1. About this Policy
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This privacy policy (‘the Privacy Policy’) applies to Elevare Pay Easy Pty Ltd ACN 634 728 591 and its affiliates and related companies including Elevare Projects Pty Ltd ACN 653 829 460 and EPE Services Pty Ltd ACN 635 830 732 (‘Elepay’).
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This policy explains how we collect, store and manage your Personal Information that you might give us in the course of applying for credit with Elepay or otherwise accessing our Products and services.
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Elepay is committed to respecting the privacy of your Personal Information and to adhering to the principles set out in Privacy Act 1988 (Cth) and the Australian Privacy Principles ('APPs').
2. Our Products
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In this Privacy Policy we refer to any product or service that we provide as our Product. This includes any service, function, feature or technology offered or operated by Elepay including, but not limited to, those found on any of our platforms including our website, landing pages, mobile applications, QR Code, our portals, customer dashboard, and within our marketing campaigns on our social media pages (including LinkedIn, Instagram and Facebook).
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Our platforms may contain links to third party websites. Elepay is not responsible or liable for the content contained in these linked sites and such sites are not subject to this Privacy Policy.
3. Collecting Personal Information
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As far as practicable, we collect your personal information directly from you or a person acting on your behalf. This may be in person, over the telephone, by email, through our website, or in our ongoing dealings with you. We may also collect personal information about you from publicly available sources, and in some cases, from third parties including:
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(a) a credit reporting body;
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(b) someone authorised by you, such as an agent, broker, referrer, accountant, introducer or guarantor;
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(c) a referee;
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(d) an employer;
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(e) a government body;
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(f) another financial institution;
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(g) an approved gateway service provider of the Document Verification Service; and
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(h) our agents.
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2. We may collect the following types of information, including without limitation:
TYPE OF PERSONAL INFORMATION
EXAMPLES
Basic personal information
Full name, date of birth, residential address and unique identifiers, such as a passport or driver’s licence number.
Contact information
Telephone number, email address and the contact details of any additional contact person provided by you.
Financial information
Assets and expense details, credit or debit card details, bank details and bank and mortgage statements
Credit information
Credit history, default and repayment history, financial hardship information, details of previous applications or agreements with us, court judgments, any matter relating to bankruptcy, insolvency or debt agreement and any other information relating to your credit worthiness including other information obtainable through conducting a credit reporting bureau check.
Employment details
Current employment status, earning capacity and pay slips.
Information collected from Partners or other suppliers
Invoices, details of services, correspondence and verification of identity details.
Sensitive information
Race, socio-demographic details, religion, ethnicity, health, criminal record, or whether you are a member of any political associations, professional or trade associations
Information about your circumstances
Relationship details, family or domestic violence, emergency event, unexpected changes affecting your financial circumstances and health matters.
3. We may obtain information about you through any other means for the purpose of complying with our policies or legal obligations to assess or provide you with credit.
4. The purposes for which we collect, hold, use and disclosure your personal Information
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We collect, hold, use and disclose Personal Information for various purposes, including (without limitation) the following:
PURPOSE
EXAMPLES (NOTE: THIS LIST IS NOT EXHAUSTIVE)
Provision of our Products
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For identify verification and know-your-customer purposes
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To administer or manage your account with us
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To investigate any potential default or fraudulent activities
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For any other matter relating to the provision of our Products
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To verify your occupation or determine whether you are a politically exposed person for compliance with anti-money laundering laws
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To communicate with you regarding the provision of our Products
Credit assessment
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To assess your application, determine your eligibility for our Products and to assess the credit eligibility of other related parties (e.g. guarantors)
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To conduct any identification of verification checks or to verify any other details related to your credit application or enquiry
Operational matters
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To manage all accounts, fees, charges and interests relating to our Products
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To collect, recover or disburse money owing by (or payable to) you.
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To manage or deal with any complaints by you or third parties.
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To investigate any health and safety concerns involving any staff, customer or third parties.
Managing security, risk and fraud prevention
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To prevent, detect and investigate suspicious, malicious illegal or fraudulent activities
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To improve our safety and security measures (e.g. resetting your login credentials)
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To collect, investigate or analyse your credit or transaction history
Collections, recoveries and enforcement action
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To collect any debts and investigate any potential default or fraudulent activities
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​To report any missed payment or default to our credit reporting agencies
Legal requirement
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To comply with our obligations under any applicable law or any requirements from any governmental or regulatory body which bind us
Consent
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For any other purpose to which you have explicitly or implicitly consented to or is incidental to any of the above
Operational matters
including business
development, venture or
purpose
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To enable us to run our business and perform administrative and operational task (such as staff training, risk management, developing of marketing products and services, undertaking planning, research and statistical analysis, credit scoring and system development)
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To conduct any market research or analytical reporting.
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To assist any proposed sale, transfer or merger of Elepay or its assets
5. How we share Personal Information with other parties
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We may share your Personal Information with:
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our affiliates, related companies, employees and contractors;
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our referrers, brokers, suppliers and service providers. This may include financial or property investment companies, investors, insurance providers, brokerage firms, auditors or other financial firms;
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any other supplier, merchant or agent related to your agreement with Elepay;
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our funders, investors and business partners;
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payments systems organisations including merchants, payment organisations and organisations that produce cards, or statements for us
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organisations involved in registering a secured property or which have an interest in the property;
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any financial institution, third party payment providers, superannuation firms or other financial service providers which is necessary for our business operations;
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credit reporting bodies and collection agencies. When we share your Personal Information with a credit reporting body, we authorise them to use that information for the purposes of providing their credit reporting services to us;
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entities that we plan to merge with or be acquired by or who may be looking to invest in us;
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government or regulatory bodies, legal officials, legal representatives and other third parties for law enforcement purposes;
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your nominated referees, contact person and appointed representative; and
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other third parties with your consent or direction to do so (including guardian, security providers);
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any joint owner of real property owned by you, which is nominated as security of our Product provided to you;
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government or regulatory bodies (including the Australian Securities and Investment Commission and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities;
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organisations involved in our normal business practices, including our agents and contractors, as well as our accountants, auditors or lawyers and other external advisers (e.g. consultants and any independent customer advocates);
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organisations that provide online verification of your identity, employment or income;
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Australian Government’s Document Verification Service to compare identification details you provided against online government records and/or your credit information, and/or to verify your identity for the purposes of the anti-money laundering and counter-terrorism financing legislation;
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any third party which we need to verify your information (including sales agency, valuers or mortgage brokers)
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You consent to us disclosing your Personal Information to any person and in such manner as is reasonably necessary to enable us to supply our Products to or for you.
6. Consent
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By providing us with your Personal Information, you explicitly consent to us using, disclosing and managing your Personal Information in accordance with this Policy.
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You may have the option to use a name other than your real name (a pseudonym) when making general inquiries with us. You are not required to provide us with your name or any personal information if you do not wish to. However, to go beyond making general inquiries you will not be able to remain anonymous. Before providing you with any specific information or offering credit we are required to identify you. We are not permitted by law to provide you with credit without obtaining proof of your identity.
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You must tell us when you are using a pseudonym when applying for our Products and services. If we need to identify you, we will tell you whether your real name is required to access those services.
7. Marketing and subscription
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We may use your Personal Information to send marketing information about Elepay’s or our referrer’s existing or new products, services or other offerings from time to time.
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You can opt out of our direct marketing communications via the opt-out link provided in the message or contacting us at suppport@elepay.com.au or 1300 019 417.
8. What about cookies and browsing services?
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Our website and other platforms may utilise cookies or online services which track IP addresses. These are used to enhance your user experience by offering more tailored and efficient online services.
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We may share certain cookies information to third parties for the purposes of verifying your identity and your loan details and to facilitate the provision of our Products to you. We may also disclose such information to third party analytics or online advertising suppliers for advertisement purposes.
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You can disable or block these cookies through the setting function of your browser. However, by disabling or blocking cookies you may interfere with your access to, and the functionality of, some or all parts of our website and the provision of our services to you.
9. Protecting Personal Information
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We take reasonable steps to protect your personal information from misuse, interference, loss, and from unauthorised access, modification, or disclosure in accordance with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles. However, no method of electronic transmission or storage is completely secure, and while we strive to protect your personal information, we cannot guarantee its absolute security. We encourage you to take steps to protect your own information, such as keeping your account credentials confidential and notifying us promptly if you become aware of any unauthorised access or security breach.
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We will retain your Personal Information for as long as it necessary for our business operations or as required by law. When your information so no longer required, we take reasonable steps to destroy and de-identify it.
10. Credit Reporting
1. We may disclose personal information, including credit-related personal information, in relation to your credit dealings with us to credit reporting bodies. You should be aware of the following:
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(a) Credit reporting bodies may include your information in credit reports provided to credit providers to assist them in assessing your creditworthiness;
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(b) If you fail to meet your repayment obligations or commit a serious credit infringement, we may disclose this information to credit reporting bodies, as permitted by law;
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(c) You can access our Credit Reporting Policy, which outlines how we manage credit-related personal information. This policy is available on our website or upon request. It includes details about how you can access and correct credit-related information we hold about you; how to lodge a complaint if you believe we have breached our legal obligations and how we will address such complaints;
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(d) You can obtain a copy of the credit reporting bodies’ policies about the management of credit-related personal information by contacting them directly;
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(e) You have the right to request that credit reporting bodies do not use your credit information for pre-screening purposes related to direct marketing by credit providers;
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(f) If you believe you have been, or are likely to become, a victim of fraud, you can request that credit reporting bodies do not use or disclose your credit information; and
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(g) If you apply to us for consumer credit (including a new credit account or to increase the limit on an existing credit account), we can do a credit check without asking for your consent, provided we have notified you or otherwise made you aware of this. A credit check is when we ask a credit reporting body for information about the loans you have applied for and taken out in the past, and how you have managed those loans. The credit reporting body will record the fact that we have done a credit check. This will show on your credit report as a ‘credit enquiry’ (also known as an ‘information request’). The enquiry may be disclosed to other credit providers and used and disclosed by the credit reporting body or a credit provider, including in the calculation of a credit score. When a credit enquiry is recorded on your credit report, it can affect your credit score in different ways. It might go up, down, or stay the same. This depends on factors like the type of credit you’re applying for, how many other credit checks you’ve had recently, and other details in your report. An enquiry is more likely to lower your credit score if you make a lot of credit applications in a short time.
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2. The credit reporting bodies to which we may disclose your credit information are:
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Equifax Pty Ltd,
P.O. Box 964,
North Sydney, NSW 2059.
Experian Australia
PO Box 7405, St Kilda Rd
Melbourne VIC 3004
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3. If, for any of the above purposes, we disclose your personal information to any supplier of services to our business or to any prospective purchaser of our business, which we shall do so only if it is necessary for the purposes listed above, we shall do so in accordance with Australian privacy law; and seek assurances from those suppliers that they comply with the Australian privacy laws.
11. Your rights
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Subject to any agreements you may have with us and any applicable law, you have certain rights to your Personal Information that we hold. These include:
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you may access your Personal Information (including your credit information) free of charge. We will endeavour to deliver information requested by you within a reasonable time and should we refuse to supply the information requested, we will notify you of the reason for our decision. In some cases, we may refuse to give you access to certain information (for example, if it affects the privacy of another person);
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it is important that you update or correct your Personal Information from time to time by contacting us or through your Elepay customer portal; and
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you may instruct us to stop using your Personal Information for direct marketing purposes.
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We will use best endeavours to comply with any requests you have regarding storage of your Personal Information. However, you acknowledge and accept that we may be required by law to keep your Personal Information kept on record for a minimum period of time.
12. Whether we supply your personal information or credit information to oversees recipients
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We may store your personal information, (including credit information and credit eligibility information) in the cloud or other types of networked or electronic systems. Currently, these are all located in Australia.
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We may also send your personal information (including credit information and credit eligibly information) to The Philippines and to South Africa, where we have outsourced functions or activity to a service provider in those countries.
13. Changes to this Privacy Policy
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We may update our Privacy Policy from time to time. Any change made to our Privacy Policy will be effective once published on our website. We may notify you via email or mail of any change to our Privacy Policy which we believe may materially affect you.
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If you wish for us to notify you regarding updates to our Privacy Policy, then please contact us directly to discuss.
14. Queries or Complaints
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f you wish to access your personal information or if you have any concerns or queries regarding your Personal Information or this Privacy Policy, please contact us directly as follows:
Elevare Pay Easy Pty Ltd
​Email: legal@elepay.com.au
Phone: 1300 019 417
2. We aim to acknowledge receipt of all correspondence from you within 3 Business Days and to resolve all matters within 14 Business Days.
3. If you are a customer of Elevare Pay Easy Pty Ltd and not satisfied with the way we handle your query or have any complaints regarding our products or procedures, you may contact the Australia Financial Complaints Authority (our member number 96789):
Australia Financial Complaints Authority
Telephone: 1300 931 678
Email: info@afca.org.au
Website: www.afca.org.au
Mail: GPO Box 3, Melbourne VIC 3001