LUTUM recognises the importance of the privacy of individuals who have dealings with LUTUM, such as customers, suppliers and employees. LUTUM is bound by the Australian Privacy Principles, to the extent required by the Privacy Act 1988. This policy outlines how LUTUM and its subsidiaries collect, use and manage personal information.
1.1 Personal information LUTUM collects
LUTUM collects personal information where reasonably necessary for its functions and activities. Personal information that LUTUM may hold includes the following:
• name, address and contact details;
• date of birth;
• employment and income details;
• bank account details;
• details of the products and services provided to an individual by LUTUM;
• details of an individual’s dealings with LUTUM, including records of telephone, email and online interactions;
• credit-related personal information (see section 1.5 below).
1.2 How LUTUM collects personal information
LUTUM collects personal information directly from an individual where reasonable and practical. LUTUM may also collect such information from other sources, including:
• other entities who provide services to LUTUM related to the products and services provided to an individual by LUTUM;
• publicly available sources of information;
• an individual’s representatives (e.g. spouse, professional adviser);
• subsidiaries of LUTUM Limited.
1.3 How LUTUM uses personal information and to whom it is disclosed
LUTUM collects, uses and discloses personal information generally to provide an individual with products and services requested, and to respond to queries. LUTUM may also use personal information to make an individual aware of LUTUM’s other products and services or offerings provided by LUTUM in conjunction with its business partners or associates. LUTUM may not be able to do these things without the individual’s personal information. LUTUM may also collect, use and disclose personal information in connection with potential or actual unlawful activity, misconduct or transfers of LUTUM’s business or assets. LUTUM understands the importance of keeping personal information private and only discloses such information to third parties in limited circumstances. Third parties with whom LUTUM usually exchanges information include:
• credit providers and credit reporting agencies;
• an individual’s representatives;
• LUTUM’s professional advisers including legal, accounting, auditing and business consulting advisers;
• government and regulatory authorities;
• subsidiaries of LUTUM Limited.
LUTUM also exchanges personal information with contractors who manage services provided to an individual on LUTUM’s behalf, or who provide services to LUTUM, including:
• mailing services;
• billing and debt-recovery functions;
• customer injury services;
• marketing functions;
• website, data management and technology services.
Parties to which LUTUM discloses personal information may be located in Australia and other countries. As outlined below, web traffic information is disclosed to Google Analytics when you visit our websites and Google stores information across multiple countries.
1.4 Website usage information and cookies
Through the use of a ‘cookie’, LUTUM can record information about your visit to our website including the clickstream to, through and from our site (including date and time), the pages visited, page interaction information and methods used to browse away from the page. This information is used anonymously and in aggregate and is collected and logged for statistical purposes. Through analysis of these records, LUTUM is able to provide an improved service when users revisit our websites.
A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and your preferences. The only personal information a cookie can contain is information you personally supply. A cookie cannot read data from your hard disk or read cookie files created by other websites.
1.5 Credit-related personal information
LUTUM sometimes provides products and services to customers on credit. In connection with this credit, LUTUM does in some cases handle certain consumer credit-related personal information described below (credit-related personal information), including information from credit reporting bodies (CRBs). For example, LUTUM may handle this information in providing credit to sole traders, or where individuals such as directors provide personal guarantees for credit LUTUM provides to their companies.
LUTUM may collect and hold any types of credit-related personal information about an individual permitted under the Privacy Act, including:
• name, sex, date of birth, driver’s licence number, employer and three most recent addresses;
• confirmation of previous information requests to CRBs made by other credit providers and credit insurers about the individual;
• details of previous credit applications, including the amount and type of credit and credit limit;
• details of current and previous credit arrangements, including credit providers, start/end dates and certain terms and conditions;
• permitted payment default information, including information about related payment arrangements and subsequent repayment;
• information about serious credit infringements (e.g. fraud);
• information about adverse court judgments and insolvency;
• publicly available information about the individual’s creditworthiness;
• any credit score or credit risk assessment indicating a CRB’s or credit provider's analysis of the individual’s eligibility for consumer credit.
This information may include information about an individual’s arrangements with other credit providers as well as with LUTUM.
LUTUM may disclose credit-related personal information to CRBs to assist the CRBs to maintain information about individuals to provide to other credit providers for credit assessments. LUTUM may collect credit-related personal information from CRBs for purposes including, to the extent permitted by law, to assess relevant credit or guarantee applications, manage and review the credit or guarantee, assign debts, collect overdue payments and produce assessments and ratings in respect of the individual’s creditworthiness. LUTUM may also exchange credit-related personal information with guarantors, debt buyers and other credit providers.
The CRBs LUTUM may use include:
• Veda, PO Box 964 North Sydney 2059, www.mycreditfile.com.au, 1300 762 207;
Under the Privacy Act, individuals may request CRBs not to:
• use their credit-related personal information to determine their eligibility to receive direct marketing from credit providers; and
• use or disclose their credit information, if they have been or are likely to be a victim of fraud.
1.6 How LUTUM stores personal information
LUTUM stores personal information at its own premises and with the assistance of its service providers. LUTUM maintains strict procedures and standards and takes a range of steps to prevent unauthorised access to, or disclosure of, personal information and protect an individual’s information from misuse or loss. Once an individual’s information is no longer needed by LUTUM, reasonable steps are taken to destroy or de-identify it.
1.7 Accessing and updating personal information
In most cases, an individual can gain access to or update personal information held by LUTUM. To make a request to access or update personal information held by LUTUM, contact LUTUM in writing. LUTUM may need to verify your identity. LUTUM may charge a fee to cover the cost of retrieving and copying requested information.
2.0 Updates to this Policy