Privacy Policy

This Privacy Policy applies to Direct Appliance Rentals Pty Ltd ACN 098 305 714 Australian Credit Licence 405 632 of 250 Bay Street Brighton Vic 3186 P.O Box 6223 St Kilda Rd Central Vic 8008 (DAR, we, our or us).

The Policy extends to and covers all operations and functions of Direct Appliance Rentals.
This Privacy Policy applies to DAR and any of its authorised representative and franchisees who operate a DAR business under DAR Australian Credit License.

DAR is bound by the Privacy Act 1988 (Cth) as amended and the Australian Privacy Principles forming part of the Privacy Act (‘Privacy Act’).

1. Who we are and what this privacy policy is about.

DAR and its authorised representatives and franchisees specialise in leasing household products to consumers. In the process of providing you with leasing services, we may collect, receive, deal with and store your Credit related information and Credit Eligibility Information.

2. What information does this privacy policy apply to?

This policy only applies to:
(a) Personal Information;
(b) Credit Eligible Information; and
(c) Credit Information.
These items are defined in the in the Privacy Act.

Generally speaking, Personal Information is information (or opinion), in any form, about an individual (not a business, company or trust) whose identity is apparent or can be ascertained from the information held whether the information is true or not. In general terms, Personal Information is any information which can identify you. For example, your account number on its own is not credit related information, however your name and surname is considered credit related information.

Credit Eligibility Information means information we collect from a credit reporting entity or information that is about the individual’s consumer and or commercial credit worthiness.

Credit Information

This means information that includes (but not limited to) the following.

• Information about an individual, like their name and address that we may use to identify that individual.
• Information about an individual’s current or terminated consumer credit accounts and from the 12th March 2014, an individual’s repayment history.
• The type and amount of credit applied for in any previous consumer or commercial credit applications to any credit provider, where that credit provider has requested information.
• Information about an individual from a credit reporting body.
• Information about consumer and or commercial credit payments overdue for at least 60 days and for which collection action has started.
• Advice that payments that were previously notified to a credit reporting body as overdue or no longer overdue.
• Getting information about new credit arrangements an individual may have made with a credit provider, in relation to consumer credit currently or previously held, to deal with any defaults or serious credit infringements by that individual.
• Having information about the individual’s consumer and or commercial credit worthiness.
• Information about court judgements which relate to judgements which relate to credit that an individual has obtained or applied for.
• Receiving information about an individual on the national Personal Insolvency Index.
• Publicly available information about an individual’s credit worthiness, and an opinion of a credit provider that an individual has committed a serious credit infringement of credit provided by that credit provider.

Personal Information

This means information that includes (but not limited to) the following

• Your name, current address details, previous address details
• Date of birth and gender
• Government identifiers
• Email address and telephone/mobile numbers
• Personal reference details; name, address and contact number
• Current and previous place of employment
• Previous address details
• If there is another applicant named in an application, you may need to provide their personal information, and you warrant that the other applicant has consented to the collection of their personal information for the reasons it is being collected.

Credit Related Information

For the purpose of this policy Credit Related Information includes, as relevant, any information we collect, store, use or disclose including Personal Information, Credit Eligibility Information, and Credit Information. Therefore for ease of reference, we will use the term credit related information as a broad term throughout this policy.

By making an application to DAR to be considered for consumer leasing and or by signing the lease agreement with us, you agree to the collection, use, and disclosure of credit related information as set out in this Privacy Policy. You do not have to disclose Credit related information to us. If you do not agree or do not provide some or all of the information requested, we may not be able to process or accept your application.

3. How we collect credit related information

Our ability to provide individuals with our services is dependent on us obtaining certain credit related information about the individual. Typically, the type of credit related information we collect about the individual includes name, age, date of birth, occupation, mailing address, phone numbers, email address and other information that is relevant to the services we provide.

The credit related information may also include information about the form of identification used in relation to an individual to send or receive a transaction (required by law in some instances), and information about a transaction in relation to an individual, including details of the amounts paid in or out of an individual’s account as well as other instructions.

The credit related information may also include:

1.1 employment details, employment history, family commitments and social security eligibility;
1.2 details of the individual’s needs and objectives;
1.3 details of the individual’s current financial circumstances including income and expenditure;
1.4 Bank account or Income details
1.5 details of the individual’s creditworthiness, defaults and other credit related information from the individual’s credit file.

We generally collect credit related information from the individual directly through the application form, from information disclosed to us by sending us correspondence, from information disclosed to us by an individual via our website and from a variety of third-party sources, including credit checking agencies, financial institutions, and credit bureaus.

We must not collect sensitive information as defined in the Privacy Act unless it is required by law and it is necessary for the provision of the services we provide you.

4. Why do we collect credit related information?

We collect credit related information for the primary purpose to:

• conduct our business of providing consumer leasing to our clients;
• assess applications of prospective customers to provide them with our services;
• comply with our legal obligations;
• follow our customer’s instructions; and
• help us manage and enhance our services.

5. How might we use and disclose credit related information?

When we refer to “use” of credit related information, we mean use within our organisation for the purposes outlined above. When we use the word “disclose” we mean providing the information to persons outside our organisation. We may use and disclose credit related information for the primary purposes for which it is collected, and also for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.

We may use and disclose credit related information for the following purposes to:

• conduct our business of providing consumer leasing to our clients;
• enter into contracts with sub-contractors to conduct our business;
• assess applications by individuals to provide them with our services;
• help us manage and enhance our services;
• communicate with individuals, by providing them from time to time with information contained in newsletters, emails or brochures;
• comply with our legal obligations;
• enable our authorised representatives and or franchisees operating under the DAR Australian Credit License to provide services to our clients; and
• help us manage and enhance our services.

We do not disclose credit related information we collect to others for the purpose of allowing them to direct market their products and services to you.

We may engage other people to perform services for us, which involves that person handling credit related information we hold. In these situations, we prohibit that person from using credit related information about you except for the specific purpose for which we supply it. We are responsible for our agents and subcontractors and their handling of credit related information.

We may also use your personal information to:

• assist in better meeting your needs and preferences
• to inform you of special offers, promotions, and other marketing purposes
• to optimise our marketing services to you
• it may be disclosed to a third party for distribution of our products
• it may be disclosed to a third-party service provider such as database management, marketing, printing/mailing services, and technology providers

We will not transfer your personal information to contractors unless we have taken reasonable steps to ensure that the information which is being transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles.

In relation to credit related information held by us about an individual’s financial history, creditworthiness or bank account details, wherever possible, we will attempt to de-identify the information. We also undertake to delete all credit related information about an individual when it is no longer needed or relevant.

We may disclose credit related information to:

• third parties, including (but not limited to) any entities or organisations handling any product warranty claims;
• a related company;
• consultants we engage to assist individuals;
• consultants we engage to manage our business;
• organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
• our lawyers;
• accountants;
• the compliance consultants;
• regulatory authorities, including the Australian Securities and Investment Commission (ASIC), if required by law;
• authorised representatives of DAR and any franchisees operating under DAR Australian Credit License; and
• anyone else to whom the individual authorises us to disclose it
• Credit reporting Bodies
• Debt collection agencies

We may also collect credit related information from these organisations and individuals, and deal with that information in accordance with this Policy.

6. Sending information overseas

We will not send credit related information to recipients outside of Australia other than to a related company without:

• obtaining the individual’s consent (in some cases this consent will be implied); or
• otherwise complying with the Australian Privacy Principles.

We will not send credit related information to recipients in a foreign country that is not subject to an information privacy scheme similar to the Privacy Act, without the consent of the individual.

7. Management of credit related information

The APPs require us to take all reasonable steps to protect the security of credit related information. DAR and its authorised representatives and licensed franchisees personnel are required to respect the confidentiality of credit related information and the privacy of individuals. We will seek to ensure that individuals’ credit related information is protected from misuse, loss, unauthorised access, modification or disclosure.

We take reasonable steps to protect credit related information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Where we no longer require the credit related information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.

In the event that an individual ceases to be a customer of Direct Appliance Rentals, the individual’s credit related information will be kept for a period of 7 years, after which the information will be destroyed.

8. Identifiers

We will not use government assigned identifiers, such as tax file number or CRN for our own file recording purposes.

9. How do we keep credit related information accurate and up-to-date?

We take reasonable steps to ensure that the credit related information we hold is accurate, complete and up-to-date. We require individuals to contact us in order to update any credit related information we hold about them. You have the right to ask us to correct any information we have about you if the information is inaccurate or erroneous. Our contact details are set out below.

Privacy Officer
Direct Appliance Rentals
PO Box 6223
St Kilda Rd Central
Melbourne VIC 8008

Email: accounts@directrentals.com.au

10. Access to credit related information

Subject to the exceptions set out in the Privacy Act, individuals may gain access to the credit related information, which we hold about them by contacting the DAR Privacy Officer. If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act. We will endeavor to respond to any request for access within 14 -30 days of the request depending on the complexity of the information requested.

We will require identity verification and to specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise the likely cost in advance.

11. Updates to this Policy

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. We will post any amendments to the policy on our website.

12. Responsibilities

It is the responsibility of management to inform employees and other relevant parties that this Privacy Policy is maintained and enforced. Management must ensure that they periodically advise DAR’s employees and other relevant parties of any changes or any new Privacy Policies in a timely manner. It is the responsibility of all employees and other relevant parties to ensure that they understand and adhere to this Privacy Policy. Ignorance of the existence of the Privacy Policy will not be an acceptable excuse for non-compliance.

13. Privacy Training

All new employees must be provided with timely and appropriate access to DAR’s Privacy Policy. All employees must be provided with opportunities to attend appropriate and periodic Privacy awareness training and must ensure that they understand the Privacy related issues that could adversely affect DAR’s position if not properly adhered to.

14. Non-compliance and disciplinary actions

Any Direct Appliance Rentals employee or relevant third party that identifies, knows about, or suspects a Privacy breach must immediately report the matter to the Privacy Officer. Employees or other relevant parties that contravene or do not comply with Direct Appliance Rental’s Privacy Policy may be subject to disciplinary action.

15. Incidents/Complaints Handling

If you have a privacy complaint, please email compliance@directrentals.com.au  with details for them to investigate.

DAR has an effective incidents/complaints handling process in place to manage privacy risks and issues. The incidents/complaints handling process involves:

• identifying (and addressing) any systemic/ongoing compliance problems;
• increasing consumer confidence in DARs’ privacy procedures; and
• helping to build and preserve Direct Appliance Rentals’ reputation and business.

We will make every effort to resolve your complaint internally. If you are dissatisfied with the resolution we offered you, you may file a complaint with DAR external dispute Resolution provider or the Office of the Australian Information Commissioner. Details of our external dispute resolution provider can be found in our credit guide and our website.

The Information Commissioner can be contacted on 1300 363 992 or by email enquiries@oaic.gov.au

16. Contractual arrangements with third parties

We must ensure that all contractual arrangements with third parties adequately address privacy issues.

Each third party is aware of this Privacy Policy and has informed us that they have implemented policies in relation to the management of credit related information in accordance with the Privacy Act, including:

• regulating the collection, use, and disclosure of credit related information;
• de-identifying credit related information wherever possible;
• ensuring that credit related information is kept securely, protected from loss or misuse, with access to it only by authorised employees or agents of the related organisations; and
• ensuring that credit related information is only disclosed to organisations which are approved by Direct Appliance Rentals.
  The third parties specifically agree only to use credit related information for the purposes consented to by Direct Appliance Rentals or by the individual concerned.

17. Website

DAR’s website contains links to other websites whose operator may or may not adhere to a privacy policy or be governed by the Australian Privacy Principles. Direct Appliance Rentals has no control over the privacy practices of sites that are linked to this site via hyperlinks or banner advertising. Please take care at all times to check whose site you are visiting.

DAR automatically receives and records information on our server logs from your browser, including your IP address and the page you request.

If you access our website, we may use Cookies for security and in order to better provide you with services. A “Cookie” is a small text file which is placed on your internet browser. We have access to the Cookie and can derive information in regards to the use of the site. You may change the settings on your browser to reject Cookies, however doing so might prevent you from accessing the secured pages on our website.

We may also use third parties to analyse traffic at our web site. Information collected through such analysis is anonymous. Our website privacy policy can be accessed by clicking on the privacy button on our website which is located at the bottom of the page.

18. Enquiries

If you have any questions about privacy-related issues please contact the Direct Appliance Rentals Privacy Officer:

Privacy Officer
Direct Appliance Rentals
PO Box 6223
St Kilda Rd Central
Melbourne VIC 8008

Email: complaints@directrentals.com.au
Phone: 1300 339 415