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Privacy Policy

1. About this Policy
1.1 This is the Privacy Policy of Credit Clear Limited (ACN 604 797 033, ABN 48 604 797 033) and its related companies that have adopted this Privacy Policy, including ARMA Group Holdings Pty Ltd and ASI Field Services Pty Ltd. We provide receivables management services to our business clients (Clients). Our services include the Credit Clear technology platform (Credit Clear Product). In some cases, Clients use their own branding for our services and the Credit Clear Product. Oakbridge Lawyers Pty Ltd maintains its own privacy policy, available at https://oakbridgelawyers.com.au/privacy-policy/
1.2 This Privacy Policy deals with how we handle personal information. Personal information is information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.
1.3 We handle personal information in our own right and also on behalf of our Clients and their customers (“Customers”).
1.4 Our Privacy Policy does not apply to information we collect about businesses or companies, but it does apply to personal information that we collect about individuals in those businesses or companies.
1.5 We comply with applicable privacy laws, including the Privacy Act 1988 (Cth) (Privacy Act), and the Australian Privacy Principles (APPs) contained in the Privacy Act.
1.6 This Privacy Policy explains how we collect, hold, use and disclose personal information. Where consent is required by law for a particular collection, use or disclosure, we will seek that consent separately or otherwise ensure that an applicable legal basis is available.
2. Information We Collect
2.1 To operate our business, we collect personal information. We aim to collect personal information only where it is reasonably necessary for one or more of our functions or activities, including to provide a service, product or information requested from us.
2.2 The types of personal information we may collect include:

(a) Personal details: details such as an individual’s name, address(es), date of birth, language, family details and other personal information that allows us to identify the individual and help make decisions, including automated decisions;

(b) Contact information: information such as an individual’s email address, telephone number, third-party usernames, residential, business and postal addresses, and other information that allows us to identify and contact the individual and to make or support decisions, including automated decisions;

(c) Financial information: information relating to an individual’s financial circumstances, such as debts owed to our Clients, assets, liabilities, income, expenses, memberships, and bank or payment card details used to transact with us. As part of our PCI-DSS compliance, we do not store complete payment card numbers. We may also collect other information that allows us to transact with the individual, provide services and make or support decisions, including automated decisions;

(d) Behavioural information: information about an individual’s online and offline preferences, habits, interactions, movements, trends and decisions when using the Credit Clear Product, together with information generated or inferred from those interactions, for automated decision-making, analytics and statistical purposes;

(e) Information an individual sends us: personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities.

(f) Sensitive information: (such as health information) which is only collected in the following circumstances:

(i) provided directly by the individual, with consent where required, about the individual’s health for the purpose of supporting a hardship application where the individual’s health may affect their capacity to pay;

(ii) provided by a Client where a referred matter relates to unpaid fees or charges for a medical service, such as an appointment, test or procedure. In those circumstances, we collect only the minimum amount of sensitive information reasonably necessary to support the asserted liability and take reasonable steps to delete or de-identify it when the matter has been resolved, recalled or withdrawn, subject to any legal or contractual retention requirement.
2.3 We may also collect other personal information about an individual if it is necessary to manage our relationship with them.
2.4 We may also collect information that is not personal information about an individual such as information regarding their computer, network and browser. This may include their IP address which can infer a location. Where information that is not personal information is collected, the APPs and this Privacy Policy do not apply.
3. How Information Is Collected
3.1 When providing our products and services (including the Credit Clear Product), we collect personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect personal information from individuals directly.
3.2 In some cases, we will collect information about individuals from a third party.
3.2 We mainly collect personal information from our Clients who use us to provide receivables management services in relation to their Customers. This may include personal information about Customers and personal information about other individuals.
3.4 We also collect personal information from individuals directly. The ways we do this include:

(a) Using Credit Clear: when an individual enters personal information into the Credit Clear Product for any reason.

(b) Registrations/subscriptions: when an individual registers or subscribes for a service, list, account, connection or other process and they enter personal information details in order to receive or access something, including a transaction.

(c) Contact: when an individual contacts us in any way, including to make an enquiry about our services, or to engage with our business or its employees in the course of receiving services from us.

(d) Access: in some cases an individual may be required to validate their identity in order to use our services, including the Credit Clear Product. When an individual accesses us through the internet we may also collect information using cookies (an individual can adjust their browser’s setting to accept or reject cookies) or analytical services.

(e) Pixel tags: pixel tags enable us to send email messages in a format Customers can read and they tell us whether mail has been opened.
3.5 We may also collect personal information from advertising sources, public records, information that an individual makes publicly available online, including social media content, and third-party data providers or data brokers.
3.6 Personal information may also be collected by us from mailing lists, contractors, staff, recruitment agencies, and our business partners.
3.7 We will seek to ensure that an individual is aware of when their personal information is being collected. At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify an individual of the collection and of matters relevant to the collection, unless it is obvious from the circumstances that the individual would know or would expect us to have the information.
4. Why We Collect, Hold And Use Personal Information
4.1 We collect, hold, use and disclose personal information primarily to:

(a) provide products or services to our Clients;

(b) enable individuals to manage their affairs with our Clients; and

(c) contact individuals for business purposes and manage our relationship with individuals or our Clients.
4.2 Personal information is also collected, held, used and disclosed to enable us to operate our business. This may include the following purposes:

(a) enabling the individual to manage their affairs with our Client;

(b) the provision of goods and services between an individual and us;

(c) verifying an individual’s identity;

(d) communicating with an individual about their relationship with us or our services;

(e) direct marketing and promotions, where permitted by law. Individuals may opt out of receiving direct marketing communications at any time by using the unsubscribe facility in the communication or contacting us using the details in paragraph 9;

(f) competitions, surveys and questionnaires;

(g) dealing with complaints about or made by an individual, or if we suspect that an individual is in breach of any of our terms and conditions or that an individual has engaged in any unlawful activity;

(h) as required or permitted by any law (including the Privacy Act); and

(i) developing and improving our products, client service and relationships.
4.3
We use computer programs, including automated processes, decisioning rules, analytical models and artificial intelligence tools, to create engagement profiles, make recommendations to our Clients, support agent-led decision-making, and make or support decisions about how we communicate and engage with individuals in connection with accounts referred to us by our Clients.
4.4
The kinds of personal information used in these computer programs may include information supplied by our Clients, information collected directly from individuals, information generated through use of the Credit Clear Product, and information obtained from the third-party sources described in section 3. This may include contact details, account and payment information, identity and verification information, interaction and engagement history across our channels, communication preferences, response history, the content of communications, inferred engagement profiles, and hardship, vulnerability or other special-circumstance indicators where lawfully collected and relevant. Sensitive information, such as health information provided in support of a hardship application, is used only in the circumstances described in paragraph 2.2(f).
4.5 The kinds of decisions or recommendations that may be made or supported by these computer programs include:

(a) the time we attempt to contact an individual;

(b) the communication channel used when attempting to contact an individual;

(c) the content and sequencing of messages sent to an individual;

(d) whether an individual may be presented with arrangement, payment or discount options, within the parameters, thresholds and exceptions approved or mandated by our Client;

(e) whether an account should be referred for review by one of our agents or our Client;

(f) whether an enquiry, communication or action should be routed or escalated to one of our agents or our Client;

(g) whether contact with an individual should be paused, limited or suppressed, including where hardship, vulnerability, dispute, complaint, deceased estate or legal indicators are present;

(h) the prioritisation and sequencing of accounts and work within our operational workflows;

(i) recommendations to our Client about the status or handling of an account, including whether an account should be returned, closed, paused or referred to our Client for further action, with any decision of that kind being made by our Client and not by us.
4.6
Some of these decisions may be made solely by automated means. In other cases, a computer program makes a recommendation or does a thing that is substantially and directly related to a decision made by one of our agents or by our Client. Our computer programs may make or support the kinds of decisions described in paragraph 4.5. Decisions or actions reasonably capable of significantly affecting an individual’s rights or interests are not made solely by automated means.
4.7
We do not use automated decisions outside of our approved and established policies, which are subject to the authority or guidelines provided by our Clients. We also work within the conditions, thresholds and exceptions imposed on us by our Clients and by the laws, regulatory obligations and industry codes that apply to us and to them, including those relating to financial hardship, vulnerability and other special circumstances.
4.8
An individual is not placed in an arrangement or position that they have not accepted. Arrangement, payment and discount options are presented to an individual as options only, and take effect only where the individual engages with them and accepts them.
4.9
We will always provide direct and accessible contact channels allowing an individual to reach someone in our team. Where an individual is unable to take advantage of an arrangement or discount offer, alternative options remain available to the individual through our digital channels, and the individual may also contact us directly so that their circumstances can be reviewed.
4.10
Actions that could significantly affect the rights or interests of an individual will always be subject to human oversight. That oversight is exercised by a responsible person within our business, and an individual may ask us to have a decision or action of that kind reviewed by a member of our team. If an individual is not satisfied with the outcome, the complaints process in paragraph 8 of this Privacy Policy is available to them.
4.11
Where we use an automated or artificial intelligence voice or messaging agent to communicate with an individual, we will disclose on every call, and in any message, that the individual is dealing with an automated system. Those interactions are recorded, transcribed, quality assured and supervised by our people. An individual may ask at any time to speak with a member of our team, and we will honour that request. Accounts that are in hardship, in dispute or flagged as vulnerable are not allocated to an automated agent. Where hardship, vulnerability or a dispute is raised during an interaction, the interaction is transferred to one of our agents.
5. Disclosure Of Personal Information
5.1 We may disclose an individual’s personal information to:

(a) external service providers that assist us to operate our business or provide services, including providers of file storage, databases, mailing, telephony and communication channels, marketing, payment processing and gateways, quality assurance, identity verification, information technology support, recording, transcription, analytics and agent-assist services; or

(b) our professional advisors and agents.
5.2 Where a third party, such as a Client, provides personal information to us, that third party may retain access to the information as the master record holder, subject to applicable law, contractual requirements and our information-handling arrangements.
5.3 We may disclose an individual’s personal information to these third parties so that they can assist us with providing the best possible service to our Customers. Those people or companies will be permitted to access only the personal information they need to deliver the service to us, our Customers, or our Clients, or where required by law or our reporting requirements. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of personal information.
5.4 If we sell or otherwise transfer part or the whole of our company or our business (or part of our business) to another organisation (including in the course of a transaction like a sale, merger or acquisition or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), personal information that is collected by us may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner.
5.5 We may utilise third party service providers which may result in personal information being in transit or disclosed outside of Australia, these circumstances include to:
We may use third-party service providers or agents located outside Australia, or whose services involve access to, processing of, transit through or temporary storage of personal information outside Australia. This may occur where those providers assist us to communicate with individuals, record, transcribe or analyse interactions, provide quality assurance, coaching, training, compliance monitoring, analytics, artificial intelligence services or technical support, or where an agent is appointed in a foreign jurisdiction on a Client’s instructions where an individual is reasonably believed to reside. Further information regarding overseas recipients is available on request.
5.6 Generally, the personal information we collect and hold about an individual is stored in the country set out below, according to the country in which the individual is located:

Country in which the individual is located: Australia and New Zealand

Country in which personal information is stored: Australia
5.7 Before disclosing personal information to an overseas recipient, we take reasonable steps required by applicable privacy law to ensure that the recipient handles the information consistently with the APPs, unless an exception applies.
5.8 Where we propose to rely on an individual’s informed consent in relation to an overseas disclosure, we will provide information about the proposed disclosure and the consequences of that consent before seeking it.
5.9 We will not otherwise disclose information about individuals unless the disclosure:

(a) is required or authorised by law; or

(b) the individual has consented to our disclosing the information about them.
5.10
We use quality assurance and agent-assist technology provided by third-party service providers to record, transcribe and analyse our telephone conversations and other interactions with individuals. This technology may be used after an interaction has ended, or in real time while a call is in progress, to support and coach our agents, monitor the quality and compliance of our interactions, and test, train and improve our systems. Calls to and from us may be recorded and monitored, and we will tell an individual when a call is being recorded. To provide that technology, and to enable an automated agent to hold an interaction with an individual, we provide the service provider with the account and contact information it needs for that purpose, together with payment and outcome information used for reporting and reconciliation.
6. Security of Personal Information
6.1 We will take all reasonable steps to protect an individual’s personal information from unauthorised access, modification or disclosure and from misuse, interference and loss. This includes appropriately securing our physical facilities and electronic networks.
6.2 We use encryption to transfer personal information. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual who provides information to us via the internet or by post does so at their own risk.
6.3 If an individual suspects any misuse or loss of, or unauthorised access to, their personal information, they should let us know immediately.
6.4 We retain personal information for as long as it is reasonably required for the purposes for which it was collected or as otherwise required or permitted by law. Retention periods may vary according to the type of information, our commercial agreements, the status and age of an account, limitation and record-keeping requirements, complaints, disputes, legal holds, regulatory investigations, fraud prevention and security requirements. When personal information is no longer required, we take reasonable steps to destroy or permanently de-identify it.
6.5
If we suspect that a data breach involving personal information has occurred, we will assess it promptly. Where an eligible data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.
7. How to Access and/or Update Information
7.1 An individual has the right to request access to, or correction of, the personal information that we hold about them. This right is subject to the APPs and some exceptions under the law. We will respond to a written request within a reasonable period of receiving it, subject to appropriate verification of the individual’s identity.
7.2 We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, up to date, complete and relevant, having regard to the purposes for which it is used or disclosed. Individuals should provide accurate information and notify us when their information changes.
7.3 If an individual believes that personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, the individual may contact us and we will take reasonable steps to correct it where appropriate. If we refuse a correction request, we will provide a written notice setting out the reasons for refusal and the available complaint mechanisms and, if requested, take reasonable steps to associate a statement with the information indicating that the individual considers it to be inaccurate, out of date, incomplete, irrelevant or misleading.
7.4 We will give each individual access to their personal information unless there is a lawful reason for refusing the request for access or correction. If we refuse a request, we will give the individual a written notice explaining our reasons for that refusal and how they may complain about that refusal.
7.5 We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the personal information that we hold about them.
8. Complaints and Disputes
8.1 If an individual has a complaint about our handling of their personal information, they are encouraged to contact us on 1300 363 394 or they should address their complaint in writing to the details below. Complaints should set out the details of the complaint and contact details of the individual making the complaint.
8.2 Our Privacy Officer will review complaints, acknowledge requests and ask for any other applicable information. Our Privacy Officer will then investigate the issue and advise the individual in writing of the outcome.
8.3 If we have a dispute regarding an individual’s personal information, we both must first attempt to resolve the issue directly between us. If the issue is not resolved, the individual can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at the OAIC website, current at the time of this publication at www.oaic.gov.au
9. Contacting Us
9.1 All correspondence should be addressed to:

Attn: Privacy Officer

Credit Clear Limited, Building 11, 41-43 Bourke Rd, Alexandria NSW 2015 

Email: info@creditclear.com.au

Call us on 1300 363 394