Privacy Policy

Movigo Group Privacy Policy

This Privacy Policy sets out how Movigo Group, which includes, but is not limited to the following subsidiaries MOVIGO Pty Ltd, Movigo Shared Services Pty Ltd, Movigo Fleet Pty Ltd, Movigo Property Services Pty Ltd, Growth Factor Debt Pty Ltd, Growth Factor Funding Pty Ltd, , Torque Factor Debtors Pty Ltd R2D Holdings Pty Ltd, R2D Receivables Pty Ltd, Right2Drive Pty Ltd, Right2Drive (New Zealand)Limited, Onyx ANZ Pty Ltd, MyMotum Pty Ltd, Veloce Motum Pty Ltd, RTN Law Pty Ltd, , Total Accident and Mobility Management Services Pty Ltd, TAMMS Asset Finance Pty Ltd, TAMMS Repair Victoria Holdings Pty Ltd, TAMMS Repair Centre Dandenong Pty Ltd, AMRG Mechanical Dandenong Pty Ltd, TAMMS Repair Victoria Holdings No.2 Pty Ltd, TAMMS Repair Centre Sunshine North Pty Ltd, AMRG Mechanical Sunshine Pty Ltd, QLD Repair Holdings Pty Ltd, Brisbane Accident Repair Centre Pty Ltd, AMRG Mechanical Archerfield Pty Ltd, South East Accident Repair Centre (Vic) Pty Ltd, Redwood Services Pty Ltd, AIHC Pty Ltd, Claims Lodging Services Pty Ltd, All Vehicle Towing Pty Ltd aims to protect the privacy of your personal information, your rights in relation to your personal information managed by us and the way in which we collect, hold, use and disclose your personal information.

In handling your personal information, Movigo Group will comply with the Australian Privacy Act 1988, including the 13 Australian Privacy Principles), and/or the New Zealand Privacy Act 1993 (as applicable), and all other relevant laws, regulations and codes relating to privacy and personal information (‘Privacy Law’).
Unless stated otherwise, this Privacy Policy is relevant to the personal information of individuals who are our current or former customers, as well as any other individuals we may deal with (for example, our customers’ guarantors, directors and shareholders or individuals we deal with in other capacities as part of our business).

This Privacy Policy may be updated from time to time. You should review it periodically so that you are aware of any changes.

What kind of personal information do we collect?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.
The kinds of personal information Movigo Group collects and holds varies according to the specific product or service being provided and may include, but is not limited to, your:

1. Contact and identification information, such as your name, address, email address, telephone number, gender and date of birth.
2. Information about your assets, occupation and income, account balances, account activities, payment history and transactions with us or third parties.
3. Government identifiers and related information, such as your driver’s licence, passport and visa particulars obtained, for example, to verify your identity or eligibility at the time you request a product or service.
4. Other details relating to your relationship with us, including if we deal with you in a capacity other than a customer (for example, information about agreements or other arrangements or transactions you may have with us, billing information including your credit card details, your purchasing preferences and history, and any information contained in correspondence between us), and
5. Any other information lawfully obtainable under relevant Privacy Law.

In some circumstances, Movigo Group may collect sensitive information about you, for example in relation to insurance claims. Sensitive information is a type of personal information and includes health information and information about racial or ethnic origin, political opinions, membership of a trade union or political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences and criminal record. We will only collect sensitive information about you where we are permitted to do so by law.

How do we collect your personal information?

Where practicable we aim to collect your personal information directly from you. The circumstances in which we may do so will vary depending on the context in which we are dealing with you (for example, if you are a customer, according to the specific product or service we are providing) but can include, for example, when you are:

• Registering for one of our websites or services or logging in to use one of our websites.
• Submitting applications and other forms through our online services, by email, verbally and/or in hard copy.
• Subscribing to receive alerts/e-brochures and filling in surveys or research, or participating in promotions and competitions we offer.
• Contacting us for any reason including, but not limited to, reporting a problem with one of our services or websites, requesting further services, updating your personal information or otherwise seeking our assistance.
• Posting or contributing material on our websites, and
• Using our services and any credit provided by us in connection with those.

There may be occasions when we collect your personal information from other sources, such as from:

• A public or commercial information services provider (such as providers of government, business or credit information).
• Social media platforms, if you choose to interact with us via your social media account.
• A third party assisting us to process an application or other transaction, confirming information in an application or other request or assisting us to locate or communicate with you.
• Vehicle dealers and other businesses involved in dealings with you and us.
• Your employer, such as where we are providing a novated lease, salary packaging services or fleet services.

Generally, Movigo Group will only collect your personal information from sources other than you if:

• It is unreasonable or impracticable to collect the personal information from you, and
• The collection of that personal information complies with all relevant Privacy Law.

How we use your personal information

We collect, hold, use and disclose your personal information where it is reasonably necessary for the purposes of providing our products and services, for our other business purposes and for any necessary related purposes. These purposes include, but are not limited to:

1. Provision of commercial and consumer vehicle leasing arrangements and factoring and finance arrangements, including accident replacement vehicle services and invoice factoring products.
2. Registering you to use one of our websites.
3. Processing a product application or service or purchase request.
4. Managing our products and services or other relationships and arrangements.
5. Processing receipts, invoices and payments and servicing customer accounts, including determining liability for payment.
6. Responding to customer enquiries about applications, accounts, products or services.
7. Understanding customer needs and offering products and services to meet those needs.
8. Assessing, processing and investigating, credit risk and insurance risks or claims.
9. Accounting, billing and other internal administrative purposes.
10. Identifying and informing customers of products and services that may be of interest.
11. Notifying you about changes to our products and services.
12. Considering, and contacting you about, any application you make for a job with us.
13. Any other legal and regulatory requirements. Various laws may expressly require us to collect your personal information, or we may need to do so in order to be able to comply with other obligations under those laws:
    
    1. In Australia such laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (for example, to comply with identity verification requirements), the Personal Property Securities Act 2009 and State and Territory real property and security interests laws (for example, to register and search for security interests), the National Consumer Credit Protection Act 2009 (for example, to comply with responsible lending requirements), the Financial Sector (Collection of Data) Act 2001, the Corporations Act 2001 and other regulatory legislation (for example, requiring us to maintain client and transaction records, or to make reports and provide other information to regulators such as ASIC) and the Taxation Administration Act 1953, the Income Tax Assessment Act 1997 and other taxation laws (for example, to comply with information requests issued by the Commissioner of Taxation).
    2. In New Zealand such laws include the Anti-Money Laundering and Countering Financing of Terrorism Act 2013 (for example, to comply with identity verification requirements), the Tax Administration Act 1993 (for example, to comply with record keeping requirements) and, to the extent necessary, the Credit Contracts and Consumer Finance Act 2003 (for example, to comply with the Responsible Lending Code).
14. Enforcing our rights, including undertaking debt collection activities and legal proceedings; and
15. Undertaking business funding and development activities.

Where personal information is used and disclosed, we take steps reasonable in the circumstances to ensure the personal information is relevant to the purposes for which it is to be used and disclosed. You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide our services to you or any other relevant customer.

Disclosures of your personal information

We may disclose your personal information for purposes such as those listed above and we will always do so consistently with our privacy obligations.
Third parties to whom we may disclose your personal information include:

1. Our related entities in Australia, New Zealand and overseas.
2. Administrative services providers, such as mailing houses, printers and call centre operators.
3. Legal, settlement, valuation and recruitment service providers.
4. Data processing and market research service providers.
5. Regulatory bodies, law enforcement authorities and toll operators in New Zealand, Australia and overseas.
6. Any person who is considering whether to acquire or who has acquired any part of our business, or the rights or obligations under our contract with you.
7. Financial and other advisors.
8. Other participants in financial and payment systems, such as banks, credit providers, clearing entities and credit card associations.
9. Account information aggregation service providers (including Yodlee), to assist in the transfer of your account data to us in connection with an application for a vehicle leasing arrangement.
10. Insurers, reinsurers, loss adjusters, assessors and underwriters.
11. Brokers and other distributors.
12. Your guarantors and security providers.
13. Debt collectors and investigators, and
14. In connection with an application for a vehicle leasing arrangement, credit reporting bodies and other information providers.

Credit reporting

When you apply for, or we provide, a Movigo Group product or service, we may access credit-related personal information about you through the credit reporting system.
We comply with all Privacy Law that applies to the collection, use and disclosure of credit information, including the Australian Credit Reporting Privacy Code and the New Zealand Credit Reporting Privacy Code 2004 (as applicable) in our handling of your credit-related personal information.
Credit-related personal information is a type of personal information which includes information:

1. About your credit history or creditworthiness.
2. About your past experiences with us and other lenders.
3. About the kinds of credit products you have had or sought.
4. About how you have managed your obligations.
5. Contained in a credit report about you which is obtained by us from a credit reporting body (CRB); and
6. About your creditworthiness that has been derived by us from such a credit report about you.

Credit-related personal information that we may collect and hold includes:

• Your name, address and date of birth, occupation (including the name of your employer or organisation, and any previous employers) and your driver’s licence number.
• Your banking or credit card details and certain financial information about you including a statement of your assets and liabilities.
• The fact that you have applied for consumer credit, or you are a guarantor in respect of that credit application and we have accessed your credit report to assess that application.
• The fact that your organisation has applied for commercial credit, or you are a guarantor in respect of that credit application, and we have accessed your credit report to assess that credit application.
• The fact that we provide goods and services on credit terms to your organisation.
• Certain publicly available information that relates to your activities in Australia and New Zealand, and your creditworthiness.
• Information that, in our opinion, you have committed a serious credit infringement or credit non-compliance action (that is, acted fraudulently or shown an intention not to comply with your credit obligations).
• Insolvency information, including adjudications, discharges, suspensions of discharges and annulments of bankruptcy, and entry into, and termination and discharge from, the no asset procedure.
  assessments, evaluations, scores, ratings, summaries and other information relating to your creditworthiness which is derived by a CRB or us, wholly or partly based on the above; and
• Administrative information relating to credit provided by us.

We collect your credit-related personal information through your dealings with us or from those acting on your behalf. We may also obtain credit-related personal information from CRBs, who may include this information in reports provided to credit providers to assist them to assess your credit worthiness.

We collect, hold, use and disclose your credit-related personal information as reasonably necessary for our business purposes and as permitted by law, including:

1. To assess, complete and process your application for credit that you make or for which you are a guarantor (where we are the credit provider) or to assist in assessing your application for credit that you make or for which you are a guarantor (where we act as agent of the credit provider).
2. To derive assessments, evaluations, scores, ratings, summaries relating to your credit worthiness that we use in our decision-making processes.
3. For account review and management.
4. To participate in the credit reporting system;
   to undertake debt recovery and enforcement activities; or
5. To deal with serious credit infringements.

We may disclose your credit-related personal information to:

1. CRBs, such as Equifax and Dun & Bradstreet.
2. Other credit providers.
3. Our affiliates and related entities in New Zealand, Australia and overseas;
   current or prospective guarantors or security providers.
4. Other CRBs (for example, if you fail to meet your payment obligations or commit a serious credit infringement, we may be entitled to disclose this to a CRB).
5. Your agents, referees, employer, executors, administrators, trustees, guardians or attorneys;
   your and our professional advisers.
6. Other credit providers.
7. Organisations involved in securitisation arrangements or debt assignments; and
8. Administrative service providers, such as providers of credit assessment, management and debt collection services.

We may disclose to Equifax, Dun & Bradstreet, or any other CRB, any failure by you to meet your payment obligations in relation to consumer credit and the fact that you have committed fraud or other serious credit infringement. Equifax and Dun & Bradstreet may include information which we provide in reports to other credit providers to assist them to assess your creditworthiness. These CRBs’ policies about the management of credit-related personal information may be obtained by contacting them on the below details: