Credit Reporting Policy (Consumer Finance)

Breeze Capital Pty Ltd ACN 147 671 949

Breeze Payment Plans Pty Ltd ACN 665 267 792

Automated Collections Services Pty Ltd ACN 144 738 796
(and our related businesses)

Purpose

This Credit Reporting Policy explains how we manage credit information and credit eligibility information in accordance with:

Part IIIA of the Privacy Act 1988 (Cth)
the Privacy (Credit Reporting) Code 2014 (CR Code)
applicable consumer credit and regulatory obligations

This Policy applies to our consumer finance products and credit-related activities.

Scope

This Policy applies to:

applicants for consumer credit
current and former consumer credit customers
credit information we obtain from or disclose to credit reporting bodies
credit reporting information we hold or use in connection with consumer finance

Types of Credit Information We Handle

We may collect, hold, use and disclose the following credit-related information:

identification information
credit application information and enquiries
consumer credit liability information
repayment history information (RHI)
default information (where permitted under law)
hardship arrangement information (where applicable and permitted)
credit eligibility information received from credit reporting bodies
information derived from credit reporting data
fraud prevention and identity verification information

We only collect and use credit information that is reasonably necessary for our consumer lending functions.

Sources of Credit Information

We obtain credit information from:

credit reporting bodies (Equifax, Illion, Experian)
credit applications and supporting documentation provided by you
internal account and repayment systems
identity verification and fraud prevention services
other credit providers (where permitted by law)

Use of Credit Information

We use credit information to:

assess consumer credit applications
verify identity and prevent fraud
manage existing credit accounts
monitor repayment performance
meet legal and regulatory obligations
comply with credit reporting obligations under Part IIIA

We do not use credit information for unrelated purposes.

Disclosure of Credit Information

We may disclose credit information to:

credit reporting bodies (Equifax, Illion, Experian)
service providers assisting with credit assessment or account management
other credit providers (where permitted by law)
internal staff and authorised representatives
professional advisers (legal, accounting, compliance)
regulators or law enforcement where required or authorised by law
entities involved in sale, assignment or transfer of finance assets or business operations

We take reasonable steps to ensure disclosures are made in accordance with applicable legal requirements.

Credit Reporting Bodies

We may exchange credit information with:

Equifax
Illion
Experian

These credit reporting bodies may use credit information to:

maintain credit reports
provide credit reporting services to other credit providers
support fraud prevention and credit assessment functions as permitted by law

Accuracy and Data Quality

We take reasonable steps to ensure that credit information we report is:

accurate
up-to-date
complete
relevant
not misleading

Our controls include:

validation of account and repayment data prior to reporting
review of account status before reporting defaults
internal reconciliation processes
investigation of discrepancies raised by customers or credit reporting bodies

Where we identify incorrect information, we take reasonable steps to correct it.

Access to Credit Information

You may request access to credit information we hold about you.

We will:

verify your identity
respond within a reasonable period in accordance with legal requirements
provide access unless a legal exception applies

Requests should be made using the contact details in this Policy.

Correction of Credit Information

You may request correction of credit information you believe is:

inaccurate
out-of-date
incomplete
irrelevant
misleading

Our process:

Upon receiving a correction request, we will:

acknowledge receipt of the request
verify identity
investigate the information in question
review internal records and relevant supporting information
consult with relevant credit reporting bodies where required
determine whether correction is required

Timeframes:

We will respond within the timeframes required under:

Part IIIA of the Privacy Act 1988 (Cth)
the Privacy (Credit Reporting) Code 2014 (generally within 30 days unless extended as permitted)

If correction is required:

We will take reasonable steps to:

correct our records
notify relevant credit reporting bodies
ensure updated information is reflected where required

Credit Reporting Complaints and Disputes

If you believe credit information we hold is incorrect or has been improperly handled, you may lodge a complaint with us.

We will:

investigate your complaint in accordance with this Policy
review internal records and supporting documentation
consult credit reporting bodies where required
keep you informed of progress
provide a written outcome with reasons

Defaults and Consumer Credit Reporting

We may report default information to credit reporting bodies where permitted under law.

We take reasonable steps to ensure:

the debt is valid and payable
required notices have been issued (where applicable)
default amounts are accurate
updates or removals are made where required

Where a default is disputed, we will investigate and take appropriate action under this Policy.

Hardship Information

Where applicable, we may record hardship arrangements in accordance with the Privacy Act and CR Code.

We ensure hardship information is:

accurately recorded
kept up to date
corrected where arrangements change or conclude
handled in accordance with legal requirements

Security of Credit Information

We take reasonable steps to protect credit information from:

misuse
interference
loss
unauthorised access, modification or disclosure

Safeguards include access controls, staff confidentiality obligations, encryption where appropriate, and system security protections.

Retention and Destruction

We retain credit information only for as long as necessary to:

manage credit relationships
comply with legal obligations
meet credit reporting requirements

When no longer required, we take reasonable steps to securely destroy or de-identify the information.

Overseas Disclosure

We do not routinely disclose credit information overseas unless required for operational purposes and permitted by law.

Where overseas disclosure occurs, we take reasonable steps to ensure compliance with applicable Australian privacy requirements.

Relationship with Privacy Policy

This Credit Reporting Policy should be read together with our Privacy Policy.

In the event of any inconsistency, this Policy prevails to the extent of credit reporting information.

Availability of this Policy

This Policy is available on our website or upon request.

Contact Us

Operations Manager

Breeze Finance

PO Box 7795

Cloisters Square WA 6850

Alternatively you can call us on 1300 290 240

Review of Policy

We review this Policy periodically to ensure ongoing compliance with:

the Privacy Act 1988 (Cth)
the Privacy (Credit Reporting) Code 2014
applicable regulatory guidance