Mobile App Privacy Policy

Fundo Loans Pty Ltd ACN 604 639 143 (referred to as 'Fundo Loans', 'we', 'our', 'us' ) is a credit provider for people who need a small or medium amount of money for a short time.

Before continuing, please read this Policy carefully

The confidentiality and security of customer's information is of utmost importance to us. We recognise that our success depends on us maintaining the utmost commitment to upholding customers' privacy rights when we collect, hold, use or disclose customers' personal information (which includes credit-related information). We have established procedures and protocols to help us keep personal information we hold secure, accurate, up-to-date and complete.

This Privacy Policy (the 'Policy') outlines our obligations to manage and protect personal information and our practices, procedures and systems that ensure compliance with the requirements of the Australian Privacy Principles ('APPs'), the Privacy (Credit Reporting) Code ('the Code') and Part IIIA of the Privacy Act 1988 (Cth) (the 'Privacy Act') and other applicable laws. This Policy applies to and covers all operations and functions of Fundo Loans. All staff members and third-parties (including suppliers, sub-contractors and agents) that have access to or use personal information (which includes credit-related information) collected and held by Fundo Loans must comply with this Privacy Policy.

1. The Entity Collecting Personal Information

The identity and contact details of Fundo Loans are as follows:

Fundo Loans

9, 46 Kippax Street, Surry Hills, NSW 2010 Australia

Email: hello@fundo.com.au

Phone: 1800 161 391

Website: www.fundo.com.au

2. What Kind of Personal Information Do We Collect

We will, from time to time, collect the following information or opinion relating to a customer, which can be used to identify that customer (the 'Personal Information'):

name;
address and email addresses;
phone and mobile numbers;
date of birth;
biometric data, such as voiceprint, fingerprint and real-time taken photograph;
employment details and pay advices;
bank account details and account statements;
identification number, passport, Driver's licence or Medicare card details;
marital status and dependents;
device information, such as IP address, operating systems, browser type;
browsing history, such as date and time of visits, pages viewed, accessing history of third-party sites;
telecommunications usage data;
approximate geographical location;
character references (e.g. names, email addresses and contact number of your character references);
credit information, such as the type, terms, maximum amount, time of provision and repayment of credit provided, repayment history; financial hardship (including information that any repayments are affected by a financial hardship arrangement), default (including overdue payments), payment, new arrangement information, details of any serious credit infringements, court proceedings, personal insolvency and publicly available information (the 'Credit Information');
credit reporting information supplied to us by a credit reporting body (CRB) and any information that we derive from it (the 'Credit Eligibility Information', together with the Credit Information, the 'Credit-related Information'); and
any other information that is relevant to the services that we provide.

In most circumstances it will be necessary for us to identify a customer in order to successfully do business with them. However, where it is lawful and practicable to do so, we will offer a customer the opportunity of doing business with us without providing us with personal information, for example, if a customer makes general inquiries about interest rates or current promotional offers.

3. HOW WE COLLECT PERSONAL INFORMATION

We may collect the following Personal Information directly provided by a customer through manual or automated means (such as cookies), including, without limitation to, information provided directly by you, the way you use and manage your account/facility, from your device, Fundo's website or mobile app, enquiry or credit application, email, letter or telephone enquiry.

We may also collect Personal Information about you from third-parties or other sources, such as:

financial institutions;
mortgage and finance brokers;
employers;
accountants;
lawyers;
other credit providers;
electronic verification services;
a CRB;
social media;
public registers;
governmental authorities, regulatory bodies and/or law enforcement agencies;

We also use cookies for a number of purposes, including but not limited to, preference for certain types of information or products, analysing traffic at our website and mobile application, to improve our products and/or to personalise our services Information collected through such analysis is anonymous. You may adjust the settings on your browser and/or mobile device to enable or disable cookie or other similar tracking tools.

We will not ask our customers to supply Personal Information publicly over Facebook, X, or any other social media platform.

If we receive unsolicited personal information about an individual, we shall destroy or de-identify all unsolicited personal information, unless it is relevant to our purposes under this Policy.

4. Consequences of Not Providing Us with the Personal Information

If you do not provide some or all of the information requested by us, we may be unable to provide you with a product or service.

5. Purpose of Collecting Personal Data

We may collect Personal Information for the following purposes (the 'Purposes'):

authenticate user's identity;
assist us in assessing and processing an application for credit and managing that credit;
verify a customer's identity and financial situation;
assess the financial need of a customer and the suitability of our credit products;
conduct credit checks and scoring to assess or verify creditworthiness of a customer;
managing credit provided to and collect overdue payments from the customer;
provide customers with our promotional material and manage our relationship with customers;
protect our business and other customers from fraudulent or unlawful activity;
conduct our business and perform other management and administration tasks;
send communicate, such as updates and reminders;
handle concerns or complaints raised by a customer;
bring, defend, or manage any legal action involving us;
collect any debt due or owing to us and enforce our rights;
detect and investigate crime, fraud or illegal activities, and to utilise and disclose the same for investigation, prevention, prosecution and compliance with sanctions, including, regular politically-exposed-persons (PEP) screening purposes;
respond to civil or criminal legal process and/or for regulatory compliance purpose as required by law or regulation;
comply with relevant laws, regulations and other legal obligations, including the National Consumer Credit Protection Act 2009; and
help us improve our products and services and to enhance our overall business.

6. HOW MIGHT WE USE PERSONAL INFORMATION

We use personal information for the purposes:

Primary purpose for which Personal Information is collected is for providing our customers with credit and managing that credit.
Secondary purpose for which Personal Information is collected is related to this primary purpose, such as keeping customers informed about changes to their loan, or new products and services.
Other purposes authorised by the Privacy Act may also apply.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless a customer agrees otherwise, or if certain other limited circumstances apply (e.g. where required by law).

7. TO WHOM MIGHT WE DISCLOSE PERSONAL INFORMATION

Customer's Personal Information held by us shall be kept confidential at all times. In order to provide you with effective and continuous products and services for the Purposes, we may need to disclose a customer's Personal Information to the following party(ies) in or:

holding companies, subsidiaries, affiliates and associates of us;
prospective funders or other intermediaries in relation to a customer's finance requirements;
organisations that are involved in managing or administering a customer's finance, such as third-party suppliers, printing and postal services, call centres, credit providers, mortgage insurers and trade insurers.
agents, contractors or service providers we engage to carry out functions and activities in connection with approving or administering credit products or services, such as our electronic verification service, lawyers, accountants, debt collectors or other advisors;
associated businesses that may want to market products to a customer;
companies that provide information and infrastructure systems to us;
any person who represents a customer, such as finance brokers, lawyers, mortgage brokers, guardians, persons holding power of attorney and accountants;
borrowers (if more than one) or prospective borrowers including in relation to any credit an individual guarantee' or proposes to guarantee.
organisations involved in a transfer or sale of all or part of our assets or business;
organisations involved in managing our payments, payment merchants and other financial institutions such as banks
investors, agents or advisers, trustees, rating agencies or any entity that has an interest in a customer's finance or our business;
our auditors, insurers, re-insurers and health care providers
where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), government and law enforcement agencies or regulators;
a CRB;
any person connected to the enforcement or preservation of any of our rights;
regulatory bodies, government agencies, law enforcement bodies and courts or tribunal, including foreign counterparts;
a customer's financial institution/s, referee/s, employer, co-account holder or authorised signatory; and
anyone else to whom the customer authorises us to disclose it.

Prior to disclosing a customer's Personal Information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

the person or organisation has a commitment to protecting a customer's personal information at least equal to our commitment; or
the customer has consented to us making the disclosure

If we intend to provide default information about a customer to a CRB, we will give that customer at least 14 days' written notice of our intention to do so. If we disclose default information to a CRB, and the customer subsequently repay the amount owed, we will tell the CRB that the amount owing has been repaid. We will not disclose to an CRB credit repayment history information that is more than 2 years old or which relates to an amount owing of less than $150.

We will only disclose your personal information to these organisations to enable them to undertake specified management, administration and advisory services or otherwise accordance with the law.

8. CREDIT REPORTING

We may disclose Personal Information (including information about your credit liabilities, repayments and defaults) to Credit Reporting Bodies (CRBs). We may also collect this information from CRBs.

Information about credit reporting, including the contact details of the CRBs we deal with, how we or a CRB may use your information, how to access our policies and your rights in relation to your credit-related personal information, is available at Privacy Consents & Electronic Authorisation .

9. WHY MIGHT WE DISCLOSE CREDIT-RELATED INFORMATION

We will use and disclose a customer's Credit-Related Information only for the following purposes:

assessing an application by the customer for credit and managing that credit;
responding to questions in the course of an investigation by the Australian Financial Complaints Authority (AFCA);
exchange and sell customer data to credit providers;
purposes required or authorised by law.

See 'To Whom Might We Disclose Personal Information' above for further information on the third-parties that we may disclose Credit-Related Information to

10. SENDING INFORMATION OVERSEAS

We may disclose a customer's Personal Information to overseas entities that provide support functions to us.

We will not send Personal Information to recipients outside of Australia unless:

we have taken reasonable steps to ensure the recipient does not breach the Privacy Act, the APPs and the Privacy (Credit Reporting) Code;
the recipient is subject to an information privacy protection regime similar to that required by the Privacy Act; and
the customer has consented to the disclosure.

We may also use cloud storage to store customers' personal information. The cloud storage and the IT servers may be located outside Australia. The countries in which the cloud storage and IT servers are likely to be located include India, Nepal, Pakistan, the Philippines and Singapore.

A customer may obtain more information about these overseas entities by contacting us.

11. MANAGEMENT OF PERSONAL INFORMATION AND CREDIT-RELATED INFORMATION

The APPs require us to take all reasonable steps to protect the security of Personal Information, including Credit-Related Information. Our employees respect the confidentiality of the Personal Information we collect.

We will take a range of measures and reasonable steps to protect customers' Personal Information.

Customers' Personal Information will always be stored in a secure environment. We may store customers' Personal Information in paper and electronic form. We will also take reasonable steps to protect any Personal Information from misuse, loss and unauthorised access, modification or disclosure.

12. NOTIFIABLE MATTERS

The law requires us to advise customers of 'notifiable matters' in relation to how we may use Credit-Related Information. A customer may request to have these notifiable matters (and this policy) provided in an alternative form.

We exchange customers' Credit-Related Information with CRBs. We use the Credit-Related Information that we exchange with CRBs to confirm a customer's identity, assess creditworthiness, assess an application for finance, and manage that finance.

The information we may exchange with CRBs includes identification details, what type of loans a customer may have, how much that customer has borrowed, whether or not a customer has met their loan payment obligations, whether a customer has entered into a financial hardship arrangement (either with us or some other third-party), and if a customer has committed a serious credit infringement (such as fraud).

If a customer fails to meet its payment obligations in relation to any finance that we have provided or arranged, or if they have committed a serious credit infringement, we may disclose this information to a CRB.

A customer has the right to request access to the credit-related information that we hold about them and make a request for us to correct that credit-related information if needed. See 'Access to Personal Information' below for further information.

Sometimes Credit-Related Information will be used by CRBs for the purposes of 'pre-screening' credit offers on the request of other credit providers. A customer can contact the time to request that their Credit-Related Information is not used in this way.

A customer may contact the CRBs to advise them that they believe that they may have been a victim of fraud. CRBs must not use or disclose that Credit-Related Information for a period of 21 days after a customer notifies them that they may have been a victim of fraud. A customer can contact any of the following CRBs for more information:

Equifax Pty Limited - www.equifax.com.au - contact on 13 83 32; see privacy policy at https://www.equifax.com.au/privacy ;
Illion (Australia) Pty Limited - www.illion.com.au - contact on 13 23 33; see privacy policy at https://www.illion.com.au/privacy-policy ; and
Experian Australia Credit Services Pty Limited - www.experian.com.au - contact on 1300 783 684; see privacy policy at https://www.experian.com.au/privacy-policy-terms-conditions

13. DIRECT MARKETING

We do not use Personal Information for the purposes of direct marketing, unless:

the Personal Information does not include Sensitive Information; and
a customer would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
we provide customers with a simple way of opting out of direct marketing; and
a customer has not requested to opt out from receiving direct marketing from us.

If a customer would not reasonably expect us to use or disclose the information for the purpose of direct marketing, we may use or disclose that information for direct marketing only if the customer grants consent to the use or disclosure of the information for direct marketing or it is impracticable to obtain that consent.

Customers can opt out of direct marketing by contacting us and we will give effect to the request within a reasonable period of time. We will give effect to the request within a reasonable period of time. We will provide customers with the source of its information about them on request, free of charge, within a reasonable period of time.

We will not use or disclose Credit-Related Information for the purposes of direct marketing.

We may use or disclose Sensitive Information about a customer for the purpose of direct marketing only with that customer's consent.

14. IDENTIFIERS

We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. We endeavour to avoid data-matching.

15. HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND CURRENT?

We take reasonable steps to ensure that the Personal Information, including Credit-Related Information, it collects, uses and discloses is relevant, accurate, complete and current.

If any of the personal or credit-related information we hold about a customer is incorrect, inaccurate or out of date, that customer may request that we correct the information by contacting our Privacy Officer.

If we correct information that has previously been disclosed to another entity, we will notify the other entity of the correction within a reasonable period of time of the correction being notified to us. If we are satisfied that Personal Information we hold is inaccurate, we will take reasonable steps to correct the information immediately (if practicable) or within 30 days. We do not charge for correcting Personal Information.

If we refuse to correct Personal Information or Credit-Related Information we will provide the customer with our reasons for not correcting the information.

16. ACCESS TO PERSONAL INFORMATION

We will provide our customer with access to the Personal Information or Credit-Related Information we hold about them. A customer may request access to any of the Personal Information we hold about them at any time by contacting our Privacy Officer.

We will provide access within 30 days of receipt of such request. If we refuse to provide access, we will provide reasons for the refusal.

17. DATA BREACHES

A data breach occurs when Personal Information held by us is lost or subjected to unauthorised access or disclosure. If we suspect or know of a data breach, we will take immediate steps to limit any further access or distribution of the affected Personal Information or the possible compromise of other information.

When we have reasonable grounds to believe that a data breach is likely to result in serious harm, and we cannot mitigate the risk of serious harm with remedial action, we will notify affected customers at likely risk as soon as practicable and make recommendations about the steps they should take in response to the data breach. We will also notify the Office of the Australian Information Commissioner.

Examples of serious harm include, but are not limited to:

identity theft;
significant financial loss; or
threats to physical safety.

Notifications will be made using our usual method of communicating with the affected customer, such as by a telephone call, email, SMS, physical mail, social media post, or in-person conversation. If we are unable to contact a customer (or nominated intermediary) above methods we will publish a statement on the front page of our website and place a public notice on our reception desk.

18. Your Rights

Our Privacy Policy contains information about how:

You may access to Personal Information, including Credit-Related Information, held about you;
You may seek the correction of information about you; and
You may complain about a breach of the Privacy Act, including the APPs and the Credit Reporting Code; and
We will deal with a privacy complaint

19. COMMUNICATION

Customers wishing to raise a matter with us or who would like to discuss any aspects of our Privacy Policy, may contact our Privacy Officer. Our Privacy Officer will investigate the issue and determine the steps we will undertake to resolve the enquiry or complaint. If additional information is required by us, this will be advised. We will notify the determination of our Privacy Officer in writing within 30 days of the determination. We can be contacted by:

telephoning us on: 1800 161 391
writing to: The Privacy Officer at Level 9, 46 Kippax Street, Surry Hills, NSW 2010 Australia
emailing us at: hello@fundo.com.au

Customer who is not satisfied with our response may contact:

Australian Financial Complaints Authority (AFCA) telephone 1800 931 678, www.afca.org.au or PO Box 3, Melbourne, VIC 3001; or
The Office of the Australian Information Commissioner telephone 1300 363 992, emailing enquiries@oaic.gov.au , or
Writing to Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.

20. UPDATES TO THIS POLICY

This Policy will be updated from time to take account of new laws and technology, changes to our operations and the business environment. If the Policy is updated, the updated version shall apply to all of your information held and processed by us henceforth. Your continuous use of our services shall signify your consent to the changes made to this Notice. If you do not consent to the updated terms thereby, you may contact our DPO.

21. ACKNOWLEDGEMENT AND CONSENT

By using our services, you hereby acknowledge that you have read, comprehend and grant consent to us, our affiliates, subsidiaries and third-party service providers to use, process and/or disclose of your Personal Information in accordance with this Policy.

By submitting a loan application, a customer specifically acknowledges that:

they have been advised of this Policy and its contents;
we may elect, at our discretion, to make an enquiry of the customer’s credit history file with a CRB and the customer explicitly grants consent to this enquiry being made.
a failure to grant consent to a credit history file enquiry being made may result in the application not being able to be considered for approval.