Chatham Capital Exchange (ABN 59 507 342 067) (‘we’, ‘us’, ‘our’) are committed to protecting the Personal Information we collect and hold about you.
We will abide by the Australian Privacy Principles for the protection of Personal Information, as set out in the Privacy Act 1988 (Cth) and any other relevant law.
1. What is Personal Information?
1.1 Personal Information is any information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable.
The Personal Information we hold about you may also include Credit Information.
1.2 Credit Information is information which is used as part of the Due Diligence process we complete as part of the on-boarding process and may include any finance that you have outstanding, your repayment history, and any defaults. Usually, Credit Information is exchanged between credit and finance providers and credit reporting bodies.
1.3 We do not collect sensitive information about you such as your religion or health related information. We will ask for your consent before we collect and hold sensitive information about you.
2. What Personal Information do we collect and hold and how it is collected?
2.1 We collect from you (either directly or when you access and use our Services via our Site) Personal Information such as your name, date of birth, address, contact number and email address and any other information we made need to identify you such as your drivers licence number.
2.2 Once you have indicated an interest in discussing an investment opportunity with another Member, you will deal directly with them and they may require you to disclose additional Personal Information.
2.3 You do not need to give us any Personal Information about you or any other person which may be requested in our communications with you. However, without that Personal Information, or if you give us incorrect or inaccurate Personal Information, we may not be able to provide you with our Services.
2.4 We may also collect your Personal Information:
a) from third parties such as Veda Advantage Information Services and Solutions Ltd (Veda), a credit reporting body and our third party service providers; and
b) from publicly available resources.
2.5 Other kinds of Personal Information we may collect and hold about you include your current bank and branch or BSB, occupation, employment history, and employer information.
3. Why we collect your Personal Information
We collect, hold and use your Personal Information for the purposes of:
a) obtaining credit reporting information from Veda;
b) enabling Members to view a de-identified customer profile for the purpose of progressing a potential discussion with another Member;
c) providing our Services to you;
d) dealing with complaints or issues you may have in relation to our Services;
e) reviewing your dealings with us, including the Services you use, your potential needs, and new services that might be of interest to you or other customers;
f) sharing with you updates, including any software updates;
g) ensuring our internal business operations are running smoothly which may include fulfilling legal requirements and conducting confidential systems maintenance and testing;
h) direct marketing – from time to time we may offer you other products and services, but we will not use credit reporting information for this purpose; and
i) other related purposes.
4. When do we disclose your Personal Information?
4.1 We may disclose your Personal Information to:
a) Veda in order for them to generate credit reporting information.
b) Providers: We provide Members with a de-identified customer profile (which may include your credit reporting information and is current as the date it was issued) for the purpose of progressing a discussion relating to an Investment opportunity. If a Member’s offer is accepted by you, that successful Member will be provided with your full Member profile.
c) Third Party Service Providers: We contract with service providers to perform certain functions on our behalf. Examples include database providers who assist in identity verification, credit scoring and credit reporting bodies, IT service providers and payment system operators. Our Third Party Service Providers will only store your Personal Information in Australia.
d) Direct marketers: Chatham will not share your personal information with third parties for the purpose of permitting them to market third party products and services to you.
e) Anyone who represents you or where you have provided us consent.
f) Investors, agents or advisers, or any entity that has an interest in our business.
g) Government agencies or regulatory bodies where required to do so by law.
4.2 Prior to disclosing any of your Personal Information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
a) the person or organisation has a commitment to protecting your Personal Information at least equal to our commitment; or
b) you have consented to us making the disclosure.
4.3 By using our Services you are deemed to have consented to our use, disclosure and other matters in relation to your Personal Information, as set out in this policy and our Terms and Conditions.
5. Other information we collect
5.1 We also collect some statistical information about visitors to our Website and users of our App (for example, the number of visitors and members, pages viewed, types of transactions conducted, time online and documents downloaded). Some of this statistical information is collected by using cookies, but this statistical information does not allow us to identify a visitor.
5.2 We use this statistical information to evaluate our Website and App performance and to improve our loyalty programs and Services.
5.3 We may disclose or sell this statistical information to third parties including advertisers or potential advertisers. Other than statistical information, we do not collect any information about you through our Website or App or unless you voluntarily provide the information to us.
6. Links to third party sites
6.2 These links are provided for your convenience and do not represent our endorsement of any linked third party website. Those website owners are responsible for the privacy of the information they collect and we recommend that you check the privacy policies of these third parties prior to providing them with your Personal Information.
7. Credit Reporting Policy
7.1 We will not obtain any other credit reporting information about you from Veda other than where you have provided your express opinion for Chatham to access your credit report and credit score. We will only hold your credit report and credit score for a period of 30 days. We do not provide any credit reporting information about you to Veda or to the Members.
7.2 We may disclose your credit reporting information to entities that provide support functions to us (see under the heading “4 When do we disclose your Personal Information?)” above.
8. Notifiable matters
8.2 We collect your credit reporting information from credit reporting bodies. Credit reporting bodies include credit reporting information in reports to assist credit providers such as the Providers to assess your credit worthiness and assess your application for finance.
8.3 You have the right to request access to the credit reporting information that we hold about you and make a request for us to correct that credit reporting information if needed. Please see the headings “Updating and correcting your Personal Information” and “access to your Personal Information and credit reporting information” below.
8.4 You may ask a credit reporting body not to use or disclose your credit reporting information for a period if you believe on reasonable grounds that you may have been a victim of fraud.
8.5 The credit reporting body we deal with is Veda – www.veda.com.au. A copy of their privacy and credit reporting policy is available on its website.
9. Security of your Personal Information
9.1 We will take reasonable steps to protect your Personal Information (including credit reporting information) from misuse, loss and unauthorised access, modification or disclosure by storing it in a secure environment.
9.2 Your Personal Information (including credit reporting information) may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store your Personal Information (including credit reporting information) and the IT servers will be located in Australia.
10. Updating and correcting your Personal Information
10.1 We will rely on you to ensure the Personal Information (including credit reporting information) we hold about you is accurate or complete.
10.2 If any of the Personal Information we hold about you is incorrect, inaccurate or out of date you may contact us at email@example.com and request that we correct the information.
10.3 If appropriate we will correct the Personal Information at the time of the request, otherwise, we will provide an initial response to you within 7 days of receiving your request. We will provide you with details about whether we have corrected the Personal Information within 30 days.
10.4 We may need to consult with other credit providers or credit reporting bodies or entities as part of our investigation.
10.5 If we refuse to correct your Personal Information, we will provide you with our reasons for not correcting that information.
11. Access to your Personal Information and credit reporting information
11.1 You may request access to any of the Personal Information (including credit reporting information) we hold about you at any time by contacting us at firstname.lastname@example.org. We may charge a fee for our costs of retrieving and supplying the information to you.
11.2 We usually respond to you within 7 days of receiving your request. We may need to contact other entities to properly investigate your request.
11.3 There may be situations where we are not required to provide you with access to your Personal Information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
11.4 We will provide you with an explanation if we deny you access to the Personal Information we hold about you.
12. Using government identifiers
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
13.1 If you are dissatisfied with how we have dealt with your Personal Information, or you have a complaint, please contact us at email@example.com.
13.2 We will acknowledge your complaint within 7 days. We will provide you with a decision on your complaint within 30 days.
13.3 If you are dissatisfied with our response, you may make a complaint to the Commissioner on either www.oaic.gov.au or 1300 363 992.
14. Change in our privacy and credit reporting policy
14.1 We may change this privacy and credit reporting policy from time to time. You should regularly review this page to familiarise yourself with our updated privacy and credit reporting policy.
14.2 You may request this Privacy and Credit Reporting Policy in an alternative form.