Spark Finance Group Pty Ltd

1. We respect your privacy

1. Spark Finance Group Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.
2. “Personal information” is information we hold which is identifiable as being about you.

2. Collection of personal information

2.1. Spark Finance Group Pty Ltd will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms.

2.2. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information, including but not limited to:

• • personal information (including credit information concerning your credit worthiness or history, consumer information and collection of overdue payments information either within or outside of Australia) from a Credit Reporting Body;
  • personal information about your credit application from any organisation;
  • information about your income, expenses, assets, debts, account balances, or payment history;
  • records of any correspondence between you and us;
  • records of any surveys that we may ask you to complete that we use for research purposes, although you do not have to respond to them;
  • details of transactions you carry out through our website, www.sparkfinance.com.au, and of the fulfilment of your loan repayments;
  • your citizenship or country of residence or similar data;
  • information relating to any criminal proceedings in which you have been involved;
  • personal information from any educational institution or other payee to whom we may need to make current or future payments on your behalf; or
  • if we are unable to contact you and we obtain publicly available personal information about you in order to update our records and your contact details;
  • if there is a need to, contact details of your next of kin;
  • if there is a need to, we may potentially also exchange information with your legal, financial advisers or other representatives and advisors in relation to or in connection with your credit application.

2.3. Additionally, we may also collect any other information you provide while interacting with us.

3. How we collect your personal information

3.1 Spark Finance Group Pty Ltd collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide you may submit an application for credit. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

4. Use of your personal information

4.1. Spark Finance Group Pty Ltd may use personal information collected from you to provide you with information, updates and our services. We may collect and disclose your personal information for purposes including:

• • supplying (including procuring the supply to) you with information about credit or related services;
  • considering whether you are eligible for credit or any related service you requested in your application;
  • processing the credit application and providing you with a credit facility or related service (if we approve your application);
  • administering the credit facility or any related service we have provided you, for example, to answer requests or deal with complaints;
  • managing current, planned or historical payments to an educational institution, or other payee, on your behalf;
  • identifying and verifying your identify (including as part of an application for credit but also subsequently, if we need to);
  • telling you about other products or services we or our related companies make available and that may be of interest to you, unless you tell us not to (this relates to direct marketing);
  • allowing us to run our business efficiently and to perform administrative and operational tasks;
  • improving our products and services and better understand your needs.
  • preventing or investigating any fraud or crime or any suspected fraud or crime;
  • as required by any law, regulation or code binding on us; and
  • any purpose to which you have consented.

You can tell us at any time if you no longer wish to receive direct marketing information or offers from us. We will process your request as soon as reasonably practicable after receipt of your request. Also, we may use personal information about you to:

• • enable an insurer to assess the risk of providing insurance to the us or to address our arrangements with an insurer;
  • consider hardship requests; and
  • assess whether to securitise the credit facility and to arrange securitising the credit facility we provide.

4.2. Spark Finance may communicate with your educational institution to verify your most recent physical address and contact details during the servicing of your loan.

As part of your loan application, you will be asked to agree to the terms of this Privacy Policy and the Personal Data collection, use, and disclosure provisions specific to the Services you receive. In particular, you will be asked to authorise Spark Finance to request Personal Data from your university relating to you for the purpose of originating and servicing your loan.

4.3. Spark Finance Group Pty Ltd may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.

5. Disclosure of your personal information

5.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

5.2. We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

5.3. We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Spark Finance Group Pty Ltd, www.sparkfinance.com.au, its customers or third parties.

5.4. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.

5.5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

5.6. By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

6. Security of your personal information

6.1. Spark Finance Group Pty Ltd is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

6.2. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

7. Your rights with respect to your personal information

7.1. You have the right to:

• • You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at info@sparkfinance.com.au.
  • We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please advise us of any changes by emailing info@sparkfinance.com.au.

• • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal information where we are relying on a legitimate business interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have legitimate business interest to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

8. Complaints about privacy

8.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to Level 1, 11 York Street, Sydney, New South Wales, 2000. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

9. Changes to Privacy Policy

9.1. Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

10. Website

10.1. When you visit our website

When you come to our website (www.sparkfinance.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

10.2. Cookies

We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

10.3. Third party sites

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Spark Finance Group Pty Ltd is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

11. Children

Spark Finance’s products and services are not intended for use by children. We do not knowingly collect personal information from children under the age of 16 years. If we become aware that a child under 16 years of age has provided us with personal information, we take immediate steps to delete such personal information.