Green Light Auto Group Pty Limited - Credit Reporting Policy

This Credit Reporting Policy applies to Green Light Auto Group Pty Limited ACN 131 507 474 and its related bodies corporate, and any entity trading under the Green Light brand in Australia (collectively and individually referred to as 'us', 'we', 'our', and 'Green Light'). It is designed to be read with our Privacy Policy and our Statement of Notifiable Matters.

Green Light is bound by Part IIIA of the Privacy Act 1988 (Cth) (Privacy Act) and the Privacy (Credit Reporting) Code (CR Code), which govern credit reporting information in Australia.

About this Credit Reporting Policy

Our Credit Reporting Policy explains how we manage:

• credit information - this information relates primarily to your credit-related dealings with us and we can disclose this information to credit reporting bodies (CRBs); and
• credit eligibility information - this information relates primarily to your credit-related dealings with other credit providers. Credit eligibility information includes:
  • credit reporting information provided by CRBs; and
  • credit worthiness information that we derive using credit reporting information

Definitions of 'credit information' and 'credit eligibility information' are provided in the Privacy Act 1988 (Cth) (Privacy Act) and the Credit Reporting Privacy Code (CR Code), which are available on the website of the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au. Credit information and credit eligibility information is collectively referred to throughout this policy as 'credit related information'.

This Credit Reporting Policy explains:

• the kinds of credit information that we collect and hold, and how we collect this information;
• how we hold credit related information;
• the purposes for which we collect, hold, use and disclose credit related information;
• the circumstances in which we may disclose credit related information, including to overseas recipients and the countries where such recipients may be located;
• how you may request access to, and correction of your credit related information held by us;
• how to make a complaint if you believe that we have not complied with Part IIIA, Division 3 of the Privacy Act or with the Credit Reporting Privacy Code, and how we will deal with such complaints.
• how to make a complaint if you believe that we have not complied with Part IIIA, Division 3 of the Privacy Act or with the Credit Reporting Privacy Code, and how we will deal with such complaints.

This Credit Reporting Policy applies to credit related information about individuals, and does not apply to commercial credit information. For information about how we manage other personal information about you, please see our Privacy Policy.

1. Credit related information that we collect and hold, and how we collect it

   When you apply for credit with us, throughout our relationship, and for as long as we are required under the law, we may collect and hold your credit related information. Examples of which include:

   • identification information, such as your name, address, date of birth or employer;
   • consumer credit liability information about you, such as the type of consumer credit, the loan date, the amount of credit applied for, the maximum credit limit approved, and similar;
   • your repayment history information;
   • a statement that we have made an information request about you with a CRB;
   • default information, relating to an outstanding payment over $150 which has been outstanding for over 60 days and we have issued prerequisite notice(s) to pay;
   • payment information when you have made a payment towards a default which was reported to a CRB;
   • new arrangement information if you vary the terms of your credit following a default disclosure;
   • court proceedings information, regarding a judgment of an Australian court that is made against you that relates to credit that was provided to, or applied for, by you;
   • personal insolvency information about you, recorded in the National Personal Insolvency Index, and that relates to either your bankruptcy, a debt agreement proposal given by you, a debt agreement made by you, a personal insolvency agreement executed by you, a direction given, or an order made, under s50 of the Bankruptcy Act that relates to your property or an authority signed under s188 of the Bankruptcy Act that relates to your property;
   • publicly available information about you that relates to your activities in Australia or the external territories and your credit worthiness; and that is not court proceedings information about you or information about you that is entered or recorded in the National Personal Insolvency Index; and
   • an opinion by us that you have committed, in circumstances specified by us, a serious credit infringement in relation to consumer credit provided by us to you.

   We collect credit information in a variety of ways, such as obtaining the relevant information directly from you or by persons acting on your behalf (including on application forms or other forms or in our ongoing dealings with you in connection with credit), collecting information from a CRB to assess your loan, to manage your repayment history and to administer hardship or default situations. Some credit information will also be derived by us from your transactions in connection with credit, such as when you make payments to us.

2. Credit eligibility information that we hold

   We may obtain credit reporting information about you from CRBs. Credit reporting information includes:

   • credit information of the kinds described above but relating primarily to your dealings with other credit providers (such as about credit applications you have made or credit that you hold with other credit providers). This information will typically have been provided by other credit providers or other third parties; and
   • credit worthiness information about you that CRBs derive from the information above, such as credit scores, risk ratings and other evaluations about you.

   We may also disclose your credit information relating to your dealings with us to CRBs. Those CRBs may include that information in reports that they provide to other credit providers to assist them to assess your credit worthiness.

   For example, we will provide information that identifies you and about your application for credit when obtaining credit reporting information for the purposes of assessing that application.

   We disclose credit information to the following CRBs:

   Equifax Pty Ltd., a wholly owned subsidiary of Equifax Inc.
   Website: https://www.equifax.com.au/
   Phone: 1300 850 211
   Mail: PO Box 964, North Sydney NSW 2059, Australia

   illion Australia Pty Ltd (Formerly Dun & Bradstreet (Australia) Pty Ltd)
   Website: https://www.illion.com.au/
   Phone: 1300 734 806
   Postal Address: PO Box 7405, St Kilda Rd VIC 3004, Australia

   Experian Asia Pacific Pty Ltd
   Website: http://www.experian.com.au/contact-us
   Phone: 1300 783 684
   Postal Address: Level 20, 101 Miller Street,
   North Sydney, NSW 2060

   These CRBs are each required to have a policy which explains how they will manage your credit-related personal information. If you would like to read the policies of these CRBs please click the website links provided above.

   You have the right to request (without cost) that these CRBs to exclude your credit reporting information from any permissible direct marketing activities that a credit provider may request them to perform.

   You also have the right to request CRBs not to use or disclose your credit reporting information if you believe that you have been, or are likely to be, the victim of fraud (for example, you suspect someone is using your identity details to apply for credit). You must contact the CRBs directly should this be the case.

3. The kinds of information we derive from credit reporting information disclosed to us by a Credit Reporting Body

   We may use credit reporting information that we have obtained from a CRB to derive other information that assists us in assessing your creditworthiness, for example, to form a credit risk rating, credit scores, or eligibility to be provided with consumer credit.

4. How we hold credit related information

   We understand the importance of protecting the personal information we hold, including credit information and credit eligibility information. We take reasonable steps to ensure that this information is free from misuse, interference, loss, unauthorised access or modification. Examples of these steps include:

   • securing information both in physical and electronic form;
   • having internal procedures and measures limiting access to personal information only to those that need access for their legitimate activities;
   • protecting our systems using reasonable and appropriate technology solutions which are secured using physical and technology controls; and
   • having internal processes to manage personal and credit information, which may include de-identifying information that we no longer need (subject to data retention laws).

5. The purposes for which we collect, hold, use and disclose credit related information

   We may collect, hold, use and disclose credit related information about you for purposes reasonably necessary for our business activities and consistently with the requirements in the Privacy Act as permitted by law. These purposes include:

   • to assess applications for credit (including assessing any proposed guarantors);
   • for the ongoing servicing and administration of our accounts and products;
   • to assist with the management, including recovery, of outstanding debts;
   • to assist you if we consider that you may be at risk of default;
   • internal management purposes;
   • for data analysis;
   • to participate in the credit reporting system and provide information to CRBs as permitted by the Privacy Act;
   • to undertake securitisation activities and debt assignments;
   • to deal with complaints and legal proceedings;
   • to meet our legal and regulatory requirements (such as reporting matters to regulators or enforcement bodies when authorised or required by law); and
   • to assist other credit providers with such purposes in circumstances permitted by the Privacy Act (such as disclosing information to another credit provider with your consent or where you have committed a serious credit infringement).

   Restrictions apply under the Privacy Act in relation to the circumstances and purposes for which such information may be used or disclosed and we comply with these restrictions. For example, credit eligibility information may not be disclosed to some types of overseas entities and restrictions apply on the use of credit eligibility information for direct marketing.

6. Disclosing credit related information, including to overseas recipients and the countries where such recipients may be located

   We may share your credit related information with related companies, and other organisations to help us provide credit. These other organisations may include, insurers, credit reporting bodies or system operators. We may also use third party service providers.

   One or more of these third parties may be located overseas. Using their services may require us to disclose your credit related information to overseas recipients.

   Whilst it is not practicable to list every country in which such recipients are likely to be located, it is likely that the countries to which your credit information or credit eligibility information may be disclosed include: Singapore, Ireland and Hong Kong.

7. How you may access your credit eligibility information held by us

   You may request us to provide you with access to the credit related information which we hold about you by contacting us on the details listed below at 'Contact Us'.

   We will need to verify your identity before giving you access to your credit related information. We will usually provide the information requested within 30 days of receiving your request.

   In certain situations, we may not agree to a request for access of credit related information that we hold about you. If this occurs we will advise you in writing of our decision, and of our reason(s) for not agreeing to the access request.

   There is no charge to make a request for access request.

8. How you may seek to correct your credit related information held by us

   We aim to hold accurate and up-to-date credit related information about you at all times. If you consider that any such information we hold about you is incorrect in any way, you may ask us to correct that information.

   To seek such a correction, please contact us using the details listed below at 'Contact Us'.

   If we do not agree to a request to correct information we hold about you, we will advise you in writing of our decision, and of our reason(s) for not agreeing to the correction request.

9. How to make a complaint if you believe that we have not complied with Part IIIA, Division 3 of the Privacy Act or the CR code, and how we will deal with complaints

   If you believe that we have failed to comply with the credit reporting requirements in Division 3, Part IIIA of the Privacy Act or the Credit Reporting Privacy Code, please contact our Internal Dispute Resolution (IDR) team by phone on (08) 9413 0093, by email at complaints@greenlightauto.finance, or by mail at PO Box Z5263, St George’s Terrace, Perth WA 6831.

   We will aim to investigate and resolve your complaint as quickly as possible, and will provide you with a confirmation of receipt within 3 days, and a written response within 21 days. Sometimes we may ask for further information to assist us with the investigation. If we are unable to resolve the complaint within the 21 days from the initial complaint, we will:

   • inform you of the reasons for the delay
   • specify a date when a decision can be reasonably expected; and
   • notify you of your right to contact the Australian Financial Complaints Authority.

   All complaints will be processed at no charge to you.

   If you are unhappy with our IDR response, you may contact our external dispute resolution scheme, the Australian Financial Complaints Authority (AFCA). AFCA is a free service, and may be contacted by phone on 1800 931 678, email at info@afca.org.au, or by post at GPO Box 3, Melbourne, Victoria 3001.

   You may also refer the matter to the OAIC at:

   Website: www.oaic.gov.au
   Phone: 1300 363 992
   Mail: The Office of the Australian Information Commissioner, GPO Box 2999, Canberra ACT 2601 Australia

10. Contact Us

    If you would like a free copy of this Credit Reporting Policy, have questions, or would like to make a request, our contact details follow.

    Email: compliance@greenlightauto.finance
    Phone: 1300 081 488
    Mail: PO Box Z5263, St George’s Terrace, Perth WA 6831

    This Credit Reporting Policy was last updated on 09/07/2019 and is subject to change. Please check our website for the latest version.