Privacy policy
 

Who are we?

For the purposes of this Privacy Policy the words “Supra”, “we”, “our” and “us” refers to Supra Capital Limited ACN 112 331 361 and our related entities.
 

Our commitment to protect your privacy

We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
 

Personal information

When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.

Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

The kinds of personal information we may collect about you include your name, date of birth, address, email address and other contact details, account details, occupation and any other information we may need to identify you.

We may verify your identity using information held by a Credit Reporting Body (CRB). To do this we may disclose personal information such as your name, date of birth, and address to the CRB to obtain an assessment of whether that personal information matches information held by the CRB. The CRB may give us a report on that assessment and to do so may use personal information about you and other individuals in their files. Alternative means of verifying your identity are available on request. If we are unable to verify your identity using information held by a CRB, we will provide you with a notice to this effect and give you the opportunity to contact the CRB to update your information held by them.

If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of assets, earnings and expenses.
 

Why we collect your personal information

We collect personal information for the purposes of assessing your application to become a investor of Supra and managing your investment and/or your application for finance and managing that finance. If you are applying for any financial products we collect your personal information to assess your application and manage and administer those financial products and disclosure of your personal information to prospective investors. We may also collect your personal information for the purposes of direct marketing, public announcements and managing our relationship with you. From time to time we may offer you other products and services.

To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. The types of organisations to which we are likely to disclose information about you include other mortgage intermediaries, lenders, valuers, lenders mortgage insurers, surveyors, accountants, credit reporting bodies, recoveries firms, debt collectors, product issuers, investment managers and lawyers. We may disclose your personal information to any other person or organisation that may have or is considering having an interest in your finance, or in our business. We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business.
 

How do we collect your personal information?

Where reasonable and practical we will collect your personal information directly from you. We also collect your personal information from CRBs and from finance brokers and other people such as accountants and lawyers. We may also collect personal information from publicly available sources of information, such as public registers.

When you access our website at http://supracapital.com.au/ via a browser or application or our Investor Portal, our servers may automatically record certain information. These server logs may include information such as your web request, GPS locations, session IDs of your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account. You can delete cookies from your computer at any time on your internet browser. However, doing so may limit your use of some of the website’s features.
 

Do we disclose your personal information?

Depending on the product or service you have requested, we may disclose your personal information to:

• prospective funders or other intermediaries in relation to your finance requirements including disclosure to our lender database in offer documents including Investment Information Memoranda;

• the State and Federal government including governmental agencies, bodies, committees and sub-committees;

• Banks, payment processors or other payment service providers;

• other organisations that are involved in managing or administering your finance such as third party suppliers, storage providers, printing and postal services, call centres, lenders mortgage insurers, trade insurers and credit reporting bodies;

• associated businesses that may want to market products to you;

• companies that provide information and infrastructure systems to us;

• anybody who represents you, such as finance brokers, lawyers, accountants and auditors;

• comply with any law enforcement agency, judicial proceeding, court order, or legal process in any jurisdiction that is investigating any breach or suspected breach of any law in any jurisdiction regarding your identity or other Information provided by you to us;

We may also disclose your personal information where:

• disclosure is reasonably necessary to protect Supra’s rights or intellectual property or to protect the safety of Supra’s employees or the public as required or permitted by law;

• we consider disclosure is necessary for the protection and wellbeing of a person;

• we are otherwise permitted by law to disclose your information;

• the purpose is related to the above purposes;

• you have provided us consent.

If you have applied for finance, we may verify any document that you have provided by sending it to the author for verification including:

• an organisation providing verification of your identity, including on-line verification of your identity or where we are required to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);

• investors and potential investors, agents or advisers, or any entity that has an interest in our business;

• data aggregators which collate and report information between us and our business partners and /or you;

• financial institutions including stockbrokers, custodians, fund managers and portfolio service providers and any other entity that administers your financial products; or

• your employer, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

1. the person or organisation has a commitment to protecting your personal information at least equal to our commitment; or

2. you have consented to us making the disclosure.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located inside or outside Australia.
 

Credit information

We may collect the following kinds of credit information and exchange this information with credit reporting bodies and other entities:

• credit liability information being information about your existing finance which includes the name of the credit provider, whether the credit provider holds an Australian Credit Licence, the type of finance, the day the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;

• repayment history information which is information about whether you meet your repayments on time;

• information about the type of finance that you are applying for;

• default and payment information; and

• court proceedings information.

We exchange this credit information for the purposes of assessing your application for finance and managing that finance.

This credit information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit information we hold about you.

When we obtain credit information from a CRB about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.

We may disclose your credit information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.
 

Notifiable matters

The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit information. You may request to have these notifiable matters (and this privacy policy) provided to you in an alternative form.

We exchange your credit information with CRBs. We use the credit information that we exchange with the CRBs to assess your creditworthiness, assess your application for finance and managing your finance.

If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement then we may disclose this information to a CRB.

You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information if needed. Please see the heading Access and correction to your personal and credit information, below.

Sometimes your credit information will be used by CRBs for the purposes of ‘pre-screening’ credit offers on the request of other credit providers.

You can contact the CRB at any time to request that your credit information is not used in this way. You may contact the CRB to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the CRB receives your notification, the CRB must not use or disclose that credit information. You can contact equifax.com.au for more information.
 

Direct marketing

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with.

If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on
(03) 8691 4190 or by writing to us at either:

• info@supracapital.com.au; or

• Level 1, 1121 High Street, Armadale
   

If the direct marketing is by email you may also unsubscribe by return e-mail with ‘unsubscribe’ in the heading. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
 

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure that information we hold about you is accurate and complete.
 

Access and correction to your personal and credit information

We will provide you with access to the personal and credit information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.

Depending on the type of request that you make, we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal or credit information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.

An explanation will be provided to you if we deny you access to the personal or credit information we hold about you.

If any of the personal or credit information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate, we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit information within 30 days.

We may need to consult with other finance providers, CRBs or entities as part of our investigation.

If we refuse to correct personal or credit information we will provide you with our reasons for not correcting the information.
 

Using government identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
 

Business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
 

Sensitive information

We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional association or trade unions, sexual preferences, criminal record, or health.
 

How safe and secure is your personal information that we hold?

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

While we take all due care in ensuring the privacy and security of your information, the possibility exists that this Information could be unlawfully intercepted while in transit over the internet or while stored on our systems or on our website. We disclaim all liability to you to the greatest extent pursuant to law should this occur.

We will take reasonable steps to destroy or permanently de-identify information if it is no longer needed for the purpose for which the information was disclosed, or required to be held pursuant to any other legal requirement.
 

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act and the Credit Reporting Code, you may contact our Compliance Officer by writing to us at either:

• info@supracapital.com.au; or

• Level 1, 1121 High Street, Armadale

We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.

If you are dissatisfied with the response of our Compliance Officer, you may make a complaint to the Australian Information Commissioner who can be contacted on enquiries@oaic.gov.au, at www.oaic.gov.au or 1300 363 992.
 

Further information

You may request further information about the way we manage your personal or credit information by contacting us.
 

Change in our privacy policy

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.

As a consequence, we may change this privacy policy from time to time or as the need arises.

You may request this privacy policy in an alternative form.