TSL Capital Pty Ltd ACN 603 922 434, AFS Licence No 478847 (“TSL”, “we” or “us”) is an “organisation” and “credit provider” for the purposes of the Privacy Act 1988 (“Act”), and is subject to the Australian Privacy Principles and credit reporting provisions detailed in the Act.
This Policy is intended to cover most personal and credit information handled by us, but is not exhaustive. If you have any queries about our management of your personal or credit information, you are encouraged to contact us for further information.
How We Collect, Hold, Use and Disclose Personal Information
We will collect your personal and/or credit information directly from you whenever possible, and will limit the personal and/or credit information we collect to that which is necessary for our functions or activities. We may also collect your personal or credit information from third parties such as credit reporting bodies.
We store your personal and credit information securely, and have policies and procedures intended to ensure that your personal and credit information is not misplaced or misused, and that unauthorised access to, or modification or disclosure of, your personal and credit information does not occur.
Security measures we employ include:
- requiring confidentiality agreements with our employees and contractors;
- having a secure place of business and secure file storage;
- permitting access to personal information only where the individual seeking access has satisfied reasonable identification / authorisation requirements;
- having up to date anti-virus/firewall measures to protect TSL’s computer network; and
- regular monitoring and improvement of our practices and systems to ensure the effectiveness our security policies.
We will endeavour to destroy your personal information as soon as it is no longer required by us (and this is permitted by law).
Use and Disclosure
We collect, hold, use and disclose your personal and credit information to:
- send you information that you request;
- perform market research;
- to correspond with you and send/receive information from you;
- deal with complaints;
- answer queries;
- providing services in relation to investments with TSL;
- to enable you to access and use our website and services;
- to send you marketing and promotional messages and other information that may be of interest to you;
- comply with our legal obligations, including for example, to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006;
- carry out our lending activities;
- assess your eligibility for a loan;
- for any purpose related to the above.
If you do not provide us with the personal or credit information we request, we may not be able to provide you with the services you have requested.
We will generally only use or disclose your personal and/or credit information for the purpose for which we collected it (as set out above), and for related purposes we consider will be within your reasonable expectations. Otherwise, we will seek your consent prior to using or disclosing your personal or credit information for another purpose, unless we are required or permitted by law to do so without seeking your permission.
From time to time, we may provide you with direct marketing material. If at any time, you do not wish to receive this information any further, you may contact us using the details set out below with this request. We will endeavour to meet your request within 2 weeks. We maintain a register for those individuals not wanting direct marketing material.
Access and Correction
You may contact us using the details below to request access to the personal or credit information about you that we hold. We may refuse to allow you to access your personal or credit information if we are legally required or entitled to do so.
If you lodge a request for access, we may provide you with access to your personal or credit information in any of a number of ways (including, for example, supplying you with a copy of your personal or credit information, or providing you with the opportunity to view your personal or credit information).
There are certain conditions under which we may refuse you access to your personal or credit information, such as when your request may unreasonably impact upon another person’s right to privacy. If we refuse to give you access, we will tell you and provide a reason for our decision.
If you establish that any personal or credit information we hold about you is not accurate, complete and up-to-date, we will amend our records accordingly.
Please notify us if your personal details change or if you believe that any information we hold about you is inaccurate. We will take reasonable steps to ensure that your information is corrected upon receiving such a request.
Kinds of Information We Hold
The personal and credit information about you we may collect, hold, use and disclose includes your name and address, contact telephone number(s), bank account details, tax file number(s), mailing addresses and/or email address(es) and any other personal or credit information that you provide to us. We may also collect, use, hold and disclose credit related information such as type and amount of credit sought, publicly available information about an individual’s creditworthiness, default information, repayment history information, payment information in relation to overdue payments and personal insolvency information.
We may undertake a credit check (or similar) through a credit reporting body in relation to a loan application made by you or to assess your eligibility for a loan. In this situation, we may derive information about your eligibility to be provided with a loan from information about you contained in the credit check.
We do not hold any sensitive information about you unless you provide it to us.
Disclosure of Personal Information to Other Organisations
We may disclose your personal or credit information to:
- certain contractors or subcontractors of ours that provide administrative or promotional services to us (for example, mail processing businesses, printers, data storage, sharing and collaboration service providers or market research companies). We enter into contractual agreements with these organisations to ensure that information we disclose is used only for the limited purposes for which we have provided it;
- legal and accounting firms, auditors, consultants and other advisers for the purpose of administering the debenture investments; and
- government authorities when required by law.
We may disclose personal information outside of Australia to data storage, sharing and collaboration service providers (such as Dropbox) located in the United States of America. We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Automatic Server Logs
Our web site server automatically collects various items of information when you use our web site, including:
- your IP (“Internet Protocol”) address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);
- the operating system and Internet browser software you are currently using; and
- the data that you download (such as web pages or other document files or software), and the time that you download it.
Although, in some circumstances, it may be possible to identify you from this information, we do not attempt to do so, and only use this information for statistical analysis, system administration, and similar related purposes. This information is not disclosed to any other party.
Email and Message Forms
We may collect personal information from you (such as your name, address, telephone number and email address, and any other personal information you volunteer) if you send us email or if you submit information to us using a message or feedback form. We will use this personal information to contact you to respond to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations. We will not use or disclose any such information for any other purpose without your consent.
Storage and Transmission of Personal Information Online
If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated to you beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
If we receive your personal information, we will take reasonable steps to store it such that unauthorised access, modification, disclosure, misuse and loss are prevented.
Other Online Services
If you believe that a breach of your privacy has occurred, we encourage you to contact us to discuss your concerns. We will respond to your complaint within 7 days. You can contact our Privacy Officer using the following details:
Telephone: 1300 842 699
Address: TSL Capital Pty Ltd – GPO Box 819, ADELAIDE SA 5001
Fax: 1300 731 347
You may contact us if you require further information about the ways we manage your personal or credit information by telephoning 1300 842 699. Alternatively, you can contact the Office of the Privacy Commissioner www.oaic.gov.au
The following matters apply in relation to any of your personal or credit information we disclose to a credit reporting body for the purposes of undertaking a credit check or disclosing payment default information in relation to commercial credit provided to you:
- We only provide commercial credit and are therefore not subject to any obligations under the Privacy Act that apply only in relation to a credit provider that provides consumer credit.
- In connection with the provision of commercial credit, we may disclose your personal and credit information to credit reporting bodies for the purposes of undertaking a credit check in relation to an application made by you, assessing your eligibility for a loan or disclosing payment default information.
Equifax Australia – www.equifax.com.au or 13 8332
Equifax may include any of your personal or credit information, disclosed to it by us, in reports provided to other credit providers to assist other credit providers to assess your credit worthiness.
You have the right to make a request to Equifax not to use or disclose your credit reporting information for the purposes of pre-screening of direct marketing by a credit provider or if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
Effective: October 2017