these cookies, customers avoid the need to keep inputting their email address and password throughout a session and may have these details auto filled when they visit the website or application. In addition, these cookies enable White Picket Fence to ascertain information regarding what web pages you visit and how regularly, enabling us to make our websites and platforms increasingly user friendly and to target advertising to content that you may be interested in.

8.3) You are free to decline the cookies in which White Picket Fence utilises and can disable them through your web browser.

Protection of personal information

9.1) White Picket Fence will take all reasonable steps to ensure that your personal information is properly protected from misuse, loss, unauthorised access, modification or disclosure.

Access to Privacy Policy

10.1) This Privacy Policy is publicly available, free of charge through White Picket Fence’s website.

Change to Privacy Policy

11.1) This Privacy Policy may change from time to time as required by White Picket Fence in order to reflect legislative and other changes.

Accessing and requesting correction of Personal Information

12.1) To access, seek or request personal information that White Picket Fence holds about you, please contact us at:

The Privacy Officer
info@wpfholdings.com.au

12.2) In the event that access to personal information is requested, White Picket Fence will endeavour to respond to that request as soon as reasonably practicable if and to the extent required by the applicable law.

12.3) If White Picket Fence are unable to give you access, or if White Picket Fence declines to amend your personal information, White Picket Fence will issue a written notice that describes our reasoning for doing so. White Picket Fence notes that before providing you with any personal information White Picket Fence will be required to verify your identity.

12.4) White Picket Fence reserves the right to make an administrative charge to you if it is required, to provide you with access to personal information as outlined in clauses 11.1 and 11.2 above.

Resolving your concerns

13.1) If you wish to make a complaint regarding that way in which White Picket Fence manages your personal information, or that you feel that White Picket Fence has fallen short of the required standards set by the Act, please prepare your complaint in writing and supply it to The Privacy Officer.

13.2) A written acknowledgement of your complaint will be provided within 7 days, and White Picket Fence will attempt to have your concern resolved within 30 days of receipt of your complaint.