Privacy Policy

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1. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).  This policy explains how and why we collect, use, hold and disclose your personal information.  
2. This privacy policy applies to Two Capital Group Pty Ltd ACN 689 204 975 ATF Two Capital Group Unit Trust ABN 42 876 449 331 (Partways).  When this privacy policy mentions "we", "us" or "our" it refers to Partways. 
3. This policy also sets out our policies relating to management of your credit information (if applicable).  Our obligations with respect to credit information are set out in Part IIIA (Credit Reporting) of the Privacy Act.

2. What is personal information?
   
   1. Under the Privacy Act, personal information is defined to mean information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
   2. Personal information can include sensitive information.  Sensitive information is defined as information or opinion about a person's race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.
   3. Personal information can also include credit information, including:
      
      1. identification information – name, date of birth, current or previous address, driver's licence number;
      2. type and amount of credit sought;
      3. publicly available information about an individual's creditworthiness;
      4. default information;
      5. new arrangement information;
      6. court proceedings information; 
      7. personal insolvency information;
      8. repayment history information; and
      9. payment information in relation to an overdue payment.
   4. Not all information that we collect from you is personal information.  Information that we collect from you that is de-identified or aggregated is not regulated by the APPs.
3. Types of personal information that we collect and hold
   
   1. We collect information about you and your interactions with us, for example, when you purchase or use any of our products or services, call us or otherwise visit our website.  The information we collect from you may include your identity and contact details, your history of purchases and use of our products and services and details of enquiries or complaints you make.
   2. We generally collect personal information and sensitive information from you in the following ways:
      
      1. information that you give directly to us (for example when applying for a loan, via email or via telephone);
      2. information that we get from your use of our websites or applications;
      3. information that you provide if you interact with us through social media websites;
      4. information that we receive from third party service providers, businesses that provide commercial financial information and market research organisations;
      5. persons authorised by you (such as lawyers or accountants);
      6. referees (if you give us the name of someone who can give a reference about you); 
      7. publicly available sources.
   3. The types of personal and sensitive information that we can collect and hold may include:
      
      1. name;
      2. contact details including address, email address and telephone number;
      3. date of birth;
      4. delivery address;
      5. citizenship;
      6. dependants;
      7. material status;
      8. property and assets;
      9. employment status;
      10. personal finances including for example income, welfare and debts;
      11. legal proceedings details (as they relate to our products or services that we may provide you); and 
      12. technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.
   4. If we offer you credit, we may also collect credit information from you (as described above).  If credit is offered, we may collect credit information through our staff, for example when you enquire about our services, or if you complete a credit application form.  We may also collect credit information about you from third party sources, for example publicly maintained records or referees.
4. Cookies
   
   1. We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.
5. Why do we collect, hold and use your personal information?
   
   1. We collect, hold and use your personal information so that we can:
      
      1. provide you with products and services, for example, to collect personal information contained in our credit application for the purposes of assessing whether or not to provide credit;
      2. manage our relationship with you;
      3. contact you, for example, to respond to your queries or complaints, or if we need to tell you something important; and
      4. comply with our legal obligations and assist government and law enforcement agencies or regulators.
6. How do we collect your personal information?
   
   1. We will collect your personal information directly from you whenever you interact with us. Including for example when you complete our credit application and undertake our credit assessment processes; 
   2. We may collect information from third parties such as:
      
      1. credit information about you from third party sources, for example publicly maintained records or trade referees.
   3. If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries. 
7. How do we store and hold personal information?
   
   1. We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.
   2. We implement and maintain processes and security measures to protect personal information, which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
   3. These processes and systems include the following:
      
      1. The use of identity and access management technologies to control access to systems on which information is processed and stored; and
      2. Monitoring and regularly reviewing our practise against our own policies and against industry best practice.
   4. We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
8. Who do we disclose your personal information to, and why?
   
   1. We may disclose personal information to external service providers so that they may perform services for us or on our behalf.
   2. We may also disclose your personal information to others where:
      
      1. we are required or authorised by law to do so;
      2. you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
      3. we are otherwise permitted to disclose the information under the Privacy Act. 
   3. If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
9. Do we disclose personal information to overseas recipients?
   
   1. We may disclose your personal information to recipients that are located outside Australia.
   2. Those recipients are likely to be located in the Philippines or India.
10. Do we use your personal information for marketing?
    
    1. We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our other business partners or our service providers.
    2. Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
11. Access to and correction of your personal information
    
    1. You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below in section 14. There are some circumstances in which we are not required to give you access to your personal information.
    2. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
    3. We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date, complete, relevant and not misleading.
12. Complaints
    
    1. If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below in section 14.
    2. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
    3. If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent adviser or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action that may be available.
13. Data breach
    
    1. If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals.  In such a situation we will comply with the requirements of the Act which may require notification to the OAIC and affected individuals.  Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk mitigation and notification activities as required.
14. Contact details
    
    1. If you have any questions, comments, requests or concerns, please contact us at:
       
       1. Email: hello@partways.au
       2. Telephone: (02) 9157 9647
15. Changes to this policy
    
    1. From time to time, we may change our policy on how we handle personal information or the types of personal information that we hold. Any changes to our policy will be published on our website.
    2. You may obtain a copy of our current policy from our website or by contacting us at the contact details above.
16. Third party privacy practices
    
    1. Partways has no control over and bears no liability in relation to the privacy practices of any third-party websites, services or resources accessible through our websites or applications.

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