This Policy applies to Lonestar Finance (ABN 84 394465904) (referred to as ‘Lonestar finance’, ‘we’, ‘our’, ‘us’) and extends to and covers all operations and functions of those organisations.
This Policy outlines Lonestar Finance’s obligations to manage and protect personal information. Lonestar Finance is bound by the Australian Privacy Principles ('APPs') and the Privacy Act 1988 ('Privacy Act'). This Policy also outlines Lonestar Finance’s practices, procedures and systems that ensure compliance with the Privacy Act and the APPs.
‘Credit information’ is personal information (other than sensitive information) that relates to an individual’s credit history or credit worthiness, and is further defined in the Privacy Act.
‘Disclosing’ information means providing information to persons outside Lonestar Finance;
‘Individual’ means any persons whose personal information we collect, use or disclose.
‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
‘Privacy Officer’ means the contact person within Lonestar Finance for questions or complaints regarding Lonestar Finance’s handling of personal information;
‘Sensitive information’ is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
‘Use’ of information means use of information within Lonestar Finance.
2. WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We collect and hold the following kinds of personal information about individuals:
bank account details;
drivers’ license details;
statement of assets and liabilities
credit information (if expressly authorised by the individual); and
any other information that is relevant to the services that we provide.
3. HOW WE COLLECT PERSONAL INFORMATION
Lonestar Finance will not collect sensitive information unless the individual has consented or an exemption under the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by an individual, we may not be able to provide the individual with the benefit of our services, or meet their needs appropriately.
Lonestar Finance does not give individuals the option of dealing with them anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for Lonestar Finance to deal with individuals who are not identified.
4. UNSOLICITED PERSONAL INFORMATION
Lonestar Finance may receive unsolicited personal information about individuals. Lonestar Finance’s employees are required to notify the Privacy Officer of all unsolicited personal information received by them. We destroy all unsolicited personal information, unless the personal information is relevant to Lonestar Finance’s purposes for collecting personal information.
5. ABOUT WHOM DO WE COLLECT PERSONAL INFORMATION?
The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:
clients;• potential clients;
service providers or suppliers;
prospective employees, employees and contractors; and
other third parties with whom we come into contact.
6. WEBSITE COLLECTION
We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However for all confidential matters, we’ll ensure we interact with you via a secure form.
7. WHY DOES LONESTAR FINANCE COLLECT AND HOLD PERSONAL INFORMATION?
We may use and disclose the information we collect about an individual for the following purposes:
to assist Lonestar Finance in providing a product or service to an individual, including credit assistance;
completion of documentation and forms;
to consider and assess an individual’s request for a product or service;
to provide an individual with information about a product or service and invite an individual to marketing events;
to provide a financial planner with information to assist in providing wealth management, financial planning, personal risk and stockbroking services;
to protect our business and other customers from fraudulent or unlawful activity;
to conduct our business and perform other management and administration tasks;
to consider any concerns or complaints an individual may have;
to manage any legal actions involving Lonestar Finance;
to comply with relevant laws, regulations and other legal obligations, including the National Consumer Credit Protection Act 2009; and
to help us improve the products and services offered to our customers, and to enhance our overall business.
8. HOW MIGHT WE USE AND DISCLOSE PERSONAL INFORMATION?
Lonestar Finance may use and disclose personal information for the primary purposes for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.
We use and disclose personal information for the purposes outlined in section 7 above. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g. if required by law).
We engage other people to perform services for us, which may involve that person handling personal information we hold. In these situations, we prohibit that person from using personal information about the individual except for the specific purpose for which we supply it. We prohibit that person from using your information for the purposes of direct marketing their products or services.
In relation to sensitive information held by us, wherever possible, Lonestar Finance will attempt to de-identify the information. We also undertake to take reasonable steps to delete all personal information about an individual when it is no longer needed.
9. TO WHOM MIGHT WE DISCLOSE PERSONAL INFORMATION?
We may disclose personal information to:
a related entity of Lonestar Finance;
an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors or other advisors;• organisations involved in a transfer or sale of all or part of our assets or business;
organisations involved in managing payments, including payment merchants and other financial institutions such as banks;
regulatory bodies, government agencies, law enforcement bodies and courts;
financial product issuers and credit providers;
lenders mortgage insurers and title insurers;
industry bodies of which we are a member; and
anyone else to whom the individual authorises us to disclose it or is required by law.
We may also collect personal information from these organisations and individuals, and will deal with that information in accordance with this Policy.
10. SENDING INFORMATION OVERSEAS
We will not send personal information to recipients outside of Australia unless:
we have taken reasonable steps to ensure that the recipient does not breach the Act, the APPs and the Credit Reporting Privacy Code;
the recipient is subject to an information privacy scheme similar to the Privacy Act; or
the individual has consented to the disclosure
We may store your information in cloud or other types of networked or electronic storage. As electronic and networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held.
11. MANAGEMENT OF PERSONAL INFORMATION
Lonestar Finance recognises how important the security of personal information is to clients. We will at all times seek to ensure that the personal information we collect and hold is protected from misuse, interference, loss, unauthorised access, modification or disclosure. Lonestar Finance employees must respect the confidentiality of the personal information we collect.
Personal information is generally held in client files. Information may also be held in a computer database. All paper files are stored in secure areas. Computer-based information is protected through the use of access passwords.
In relation to our computer-based information, we apply the following guidelines:
data ownership is clearly defined within Lonestar Finance;
passwords are routinely checked;
employees’ access capabilities are changed when they are assigned to a new position;
employees have restricted access to certain sections of the system;
the system automatically limits the amount of personal information appearing on any one screen;
unauthorised employees are barred from updating and editing personal information;
all personal computers which contain personal information are secured, physically and electronically;
data is encrypted during transmission over the network;
print reporting of data containing personal information is limited;
Lonestar Finance has created procedures for the disposal of personal information; and
personal information is overwritten to the extent possible when the information is no longer required.
Lonestar Finance performs all employment procedures, including application and termination processes, in a confidential manner. All individual job attributes, such as classification information and salaries, are confidential.
Where we no longer require the personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.
12. DIRECT MARKETING
Lonestar Finance does not use personal information for the purposes of direct marketing, unless:
the personal information does not include sensitive information; and
the individual would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
we provide a simple way of opting out of direct marketing; and
the individual has not requested to opt out of receiving direct marketing from us.
If the individual would not reasonably expect us to use or disclose the information for the purpose of direct marketing, we may only use or disclose that information for direct marketing if the individual has consented to the use or disclosure of the information for direct marketing or it is impracticable to obtain that consent.
In relation to sensitive information, Lonestar Finance may only use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.
Individuals have the right to request to opt out of direct marketing and we must give effect to the request within a reasonable period of time.
Individuals may also request that Lonestar Finance provides them with the source of their information. If such a request is made, Lonestar Finance must notify the individual of the source of the information free of charge within a reasonable period of time.
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. Lonestar Finance endeavors to avoid data-matching, being the comparison of data collected and held for two or more separate purposes in order to identify common features in relation to individuals, as a basis for further investigation or action in relation to those individuals.
14. HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
Lonestar Finance is committed to ensuring that the personal information it collects, uses and discloses is relevant, accurate, complete and up-to-date.
We encourage individuals to contact us to update any personal information we hold about them. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge individuals for correcting the information.
15. YOU HAVE THE ABILITY TO GAIN ACCESS TO YOUR PERSONAL INFORMATION
Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information that we hold about them by contacting the Lonestar Finance Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide access to the information, we will provide reasons for the refusal.An individual’s request for access to his or her personal information will be dealt with by allowing the individual to look at his or her personal information at the offices of Lonestar Finance. We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
16. UPDATES TO THIS POLICY
This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment. All changes to this Policy will be approved by Director/s. We will let you know of any changes to this Policy by posting a notification on our website.
18. PRIVACY TRAINING
19. NON-COMPLIANCE AND DISCIPLINARY ACTIONS
20. INCIDENTS/COMPLAINTS HANDLING
Lonestar Finance has an effective complaints handling process in place to manage privacy risks and issues.
The complaints handling process involves:
identifying (and addressing) any systemic/ongoing compliance problems;
increasing consumer confidence in Lonestar Finance’s privacy procedures; and
helping to build and preserve Lonestar Finance’s reputation and business.
Individuals can make a complaint to Lonestar Finance about the treatment or handling of their personal information by lodging a complaint with the Privacy Officer.
21. CONTRACTUAL ARRANGEMENTS WITH THIRD PARTIES
regulating the collection, use and disclosure of personal and sensitive information;
de-identifying personal and sensitive information wherever possible;
ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
ensuring that the personal and sensitive information is only disclosed to organisations which are approved by Lonestar Finance.
22. PRIVACY AUDITS
Lonestar Finance will conduct periodic privacy audits in order to ensure that it is continuing to comply with its obligations under the APPs.
23. INQUIRIES AND COMPLAINTS
If you have any questions about our privacy procedures, or if wish to make a complaint about how we have dealt with your personal information (including credit information) you may lodge a complaint with us in any of the following ways:
by telephoning – +61425723716
by writing to – Privacy Officer: IndiraPanicker, 11 Coldstream Lane, Gledswood Hills, NSW 2557, Australia.
by emailing – email@example.com
24. WHAT IF I AM NOT SATISFIED WITH THE RESPONSE?
If you are not satisfied with the result of your complaint to Lonestar Finance you can also refer your complaint to the Office of the Australian Information Commissioner.You can contact the Office of the Australian Information Commissioner:
by telephoning - 1300 363 992
by writing to - Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
by emailing - firstname.lastname@example.org