Privacy Policy for

FIRST NETRADER PTY LTD (FNT)

How FNT handle your personal information

Your privacy is important to FNT

FNT know that how it collects, uses, exchanges and protects your information is important to you, and FNT values your trust. That’s why protecting your information and being clear about what FNT does with it is a vital part of its relationship with you.

This Privacy Policy is for customers of FNT. It also includes FNT’s policy on the handling of your information including credit related information.

About FNT

FNT provides internet advertisement of your chattels in exchange for your payment.

FNT is bound by the Privacy Act and the Australian Privacy Principles (APPs), upon which this policy is based.

Information FNT collects

Information FNT collects from you

FNT collects information about you and your interactions with us, for example when you request or use our advertisement services, make a payment or transfer money or communicate with us (for example by phone, letter, sms or email).

The information FNT collects from you may include your identity, name, date of birth, address, email address, telephone number or other contact details and other personal details such as gender and marital status, credit or debit card issuer, card number, your bank, BSB, Account number and other financial information.

Information FNT collects from others

FNT may collect information about you from others, such as its service providers, agents, advisers, employers or your bank, credit or debit card issuer, your bank or financial institution, credit reporting agencies, debt collection agencies and or your family members or friends. FNT may collect information about you that is publicly available, for example from public registers or social media, or made available by third parties.

Sensitive information

The Privacy Act also protects your sensitive information, such as health information on hardship applications. If FNT needs to obtain this type of information, FNT will ask for your consent, except where otherwise permitted by law.

If you do not wish FNT to have, collect or use such information then please do not give that information to FNT.

Your delivery of that information to FNT is your ongoing consent for FNT to receive, collect, use and exchange that information.

How does FNT use your information?

FNT collects, uses and may exchange your information with others including third parties so that it can:

• establish your identity and assess your request for FNT to provide you with its advertisement services

• price and design its services to you

• administer its services

• manage its relationship with you

• manage its risks and help identify and investigate illegal activity, such as fraud

• contact you, for example if FNT suspects fraud in connection with the services it is asked to and or does provide to you or FNT needs to tell you something important

• conduct and improve our businesses and improve the customer experience with you

• comply with our legal obligations and assist government and law enforcement agencies or regulators

• identify and tell you about other services that FNT thinks may be of interest to you

• process any agreement between FNT and you including your payment and or speak to you about any arrears.

• Inform others including third parties and credit reporting agencies if you fall into arrears and or do not pay FNT for its services on time.

• Inform others to commence enforcement action against you to recover any unpaid monies from you.

FNT may also collect, use and exchange your information in other ways where permitted by law.

FNT does not currently disclose or store your information overseas but may do so in the future if technology and cloud storage devices require it in which case your provision of your information is your consent to that disclosure.

Direct marketing

If you don’t want to receive direct marketing, you can tell us by using any of the methods set out below.

Anonymity and Pseudonymity

You may in elect to be described using a pseudonym and where possible FNT will endeavour to do so. However FNT will still require from you, will collect, use and exchange your correct information.

Website analytics

To improve your experience on FNT’s website, FNT may use cookies which are an industry standard, common and most major websites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse and or delete a cookie at any time.

FNT’s website may contain links to other websites and or the advertising of third parties. Please be aware that FNT does not control and therefore is not responsible for the privacy policies of other links, sites or advertisers and you should read terms and privacy policies belonging to those sites and parties before disclosing any information.

Our website may use analytic services such as Google analytics which is a service which transmits traffic data to Google servers overseas. Such services do not identify individual users or your IP address. By using our website, you consent to the processing of your information and this data in this way and in the manner described in Google’s Privacy Policy.

How FNT protects your information

FNT uses third parties to host storage of its data and information in Australia in secure facilities.

To help protect the privacy of such data and information FNT requires these hosts to maintain physical, technical and administrative safeguards.

When you transact with FNT on the internet via its website or mobile apps FNT encrypts data sent from your computer to its systems. FNT has third party firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing its systems. When FNT sends your electronic data outside its own network and server FNT uses third party services which are secure and encrypted.

FNT trains its workers about the importance of confidentiality and maintaining the privacy and security of your information and has imposed restraints on any information being used for improper purposes. Access to your information is also restricted to workers who need it to provide services to you or in connection with you as well as the purposes listed in this policy.

Who does FNT exchange your information with?

Third parties

FNT may exchange your information with third parties where this is permitted by law or for any of the purposes mentioned in in this policy and may include:

• service providers reasonably necessary for FNT to provide its service and the advertisement to and for you, for example internet advertising media

• those to whom FNT outsource certain functions, for example, direct marketing, statement production, debt recovery and information technology support

• agents and advisers, family members and persons acting on your behalf, for example guardians and persons holding power of attorney

• guarantors

• persons involved in arrangements that provide funding to us, including persons who may acquire rights to our assets (for example loans), investors, advisers, trustees and rating agencies

• claims-related providers, such as assessors and investigators, who help us with claims

• other financial institutions, for example so that FNT can process a claim for mistaken payment

• your employers or former employers

• your bank or financial institution

• persons or entities concerned with the product advertised by you

• government and law enforcement agencies or regulators

• credit reporting bodies and credit providers

• entities established to help identify illegal activities and prevent fraud.

Under 16s and special needs

If you are under 16 or have special needs, FNT may share your information with your parent or legal guardian or any person appointed to manage your affairs.

Credit checks and credit reporting

If you apply to FNT for credit, FNT may need to know if you’re able to meet repayments under your agreement with us. FNT also want to avoid giving you further credit if this would put you in financial difficulty. One of our checks may involve obtaining a credit report about you.

A credit report contains information about your credit history which helps credit providers assess your credit applications, verify your identity and manage accounts you hold with them. Credit reporting bodies collect and exchange this information with credit providers like FNT and other service providers such as phone companies.

The Privacy Act limits the information that credit providers can disclose about you to credit reporting bodies, as well as the ways in which credit providers can use credit reports.

What information can FNT exchange with credit reporting bodies?

The information FNT can exchange includes your identification details, what type of credit or loan or other facility or arrangement you have, how much you’ve borrowed or the value of that credit, whether or not you’ve met your loan payment obligations and or repaid that credit and if you have committed a serious credit infringement (such as fraud). FNT may also ask the credit reporting body to provide us with an overall assessment score of your creditworthiness.

FNT may use any number of credit reporting bodies including but not limited to Veda Advantage Information Services, Equifax Pty Ltd, Solutions Ltd, Experian Australia Credit Services Pty Ltd and Dun & Bradstreet (Australia) Pty Ltd. You can download a copy of their respective privacy policies from each of these organisations from the internet as it is freely available to you.

What does FNT do with credit-related information?

FNT may use information from credit reporting bodies to confirm your identity, assess applications for credit, manage our relationship with you and collect overdue payments. FNT may also use this information as part of arriving at its own internal assessment of your creditworthiness.

FNT stores credit-related information with your other information. You can access credit-related information FNT holds about you, request FNT to correct the information and make a complaint to us about your credit-related information.

FNT is only obliged to correct information which is proven incorrect and whilst FNT may ask third parties to also correct information proven to be incorrect FNT may have no capacity and therefore makes no guarantee to compel a third party to also make that correction.

Other rights you have

Credit providers may ask credit reporting bodies to use their credit-related information to pre-screen you for direct marketing. You can ask a credit reporting body not to do this. Also, if you’ve been, or have reason to believe that you’re likely to become, a victim of fraud (including identity fraud), you can ask the credit reporting body not to use or disclose the credit-related information it holds about you.

Keeping your hard copy information secure

FNT may keep a paper or hard-copy record of your information at its premises. They are secured and or locked away.

Destroying data when no longer required

Where practical, FNT keeps information only for as long as required (for example, to meet legal requirements or our internal needs).

Accessing, updating and correcting your information

Can I get access to my information?

You can ask for access to your basic information (for example what personal identification information such as name, date of birth, address and telephone number FNT have on record for you) by calling or sending a sms or email to FNT.

For more substantial information you are required to send a detailed written request for access to personal information to FNT by email detailing precisely what information you require and including photographic proof of your identity.

Is there a fee?

There is no fee for making the initial request, but in some cases, there may be an access charge to cover the time FNT spends locating, compiling and explaining the information you ask for. If there is an access charge, FNT will give you an estimate up front and confirm that you’d like us to proceed. Generally, the access charge is based on an hourly rate plus any photocopying costs or other out-of-pocket expenses. You’ll need to make the payment before FNT starts, unless you’ve authorised FNT in writing to debit your credit or debit card.

How long does it take to gain access to my information?

FNT tries to make your information available within 30 days of your request. Before FNT will give you the information, FNT will need to confirm your identity and have received payment of any access charge.

Can you deny or limit my request for access?

In certain circumstances FNT is allowed to deny your request, or limit the access it provides. For example FNT might not provide you access to commercially sensitive information. Whatever the outcome, FNT will write to you explaining its decision.

Updating your basic information

It’s important that FNT has your correct details, such as your current address and telephone number. You can check or update your information by telephoning or writing to FNT by SMS on 0433117718 and or by email using admin@firstnetrader.com.au.

Can I correct my information?

You can ask FNT to correct any inaccurate information it holds or have provided to others (including credit-related information) by contacting FNT. If the information that is corrected is information FNT has provided to others, you can ask FNT to notify them of the correction. FNT does not charge a fee for these requests.

If your request relates to credit-related information provided by others, FNT may need to consult with credit reporting bodies or other credit providers. FNT will try to correct information within 30 days. If FNT can’t complete the request within 30 days, FNT will let you know the reason for the delay and try to agree a timeframe with you to extend the period.

FNT’s ability to correct some information held by third parties may be restricted by the policies and procedures of third parties.

If FNT is able to correct your information, FNT will inform you when the process is complete.

What if FNT disagrees that the information should be corrected?

If FNT disagrees with you that information should be corrected, FNT will let you know in writing our reasons. You can ask FNT to include a statement with the relevant information, indicating your view that the information is inaccurate, misleading, incomplete, irrelevant or out-of-date. FNT will take reasonable steps to comply with such a request.

Making a privacy complaint

FNT is here to help

FNT accepts that sometimes it can get things wrong. If you have a concern about your privacy (including credit-related matters), you have a right to make a complaint and FNT will do everything it can reasonably do to put matters right.

How do I make a complaint?

To lodge a complaint, please telephone FNT on [07] 55646564 or email using admin@firstnetrader.com.au.

Please tell FNT what your concern or complaint is and give us as much detail as possible so that FNT can investigate your concerns. FNT will review your situation and try to resolve it as soon as possible.

How does FNT handle a complaint?

FNT acknowledges that every complaint it receives and provides a name, a reference number and contact details of the investigating officer. FNT will keep you updated on the progress its making towards fixing the problem.

Usually, it takes only a few days to resolve a complaint. However, if FNT is unable to provide a final response within 45 days, FNT will contact you to explain why and discuss a timeframe to resolve the complaint.

Credit-related information complaints

If your complaint is about our practices relating to credit-related information, then FNT may need to consult with other organisations, including credit reporting bodies or credit providers.

FNT will acknowledge receipt of the complaint within 7 days. If FNT cannot resolve the matter within 30 days, FNT will contact you and explain the reason for the delay, the expected timeframe to resolve the complaint and seek your agreement to extend the period.

External review

If you’re not satisfied with FNT’s handling of your matter, you can refer your complaint to external dispute resolution. FNT suggests you do this only once you’ve first followed FNT’s internal complaint processes set out above.

The Credit Ombudsmen Service Limited (COSL) offers an independent dispute resolution service for the Australian credit and finance industries. COSL will consider privacy disputes if they’re about the provision of credit, the collection of a debt, credit reporting or the credit provider-customer relationship, or if the privacy issue is part of a broader dispute with us. Please contact COSL on 1800 138 422, online at www.cosl.com.au or by writing to the Credit Ombudsmen Service, PO Box A52, South Sydney NSW 1235.

If your complaint is about the way FNT handles your personal information, you may also contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, online at www.oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.

For more information about the Australian Privacy Principles and credit reporting rules

You may contact or alternatively visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.