Bravure Group Pty Limited Privacy and Credit Information Policy
We are subject to the requirements of the Privacy Act 1988 (Cth) (Privacy Act). This policy explains how we handle personal information (including credit related information) relating to individuals so as to ensure we meet our obligations under the Privacy Act.
In this policy the expressions “we”, “us” and “our” are a reference to Bravure Group Pty Limited ACN 086 201 194 of Level 7, 10 Bridge Street, Sydney 2000. The expressions “you” and “your” refer to a relevant individual whose personal information we may collect, use or disclose from time to time.
The expression “personal information” is used in this policy to refer to information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. In this policy, the term “personal information” includes credit related information about an individual.
Types of information collected
We only collect personal information to the extent that this is reasonably necessary for the performance or fulfilment of one or more of our functions or activities. Primarily, our functions and activities are related to the provision of administrative and assistance services to support creditors’ recovery of outstanding debts. We also provide administrative and assistance services to debt agreement administrators to assist them in formulating and proposing payment plans to creditors on your behalf.
The personal information that we may collect about you, as an individual, may include the following kinds of information:
- your name;
- your contact details, such as your residential and/or email address;
- your telephone number and other contact details;
- your age or date of birth;
- information provided to us by our clients in relation to amounts owing by you to creditors;
- information provided to us by our clients in relation to amounts paid to them or proposed to be paid by or on behalf of you;
- information we receive from the Australian Financial Security Authority, courts, debt collectors, credit reporting bodies, trustees in bankruptcy or other insolvency administrators or practitioners;
- any additional information about you that is necessary to allow us to perform and deliver our support and administrative services to our clients, and to respond to enquiries.
Method of Collection
Where information is not collected directly from you, for example where it is unreasonable or impracticable for us to do so, information about you will generally be collected from the following sources:
- our relevant client to whom you may owe money;
- our related companies, employees, agents, contractors and advisors;
- our service providers, such as computer systems consultants, trust managers, document custodians, mailing houses and the like;
- the Australian Financial Security Authority, courts, debt collectors, trustees in bankruptcy or other insolvency administrators or practitioners.
Purposes of collection
Purposes for which we may collect personal information include, but are not limited to the following:
- enabling our clients (creditors or debt agreement administrators, where applicable) to use our services and to better allow us to perform those services, which include transactional services relating to the sale of delinquent debt, and administrative services relating to the proposal and management of bankruptcies, insolvencies, and alternatives to bankruptcy;
- operating, protecting, improving and optimising our business and our users’ experience, such as performing analytics, and conducting research;
- sending service, support and administrative messages, reminders, technical notices, updates, security alerts, and requested information to our clients;
- sending relevant notices to you or your debt agreement administrator, trustee, or insolvency practitioner;
- complying with our legal obligations, resolving any disputes that we may have with any person, and to enforce our agreements with third parties.
Use and disclosure
As a general rule, we will not use or disclose personal information for the purposes other than those connected with the primary purpose of collection, or a reasonably related secondary purpose which we believe you should reasonably expect.
Secondary purposes might include disclosure to service providers or other third party contractors (including outsourced and cloud service providers) who may be unable to avoid accessing personal information in the course of providing technical or other support services to our company.
Examples of our disclosures of personal information may include disclosures to:
- our clients (your creditors or debt agreement administrators, where applicable);
- our employees and related bodies corporate;
- third party suppliers and service providers, professional advisers, dealers and agents;
- our existing or potential agents, business partners or partners;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information about you held by us; and/or
- other persons, including government agencies, courts, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
We will not use or disclose personal information for the purposes of direct marketing to you.
Storage of data and overseas disclosure
We will only store and hold personal information in Australia and in a secure manner, for example, on a secure encrypted server located in Australia. We do not share any of your personal information with persons in overseas locations.
In accordance with the Privacy Act, this policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, and an employee record held by us relating to the employee.
If, nevertheless, we transfer employee records offshore for any reason, we will comply with cross-border restrictions set out the Privacy Act which apply to the overseas transfer of personal information.
We will take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. Subject to our legal obligations to retain our business records for particular periods, we will destroy or de-identify personal information once we no longer require it for our business purposes.
Access, correction and further information
We will take such steps as are reasonable to ensure that the personal information which we collect remains accurate, up to date and complete.
We will provide you with access to your personal information held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us via the details at the end of this policy if you:
- wish to have access to the personal information which we hold about you;
- consider that the personal information which we hold about you is not accurate, complete or up to date; or
- require further information on our personal information handling practices.
There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Act, to correct that information if you so request.
We will respond to all requests for access and/or correction within a reasonable time.
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, please contact us in writing using our contact details below. We will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.
If you remain unsatisfied with the way in which we have handled a privacy issue, we suggest you contact the Office of the Australian Information Commissioner for guidance on alternative courses of action which may be available. We will provide our full cooperation in the event that you elect to pursue this course of action.
For further information about our policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
The Privacy Officer
Phone: 02 9252 2811
Mail: PO Box R1578 Royal Exchange, NSW, 1225
If you require further information about Privacy laws generally, please contact:
The Office of the Australian Information Commissioner
Mail: GPO Box 5218, Sydney NSW 1042
Phone: 1300 363 992
This policy was last updated on 1 June 2020 and is subject to change.
From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website. You may obtain a copy of our current policy from our website or by contacting us on the details below. It is your responsibility to check the website from time to time in order to determine whether there have been any changes.