Legals

Credit Reporting Statement

Updated on

January 15, 2024

SECTION A – INTRODUCTION

1. INTRODUCTION

1.1 This document is the Credit Reporting Statement of Speedle Pty Limited ABN: 86 668 001 045 (“Speedle, we or us”).

1.2 The purpose of this Credit Reporting Statement is to tell you how we collect, use, hold, disclose and protect your Credit Information.

1.3 This Credit Reporting Statement should be read in conjunction with our Privacy Statement.

1.4 We will act to protect your Credit Information in accordance with the Australian Privacy Principles, the Privacy Act 1988 (Cth) (the “Privacy Act”) and the Credit Reporting Code 2014 Version 2 (“CR Code”).

1.5 Please check the privacy page on our website regularly at the following address for amendments and updates to our Privacy Statement and Credit Reporting Statement: www.speedle.com.au

SECTION B – INFORMATION WE MAY COLLECT

2. WHAT IS CREDIT INFORMATION?

2.1 Credit Information is information that has a bearing on credit that has been provided to you or that you have applied for. This includes credit for personal, domestic or household purposes and credit in connection with a business. It can also cover information about you as a guarantor of a loan or as an insured party under a credit related insurance policy.

2.2 If you apply for credit or give a guarantee, we may collect information about your financial position for the purpose of assessing an application for credit and to assist in the ongoing management of the credit product or guarantee. The credit information we collect may include:

(a) identification information;

(b) credit application information - information in relation to a credit application, including the type and amount credit you have applied for;

(d) serious credit infringement - a record of when a lender reasonably believes that there has been a fraud relating to your consumer credit or that you have avoided paying your consumer credit payments and the credit provider can’t find you;

(e) personal insolvency information - a record relating to your bankruptcy or your entry into a debt agreement or personal insolvency agreement;

(f) court proceedings information - an Australian court judgment relating to your credit;

(g) publicly available information - a record relating to your activities in Australia and your credit worthiness;

(h) consumer credit liability information - certain details relating to your consumer credit, such as the name of the credit provider, the type of consumer credit, the day on which the consumer credit was entered into and terminated, the maximum amount of credit available and certain repayment terms and conditions;

(i) repayment history information - a record of whether or not you’ve made your consumer credit payments and when they were paid;

(j) payment information - if a lender gave a credit reporting body default information about you and the overdue amount is paid, a statement that the payment has been made; and

(k) new arrangement information - if a lender gave a credit reporting body default information about you and your consumer credit contract is varied or replaced, a statement about this.

3. WHAT CREDIT INFORMATION DO WE COLLECT FROM OTHERS?

3.1 We may collect Credit Information about you from other people. This may happen without your direct involvement. For instance, we may collect credit reports from credit reporting bodies or opinions from other lenders about your creditworthiness. We may also seek credit information about you from:

(a) publicly available sources of information, such as public registers;

(b) your representatives (including your legal adviser, mortgage broker, financial adviser, executor, administrator, guardian or trustee);

(d) other organisations, who jointly with us, provide products or services to you; and

(e) commercial information service providers, such as companies that provide fraud prevention reports.

SECTION C – PURPOSES FOR COLLECTING, USING AND DISCLOSING CREDIT INFORMATION

4. HOW WE USE OR DISCLOSE YOUR CREDIT INFORMATION

4.1 We may use the Credit Information that is collected and held by us to help us decide whether or not to provide credit to you (or to your related company or other entity). We may also use this information to derive or calculate a credit assessment score in relation to you, which we may use to help in conducting an assessment of your creditworthiness or the creditworthiness of your related company or other entity.

4.2 The Credit Information that we hold about you may be used by us in accordance with the Privacy Act and the CR Code.

4.3 The purposes for which we use your Credit Information may include:

(a) using your Credit Information to assess any application that you make to us for credit (or which is made by your related company or other entity);

(b) using your Credit Information to collect payments that are owed to us in respect of any credit that we have previously provided to you (or to your related company or other entity);

(c) disclosing your Credit Information to any of our related companies that are also are considering whether to provide credit to you (or to your related company or other entity);

(d) where you have offered to guarantee credit that we have offered to provide to your related company or entity, to assess your suitability as a guarantor of that credit and to enforce that guarantee if required;

(e) disclosing your Credit Information to a third party that you or we ask to act as a guarantor of any credit provided to you;

(f) disclosing your Credit Information to the credit reporting body that we deal with. Credit reporting bodies collect different types of Credit Information about individuals and use that information to provide a credit-related service to their customers (including to us);

(g) disclosing your Credit Information to other third parties that provide services to us (or to you on our behalf). These might include debt collectors, credit management agencies and other third parties that process applications for credit made to us;

(h) disclosing your Credit Information to other credit providers which provide, or are considering providing, credit to you (or to your related company or other entity);

(i) using and disclosing Credit Information that we hold about you to assess and respond to any access or correction requests that you make to us;

(j) where we are consulted by a credit reporting body or another credit provider about an access or correction request that you have made to those entities, to respond to that consultation request;

(k) where you complain to the Office of the Australian Information Commissioner (“OAIC”) or the Australian Financial Complaints Authority (“AFCA”) about our treatment of your Credit Information, to respond to that complaint and to seek legal or other professional advice in relation to your complaint;

(l) using and disclosing Credit Information that we hold about you as required by law or the order of a court or tribunal; and

(m) where you otherwise expressly consent to the use or disclosure.

5. WHO DO WE DISCLOSE YOUR CREDIT INFORMATION TO?

5.1 We disclose your Credit Information to organisations to help deliver or support the provision of products or services to you. These may include:

(a) our agents, contractors and external service providers (for example, mailing houses and technology service providers);

(b) credit representatives who sell products and services on our behalf;

(d) other organisations, who jointly with us, provide products or services to you;

(e) other financial services organisations, including banks, superannuation funds, stockbrokers, custodians, fund managers and portfolio service providers;

(f) organisations involved in our funding of loans (including securitisation trustees, investors and their advisers);

(g) credit reporting bodies;

(h) organisations that provide us with insurance to cover our lending risks;

(i) our financial advisers, legal advisers or auditors;

(j) your representatives (including your legal adviser, mortgage broker, financial adviser, executor, administrator, guardian or trustee);

(k) government agencies or dispute resolution schemes that assist consumers in relation to credit; and

(l) where permitted by law, debt collection agencies or other lenders, such as where you have given mortgage security over the same property to us and another lender.

5.2 We may also disclose your Credit Information to others where:

(a) we are required to disclose information by law e.g. under court orders or statutory notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter-terrorism financing;

(b) you may have expressly consented to the disclosure or your consent may be reasonably inferred from the circumstances; or

5.3 Where required by law, we will make a written note (which may be kept in electronic form) of any use or disclosure that we make relating to your Credit Information.

6. COLLECTING AND DISCLOSING CREDIT INFORMATION TO CREDIT REPORTING BODIES

6.1 We may disclose information about you to, or collect information about you from a credit reporting body if you are applying for credit or you have obtained credit from us or if you guarantee or are considering guaranteeing the obligations of another person to us or you are a director of a company that is loan applicant or borrower or guarantor.

6.2 The Privacy Act and the CR Code limit the information we can give to credit reporting bodies and that the credit reporting body can give to us.

6.3 The information we can disclose to credit reporting bodies includes:

(a) identification details;

(b) the type and amount of credit you have e.g. credit cards, personal loans etc.;

(d) if you have made your repayments; and

(e) if you have committed fraud or another serious credit infringement.

6.4 Credit reporting bodies may include your Credit Information in reports that they provide to credit providers to assist those providers in assessing your creditworthiness. Some of that information may reflect adversely on your creditworthiness, e.g. if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get credit from other lenders.

6.5 The Privacy Act and the CR Code also limits what we can do with the information we obtain from a credit reporting body. Generally, it can only be used in relation to the consumer credit products you hold through us.

6.6 The credit reporting bodies we deal with are:

(a) Equifax - www.equifax.com.au

(b) Illion - www.illion.com.au

6.7 For contact details and information on how credit reporting bodies manage Credit Information, please see the privacy policies available at the links above.

6.8 You can also ask a credit reporting body not to use or disclose your personal information for a period if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.

6.9 We will not share any of your Credit Information with a credit reporting body, unless it has a business operation in Australia. We will not share credit eligibility information (that is, credit information we obtain about you from a credit reporting body or that we derive from that information) with organisations unless they have business operations in Australia.

7. DO WE DISCLOSE YOUR CREDIT INFORMATION OVERSEAS?

7.1 We may utilise overseas service providers for some of our activities. These service providers may be located in:

(a) Australia; and

(b) New Zealand

7.2 We will only disclose your Credit Information when permitted to do so by the Privacy Act and after we ensure that:

(a) the overseas recipient does not breach the Australian Privacy Principles; or

(b) you will be able to take action to enforce the protection of a law or binding scheme that has the effect of protecting the information in a way that is at least substantially similar to the way in which the Australian Privacy Principles protect the information; or

(c) you have consented to the disclosure after we expressly informed you that there is no guarantee that the overseas recipient will not breach the Australian Privacy Principles; or

(d) the disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order.

7.3 We may store your Credit Information in cloud-based software or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your personal information may be held. If your personal information is stored in this way, disclosures may occur in countries other than those listed.

7.4 Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

SECTION D – ACCESS TO AND CORRECTION OF YOUR CREDIT INFORMATION

8. ACCESS TO A CREDIT REPORT ABOUT YOU

8.1 You have the right to ask for a copy of any credit report we have obtained about you from a credit reporting body. However, as we may not have retained a copy after we have used it in accordance with the Privacy Act, the best means of obtaining an up-to-date copy is to get in touch with the credit reporting body directly.

8.2 You have a right to have any inaccuracies corrected or, if there is any dispute as to accuracy, to have a note added to your credit reporting body file explaining your position.

8.3 If we decline your credit application wholly or partly because of adverse information on your credit report, the Privacy Act requires us to tell you of that fact and how you can go about getting a copy of your credit report.

9. CORRECTION

9.1 We aim to hold up to date Credit Information about you at all times. If you consider that any information we hold about you is incorrect in any way, you may seek the correction of that information.

9.2 To seek such a correction please call the relevant contact number provided at clause 11 below.

9.3 We do not charge a fee for requesting a correction of Credit Information.

9.4 In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request in writing.

9.5 If we refuse your request to correct your Credit Information, you also have the right to request that a statement be associated with your Credit Information noting that you disagree with its accuracy.

SECTION E – MAKING A PRIVACY COMPLAINT

10. COMPLAINTS

10.1 We offer a free internal complaint resolution scheme to all of our customers. Should you have a privacy complaint, please contact us to discuss your concerns. Our contact details set out as per clause 11 below.

10.2 To assist us in helping you, we ask you to follow a simple three-step process:

(a) gather all supporting documents relating to the complaint;

(b) contact us and we will review your situation and if possible, resolve your complaint immediately; and

(c) if the matter is not resolved to your satisfaction, please contact our Compliance Officer on 02 8365 2322 or put your complaint in writing and send it to:

(i) Email: complaints@speedle.com.au or

(ii) Post: Speedle, Salesforce Tower, Level 22, 180 George Street Sydney NSW 2000

10.3 We will rectify any breach if the complaint is justified and will take necessary steps to resolve the issue.

10.4 In certain situations, to deal with a complaint it may be necessary to consult with third parties. However, please note any disclosure of personal information to third parties will be provided with your authority and consent.

10.5 After a complaint has been received, we will send you a written notice of acknowledgement setting out the process. The complaint will be investigated, and the decision will be sent to you within thirty (30) days unless you have agreed to a longer time. If a complaint cannot be resolved within the agreed time frame or a decision could not be made within thirty (30) days of receipt, a notification will be sent out to you setting out the reasons and specifying a new date when you can expect a decision or resolution.

10.6 If you are not satisfied with our internal privacy practices or the outcome in respect to your complaint, you may approach the Office of the Australian Information Commissioner (“OAIC”) Commissioner with your complaint.

Office of the Australian Information Commissioner

Address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Website: oaic.gov.au

10.7 AFCA is an external dispute resolution scheme in which we are a member. AFCA can consider certain privacy complaints relating to either the provision of credit or credit reporting information in general. You can lodge your complaint with:

Australian Financial Complaints Authority

Address: PO Box 3 Melbourne VIC 3001

Phone: 1800 931 678 (free call)

Email: info@afca.org.au

Website: www.afca.org.au

SECTION F – CONTACT US

11. CONTACT DETAILS

11.1 If you have any questions or would like further information about our privacy, credit reporting and information handling practices, please contact us by:

(a) Email: privacy@speedle.com.au; or

(b) Phone: 02 8365 2322; or

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Credit Reporting Policy

Updated on

January 15, 2024

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SECTION A – INTRODUCTION

1. PURPOSE

1.1 Speedle Pty Limited (“Speedle”) is committed to complying with all laws, codes of practice and regulations that apply to its business. Speedle recognises its responsibility to ensure its staff are adequately trained and undertake their compliance obligations in a responsible and diligent manner.

1.2 This Credit Reporting Policy (“Policy”) explains how Speedle manages clients’ Credit Information and Credit Eligibility Information.

1.3 This Policy has been developed in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”), Privacy Regulations 2013 (“Privacy Regulations”) and the Privacy (Credit Reporting) Code 2014 (Version 2) (“CR Code”).

2. GLOSSARY

TERM

DEFINITION

Affected Information Recipient means:

(a) a mortgage issuer; or

(b) a trade issuer; or

(d) a person referred to in paragraph 21G(3)(b) Privacy Act being a related body corporate of a Credit Provider; or

(e) a person referred to in paragraph 21G(3)(c) Privacy Act being a person to whom the disclosure is made who processes an application made for credit or manages credit for the Credit Provider; or

(f) an entity or adviser referred to in paragraph 21N(2)(a) Privacy Act such as a legal adviser or a financial adviser.

Australian Law means:

(a) an Act of the Commonwealth or of a State or Territory;

(b) or regulations, or any other instrument, made under such an Act; or

(d) or rule of common law or equity.

Australian Link An organisation or SBO has an Australian Link if the organisation or operator is:

(a) an Australian citizen; or

(b) a person whose continued presence in Australia is not subject to a limitation as to time imposed by law; or

(d) a trust created in Australia or an external Territory; or

(e) a body corporate incorporated in Australia or an external Territory; or

(f) an unincorporated association that has its central management and control in Australia or an external Territory.

An organisation or SBO also has an Australian Link if all of the following apply:

(a) the organisation or operator is not described above;

(b) organisation or operator carries on business in Australia or an external Territory;

(c) the personal information was collected or held by the organisation or operator in Australia or an external Territory, either before or at the time of the act or practice.

Australian Privacy Principles (“APPs”) means the legally binding principles that set out standards, rights and obligations in relation to handling personal Information.

Court/Tribunal Order means an order, direction or other instrument made by:

(a) a court; or

(b) a tribunal; or

(d) a magistrate (including a magistrate acting in a personal capacity) or a person acting as a magistrate; or

(e) a member or an officer of a tribunal;

and included an order, direction or other instrument that is of a interim or interlocutory nature.

CP Derived Information means any Personal Information (other than Sensitive Information) about the individual:

(a) that is derived from Credit Reporting Information about the individual that was disclosed to a Credit Provider by a CRB; and

(b) that has any bearing on the individual’s credit worthiness; and

CRB Derived Information about an individual means any Personal Information (other than Sensitive Information) about the individual:

(a) that is derived by a CRB from Credit Information about the individual that is held by the body; and

(b) that has any bearing on the individual’s credit worthiness; and

Credit Eligibility Information means Credit Reporting Information that was disclosed to Speedle by a CRB or CP Derived Information.

Credit Eligibility Information is generally held by a Credit Provider and may be disclosed to Affected Information Recipients and other entities in specific circumstances.

Credit Information means Personal Information (other than Sensitive Information) that is:

(a) identification information about an individual; or

(b) consumer credit liability information about an individual; or

(d) a statement that an information request has been made in relation to an individual by a Credit Provider, mortgage insurer or trade insurer; or

(e) the type of consumer credit or commercial credit, and the amount of credit, sought in an application:

(i) that has been made by an individual to a Credit Provider; and

(ii) in connection with which the provider has made an information request in relation to an individual; or

(f) default information about an individual; or

(g) payment information about an individual; or

(h) new arrangement information about an individual; or

(i) court proceedings information about an individual; or

(j) personal insolvency information about an individual; or

(k) publicly available information about an individual:

(i) that relates to an individual’s activities in Australia or the external Territories and the individual’s credit worthiness; and

(ii) that is not court proceedings information about an individual or information about an individual that is entered or recorded on the National Personal Insolvency Index; or

(l) the opinion of a Credit Provider that an individual has committed, in circumstances specified by the provider, a serious credit infringement in relation to consumer credit provided by the provider to the individual.

Credit Provider means:

(a) a bank;

(b) an organisation or SBO if a substantial part of the organisation or SBO’s business is the provision of credit, such as a building society, finance company or a credit union;

(d) an organisation or SBO that supplies goods and services where payment is deferred for seven (7) days or more, such as a telecommunications carriers and energy and water utilities; and

(e) certain organisations or SBOs that provide credit in connection with the hiring, leasing or renting of goods.

Importantly, the following entities are not Credit Providers:

(a) real estate agents;

(b) general insurers (within the meaning of the Insurance Act 1973 (Cth)); and

Credit Reporting Body (“CRB”) means an organisation whose business involves handling Personal Information in order to provide another entity with information about the credit worthiness of an individual.

Credit Reporting Information means Credit Information or CRB Derived Information about an individual.

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a) whether the information or opinion is true or not; and

(b) whether the information or opinion is recorded in a material form or not.

Sensitive Information means:

(a) information or an opinion about an individual’s:

(i) racial or ethnic origin; or

(ii) political opinions; or

(iii) membership of a political association; or

(iv) religious beliefs or affiliations; or

(v) philosophical beliefs; or

(vi) membership of a professional or trade association; or

(vii) membership of a trade union; or

(viii) sexual orientation or practices; or

(ix) criminal record;

(x) that is also Personal Information; or

(b) health information about an individual; or

(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or

(e) biometric templates.

Small Business Operators (“SBO”) means a person or organisation that has an annual turnover of $3,000,000 or less. For the purposes of the Privacy Act, health service providers or businesses that trade in Personal Information are not an SBO.

SECTION B – COLLECTION OF CREDIT INFORMATION AND CREDIT ELIGIBILITY INFORMATION

3. COLLECTION

3.1 Speedle will collect Credit Information and Credit Eligibility Information when it is reasonably necessary pursuant to one or more of its business functions or activities.

3.2 This may include:

(a) providing clients with the products and services they request and, unless Speedle is told otherwise, to provide information on products and services offered by Speedle and external product and service providers for whom Speedle acts as agent;

(b) complying with Speedle’s legal obligations;

(d) gathering and aggregating information for statistical, prudential, actuarial and research purposes;

(e) assisting clients with queries; and

(f) taking measures to detect and prevent fraud.

3.3 Speedle may at times collect and retain Credit Information and Credit Eligibility Information in accordance with the Privacy Act and CR Code.

3.4 The Credit Information Speedle may collect generally includes or consists of:

(a) a client’s full name, residential address (including previous addresses), contact details (including telephone and email addresses) and other identity verification emails;

(b) a client’s date of birth and gender;

(d) details of any credit provided to the client by other Credit Providers;

(e) any credit rating or credit assessment score that Speedle has derived or that is provided to Speedle by a CRB; and

(f) details of any credit-related court proceedings or insolvency applications that relate to the client.

3.5 The Credit Eligibility Information Speedle may collect generally includes or consists of:

(a) any of the types of credit information listed in 3.4 above which was disclosed to Speedle by a CRB under the Privacy Act;

(b) any Personal Information (other than Sensitive Information) about the client that is derived by a CRB from Credit Information about the client that is held by the body that has any bearing on the client’s credit worthiness and that is used or could be used in establishing the client’s eligibility for consumer credit; and

3.6 Speedle may also collect the number and ages of dependants, the length of time at the client’s current residential address, the current employer’s name and contact details, the length of employment, proof of earnings and, if the client has changed employer in the last few years, details of previous employment.

4. MEANS OF COLLECTION

4.1 Speedle must only collect Credit Information and Credit Eligibility Information by lawful and fair means.

4.2 Speedle collects Credit Information directly from clients, unless it is unreasonable or unpracticable to do so or the client has instructed an agent to act on their behalf.

4.3 Speedle will collect Credit Information from a client when:

(a) Speedle’s Application Form is completed;

(b) a client provides the information to Speedle’s representatives over the telephone or via email;

5. STORAGE OF CREDIT INFORMATION AND CREDIT ELIGIBILITY INFORMATION

5.1 Speedle stores Credit Information and Credit Eligibility Information in different ways, including:

(a) hard copy on site at Speedle’s head office;

(b) electronically secure data centres which are located in Australia and owned by either Speedle or external service providers;

5.2 In order to ensure Speedle protects any Credit Information and Credit Eligibility Information it holds from misuse, interference, loss, unauthorised access, modification and disclosure, Speedle implements the following procedures and systems:

(a) access to information systems is controlled through identity and access management;

(b) employees are bound by internal information security policies and are required to keep information secure;

(d) Speedle regularly monitors and reviews its compliance with internal policies and industry best practice.

5.3 Speedle may take reasonable steps to destroy or de-identify Credit Eligibility Information it holds about a client where:

(a) Speedle no longer needs the information for any purpose for which the information may be used or disclosed; and

(b) Speedle is not required under Australian law or Court/Tribunal Order to retain the information.

SECTION C – USE OF CREDIT INFORMATION AND CREDIT ELIGIBILITY INFORMATION

6. PERMITTED USE

6.1 Speedle may use the Credit Information and Credit Eligibility Information that is collected from clients to help Speedle to decide whether or not to provide credit to a client. Speedle may also use Credit Information and Credit Eligibility Information to derive or calculate a credit assessment score in relation to a client, which may be used to help in conducting an assessment of a client’s creditworthiness.

6.2 The Credit Information and Credit Eligibility Information that Speedle holds about clients is used:

(a) to assess any application for credit;

(b) to collect payments that are owed to Speedle in respect of any credit previously provided to a client;

(c) where the client has offered to guarantee credit that Speedle has offered to provide the client’s company or entity, to assess their suitability as a guarantor of that credit and to enforce that guarantee if required;

(d) to assess and respond to any access or correction requests;

(e) where Speedle is consulted by a CRB or another Credit Provider about an access or correction request that a client makes to those entities, to respond to that consultation request;

(f) where a client complains to the Office of the Australian Information Commissioner (“OAIC”) or the Australian Financial Complaints Authority (“AFCA”) about Speedle’s treatment of Credit Information and Credit Eligibility Information, to respond to that complaint and to seek legal or other professional advice in relation to such complaint; and

(g) where a client otherwise expressly consents to the use.

6.3 Where Speedle uses Credit Information and Credit Eligibility Information under section 6.2, Speedle must make a written note of that use.

7. DIRECT MARKETING

7.1 Speedle must not use or disclose the Credit Information or Credit Eligibility Information it holds about a client for the purpose of direct marketing.

SECTION D – DISCLOSURE OF CREDIT INFORMATION

8. NOTIFICATION OF COLLECTION

8.1 Speedle must notify the client of the name and contact details of the CRB at the time or before it collects Credit Information about a client that it will likely disclose to the CRB.

9. PERMITTED DISCLOSURE

9.1 The credit information that Speedle holds about clients can be disclosed to a CRB in the following circumstances:

(a) Speedle is a member of AFCA; and

(b) Speedle knows, or believes on reasonable grounds that the client is at least eighteen (18) years old; and

(d) the Credit Information disclosed meets the following requirements:

(i) the information does not relate to an act, omission, matter or thing that occurred or existed before the client turned eighteen (18) years old;

(ii) if the information relates to consumer credit or commercial credit – the credit is or has been provided, or applied for, in Australia;

(iii) if the information is about repayment history:

A. Speedle holds an Australian Credit Licence or id authorised under the National Consumer Credit Protection Act 2009 (Cth); and

B. the repayment information disclosed relates to consumer credit liability information about the client; and

(i) if the information relates to default information about the client:

A. Speedle has given the client a written notice stating it intends to disclose this information to a CRB; and

B. at least fourteen (14) days have passed since the notice was given. If the client has paid the overdue amount after the disclosure has been made, Speedle must, within a reasonable amount of time, disclose the payment information to the CRB.

9.2 Where Speedle discloses Credit Information to a CRB under this section 9, Speedle must make a written note of that use.

SECTION E – DISCLOSURE OF CREDIT ELIGIBILITY INFORMATION

10. PERMITTED DISCLOSURE

10.1 The Credit Eligibility Information that Speedle holds about clients can be disclosed:

(a) to any of Speedle’s related companies;

(b) where the disclosure is to:

(i) a person for the purposes of processing an application for credit made with Speedle; or

(ii) a person who manages credit provided by [insert defined company name[ for the use in managing that credit;

(i) a third party that the client or Speedle has asked to act as a guarantor of any credit provided; and

(ii) the third party has an Australian link; and

(iii) the client has expressly consented in writing to the disclosure of Credit Eligibility Information;

(d) to a mortgage insurer with an Australian Link for the purposes of obtaining mortgage insurance or arising under a contact for mortgage insurance;

(e) where the disclosure is to:

(i) another Credit provider or agent of another Credit Provider for a particular purpose; and

(ii) the Credit Provider or agent has an Australian Link; and

(iii) the client has expressly consented in writing the disclosure of Credit Eligibility Information;

(f) where both of the following apply:

(i) Speedle believes on reasonable grounds that the client has committed a serious credit infringement; and

(ii) Speedle discloses the information to another Credit Provider that has an Australian Link or to an enforcement body;

(g) where the disclosure is to:

(i) a third party that carries on a business or undertaking that involves the collection of debt on behalf of Speedle; and

(ii) the primary purpose of disclosure is for collecting payments that are overdue; and

(iii) the Credit Eligibility Information provided is limited to:

A. identification information about the client; or

B. court proceedings information about the client; or

C. personal insolvency information about the client; or

D. default information about the client.

(h) where both of the following apply:

(i) the disclosure is to the OAIC or AFCA; and

(ii) Speedle is a member of AFCA; and

(i) the disclosure is required by Australian Law or Court/Tribunal Order.

SECTION F – CROSS BORDER DISCLOSURE OF INFORMATION

11. DISCLOSING PERSONAL INFORMATION TO CROSS BORDER RECIPIENTS

11.1 Where Speedle discloses Credit Information or Credit Eligibility Information about a client to a recipient who is not in Australia, Speedle must ensure that the overseas recipient does not breach the Australian Privacy Principles (with the exception of APP1).

11.2 The countries Speedle may disclose to include:

(a) Australia; and

(b) New Zealand.

11.3 Section 11.1 does not apply where:

(a) Speedle reasonably believes that:

(i) information is subject to a law or binding scheme that has the effect of protecting the information in a way that is at least substantially similar to the way in which the Australian Privacy Principles protect the information; and

(ii) there are mechanisms that the client can access to take action to enforce that protection of the law or binding scheme; or

(b) both of the following apply:

(i) Speedle has informed the client that if they consent to the disclosure of information Speedle will not take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles; and

(ii) after being so informed, the client consents to disclosure;

(c) the disclosure of the information is required or authorised by or under an Australian law or a Court/Tribunal Order; or

(d) a Permitted General Situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) of the Privacy Act) exists in relation to the disclosure of the information by Speedle.

SECTION G – ACCESS TO CREDIT ELIGABILITY INFORMATION

12. ACCESS

12.1 Speedle must give a client access to the Credit Eligibility Information it holds about a client if so requested.

12.2 Speedle must respond to any request for access to Credit Eligibility Information within thirty (30) calendar days after the request is made.

12.3 Speedle must not provide access without first obtaining evidence to satisfy itself as to the identity of the client making the request and the person’s entitlement under the Privacy Act and CR Code to access.

12.4 Speedle must give access to the Credit Eligibility Information in the manner requested by the client, if it is reasonable and practicable to do so and must take such steps as are reasonable in the circumstances to give access in a way that meets the needs of Speedle and the client.

12.5 Speedle must present the information clearly and accessibly and provide reasonable explanations and summaries of the information to assist the client to understand the impact of the information on the client’s credit worthiness.

12.6 Speedle must not charge a client for making a request and must not impose excessive charges for the client to access their Credit Eligibility Information.

13. EXCEPTIONS

13.1 Speedle is not required to give a client access to their Credit Eligibility Information if:

(a) giving access would be unlawful; or

(b) denying access is required or authorised by or under an Australian law or a Court/Tribunal order; or

(c) giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

14. REFUSAL TO GIVE ACCESS

14.1 If Speedle refuses to give access in the manner requested by the client, Speedle will give the client a written notice that sets out:

(a) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and

(b) the mechanisms available to complain about the refusal to the OAIC or AFCA.

SECTION H – CORRECTION OF CREDIT INFORMATION AND CREDIT ELIGABILITY INFORMATION

15. CORRECTION

15.1 Speedle must take reasonable steps to correct all Credit Information and Credit Eligibility Information having regard to the purpose for which the information is held where:

(a) Speedle is satisfied the information is inaccurate, out of date, incomplete, irrelevant or misleading; or

(b) the client requests Speedle corrects the information within thirty (30) days of the request being made.

15.2 Speedle must not charge a client for making a request and correcting the Credit Information or Credit Eligibility Information.

16. NOTICE OF CORRECTION

16.1 Where Speedle has previously disclosed Credit Information or Credit Eligibility Information it has corrected, Speedle will, within a reasonable period provide each recipient a written notice of the correction.

SECTION I – COMPLAINTS

17. POLICY

17.1 Speedle has internal procedures in place to deal with client complaints, through the Dispute Resolution Policy.

18. RECEIVING COMPLAINTS

18.1 Speedle’s employees must immediately refer clients wishing to make a complaint to the Compliance Officer. This ensures that wherever possible, the complaint will be investigated by a staff member not involved in the subject matter of the complaint.

18.2 On receiving a complaint, the following information must be recorded:

(a) date of complaint;

(b) name of client;

(d) format of complaint (phone/email/letter/fax);

(e) preferred contact method of client (phone/email/letter/fax);

(f) details of the complaint; and

(g) classification of the complaint (Refer to section 20).

18.3 Once the complaint is received, the Compliance Officer must acknowledge receipt of the complaint within seven (7) calendar days using the preferred contact method of the client and attempt to resolve the complaint within thirty (30) calendar days of it being received.

19. COMPLAINTS RECEIVED OVER THE PHONE

19.1 The following procedure must be followed when a complaint is received orally:

(a) identify yourself, listen, record details and determine what the client wants;

(b) confirm the details received;

(d) explain the courses of action available;

(e) do not attempt to lay blame or be defensive;

(f) resolve the complaint if possible or commit to doing something immediately, irrespective of who will ultimately handle the complaint;

(g) don’t create false expectations;

(h) inform the client of the name and contact details of the person who will be formally dealing with the complaint (i.e. the Compliance Officer);

(i) refer the matter immediately to the Compliance Officer (even if you resolved the matter); and

(j) record the details in the complaints register.

20. CLASSIFICATION OF COMPLAINTS

20.1 All complaints must be classified by Speedle and then analysed to identify systemic, recurring and single incident problems and trends.

20.2 Level 1 – the least serious complaints. The complaint could not be resolved at first contact with the client. Some complaints at this level will require the assistance of other employees at Speedle. The complaint can be resolved without escalating it to the Compliance Officer.

20.3 Level 2 – more serious complaints. The Compliance Officer must be informed of the complaint and may provide input where necessary to help resolve the complaint.

20.4 Level 3 – the most serious complaints. This type of complaint will require the involvement of the Compliance Officer.

21. RESPONSIBILITY FOR AND INVESTIGTION OF COMPLAINTS

21.1 At first instance the Compliance Officer is responsible for dealing with complaints.

21.2 If the Compliance Officer is unable to resolve the complaint within thirty (30) calendar days, a letter or email must be provided before the end of the period which:

(a) informs the client of the reasons for the delay;

(b) the expected timeframe to resolve the complaint;

(c) seeks the client’s agreement to an extension period that is reasonable in the circumstances to resolve the complaint; and

(d) advise the client that they may contact AFCA or the OAIC and provide the relevant contact details.

22. RESOLUTION OF COMPLAINTS

22.1 When an outcome is reached for a complaint, the client needs to be advised of the final response by email, fax or letter.

23. COMPAINTS REGISTER

23.1 A Complaints Register is to be compiled and managed by the Compliance Officer.

23.2 A copy of the Complaints Register is to be provided to the Compliance Officer prior to the quarterly meeting of the Compliance Committee.

23.3 The Compliance Officer must maintain a soft copy record of the Complaints Register on file.

24. IDENTIFIYING AND RECORDING SYSTEMIC ISSUES

24.1 The Compliance Officer should aim to identify any systemic issues or recurring complaints as a result of compiling the Complaints Register.

24.2 Where any systemic issues or recurring complaints are identified, these should be addressed to the Compliance Officer by preparing a report to accompany the Complaints Register. The issues will be included in the Compliance Report presented at the next Compliance Committee Meeting. This will encourage the identification of compliance issues or risks, which can be investigated to determine their causes and then rectified.

25. EXTERNAL DISPUTE RESOLUTION SCHEME

25.1 Speedle is a member of AFCA. AFCA is the External Dispute Resolution (“EDR”) Scheme approved by ASIC.

25.2 This external and impartial service is available to clients free of charge. It has jurisdiction to hear and resolve any dispute that is not resolved by Speedle’s Internal Dispute Resolution process.

25.3 The external and impartial process will apply the law and may take into account what is fair in all the circumstances to both the client and Speedle.

25.4 Speedle has a guide for clients that includes reference to the availability of this EDR mechanism.

SECTION J – RECORD KEEPING

26. DOCUMENT RETENTION POLICY

26.1 In accordance with Speedle’s Document Retention Policy, Speedle will maintain adequate records that evidence their compliance with Part IIIA of the Privacy Act, Privacy Regulations and CR Code for a minimum period of five (5) years.

27. TYPE OF RECORDS

27.1 Speedle is required to maintain the following records:

(a) information where credit-related personal information is destroyed to meet obligations under Part IIIA of the Privacy Act, the Privacy Regulations and CR Code (if possible);

(b) where Speedle receives Credit Eligibility Information disclosed to it by another Credit Provider:

(i) the date on which the information was disclosed;

(ii) the Credit Provider who disclosed the information;

(iii) a brief description of the type of information disclosed; and

(iv) evidence relied upon that the consent requirements have been met;

(i) the date on of the disclosure;

(ii) a brief description of the type of information disclosed; and

(iii) evidence that the disclosure was permitted under Part IIIA of the Privacy Act, the Privacy Regulations and CR Code;

(d) records of any consent provided by a client for the purposes of Part IIIA of the Privacy Act, the Privacy Regulations and CR Code;

(e) records of any written notice given to a client stating that a consumer credit application has been refused within ninety (90) days of disclosure by a CRB to Speedle of Credit Reporting Information in relation to that client; and

(f) records of correspondence and actions taken in relation to:

(i) requests to establish or extend a ban period;

(ii) request for, or notifications of, corrections;

(iii) complaints;

(iv) pre-screening requests by Speedle; and

(v) monitoring and auditing of Speedle in accordance with Part IIIA of the Privacy Act, the Privacy Regulations and CR Code.

SECTION K – CONCLUSION

28. POLICY BREACHES

28.1 Breaches of this Policy may lead to disciplinary action being taken against the relevant party, including dismissal in serious cases and may also result in prosecution under the law where that act is illegal. This may include re-assessment of bonus qualification, termination of employment and/or fines (in accordance with the Privacy Act).

28.2 Staff are trained internally on compliance and their regulatory obligations to Speedle. They are encouraged to respond appropriately to and report all breaches of the law and other incidents of non-compliance, including Speedle’s policies, and seek guidance if they are unsure.

28.3 Staff must report breaches of this Policy directly to the Director.

29. POLICY REVIEW

29.1 This Credit Reporting Policy will be reviewed on at least an annual basis by the Compliance Officer having regard to the changing circumstances of Speedle. The Compliance Officer will then report to the Director on compliance with this Policy.

Issued by Speedle Pty Limited – 15 January 2024

‍

Privacy Statement

Updated on

January 15, 2024

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SECTION A – INTRODUCTION

1. INTRODUCTION

1.1 This document is the Privacy Statement of Speedle Pty Limited ABN: 86 668 001 045 (“Speedle, we or us”).

1.2 The purpose of this Privacy Statement is to tell you how we collect, use, hold, disclose and protect your Personal Information.

1.3 Please refer to Speedle’s Credit Reporting Statement for information about how we manage your Personal Information collected in connection with a credit application or facility.

1.4 We will act to protect your Personal Information in accordance with the Australian Privacy Principles (“APP”) and the Privacy Act 1988 (Cth) (together “Privacy Laws”).

1.5 Please always check the privacy policy page on our website regularly at the following link for amendments and updates to our Privacy Statement and Credit Reporting Statement: www.speedle.com.au

1.6 This Privacy Statement does not cover information that you submit on other websites, even if we communicate with you on those sites. For example, if contact us via Instagram, Facebook, Pinterest, Twitter, or YouTube, that information is governed by the privacy policies on those websites and is not governed by this Privacy Statement.

SECTION B – INFORMATION WE MAY COLLECT

2. WHAT IS PERSONAL INFORMATION?

2.1 Personal Information is any information or opinion about you that is capable, or reasonably capable, of identifying you, whether the information or opinion is true or not and is recorded in material form or not. Personal Information includes Sensitive Information.

2.2 Sensitive Information includes such things as your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record, that is also personal information. Your health, genetic and biometric information and biometric templates are also Sensitive Information.

2.3 We will only collect Sensitive Information about you if we obtain prior consent to the collection of the information or if the collection is required or authorised by law.

2.4 WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?

2.5 The Personal Information we collect and hold generally includes or consists of:

(a) identification information such as your name, postal or email address, telephone numbers and date of birth;

(b) other contact details such as social media handles;

(d) financial and transactional information;

(e) health and biometric information (where permitted);

(f) information about how you interact with us when you use our website (such as device information - which browser you use and your operating system language, your location or activity including IP address and geolocation data based on the GPS of your mobile device (when accessing our services) and whether you’ve accessed third party sites); and

(g) other information we think is necessary.

2.6 Over the course of our relationship with you, we may collect and hold additional pieces of Personal Information about you, including transactional information, account or policy information, complaint or enquiries about your product or service.

2.7 We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) (“Anti-Money Laundering Laws”) require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) in order to meet the standards set under those laws.

2.8 You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific to an account or relates to your Personal Information, we will need to identify you before we can engage in further discussions and correspondence.

SECTION C – CONSENT

3. CONSENT

3.1 In most cases, before or at the time of collecting your Personal Information, we will obtain your consent for the purposes for which we intend to use and disclose your Personal Information.

3.2 If you don’t give us consent, we may not be able to provide you with the products or services you want. This is because we are required to collect this Personal Information to provide you with the products or services.

4. WITHDRAWING CONSENT

4.1 Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact us. Please note that withdrawing your consent may lead to us no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.

SECTION D – WHEN AND HOW WE COLLECT PERSONAL INFORMATION

5. HOW DO WE COLLECT PERSONAL INFORMATION?

5.1 We collect most Personal Information about you directly from you whether in person, over the phone or electronically. For example:

(a) when you apply for, register your interest in or enquire about a product or service;

(b) when you provide us with feedback or make a complaint;

(d) when you talk to us or do business with us;

5.2 We may collect Personal Information about you from others, such as from:

(a) service providers;

(b) agents;

(d) employers; or

(e) family members.

5.3 We may take steps to verify the information we collect for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation, or we may verify with an employer that employment and remuneration information provided in an application for credit is accurate.

6. DO WE COLLECT INFORMATION ELECTRONCIALLY?

6.1 We may collect information from you electronically through internet browsing on our websites.

6.2 Each time you visit our websites, we may collect information about you which may include Personal Information (which will be de- identified) and may include the following:

(a) the date and time of visits;

(b) the pages viewed and your browsing behaviour;

(c) how you navigate through the site and interact with pages (including fields completed in forms and applications completed);

(d) general location information;

(e) information about the device used to visit our website (including your tablet or mobile device) such as device IDs; and

(f) IP addresses.

6.3 We collect information using cookies when you use our website. Cookies are small pieces of information stored on your hard drive or in memory. One of the reasons for using cookies is to offer you increased security. They can also record information about your visit to our websites, allowing us to remember you the next time you visit and provide a more meaningful experience.

6.4 We may also collect information from third party websites, applications or platforms containing our interactive content or that interface with our own website such as Google Analytics.

6.5 We may collect Personal Information about you from social media platforms if you publicly comment. We will NEVER ask you to supply Personal Information publicly over any social media platforms that we use. We may, invite you to send your details to us via private messaging, for example, to answer a question about your account. You may also be invited to share your Personal Information through secure channels to participate in other activities, such as online competitions.

7. HOW DO WE DEAL WITH UNSOLICITED PERSONAL INFORMATION?

7.1 If we receive Personal Information that is not solicited by us, we will only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.

7.2 If these conditions are not met, we will destroy or de-identify the information.

7.3 If such unsolicited information is Sensitive Information, we will obtain your consent to retain it regardless of what the circumstances are.

SECTION E – PURPOSES FOR COLLECTING, USING AND DISCLOSING PERSONAL INFORMATION

8. WHY DO WE COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION?

8.1 We collect, use and disclose your Personal Information so we can:

(a) consider your request for products and services, including your eligibility;

(b) process your application and provide you with the products and services;

(d) confirm your identity;

(e) manage our relationship with you;

(f) complying with our legal obligations;

(g) monitor and evaluate products and services;

(h) gather and aggregate information for statistical, prudential, actuarial and research purposes;

(i) assist you with queries;

(j) take measures to detect and prevent fraud;

8.2 We may not be able to provide you with the products or services you are seeking if you provide incomplete or inaccurate information.

SECTION F – INTEGRITY OF YOUR INFORMATION

9. QUALITY OF INFORMATION

9.1 We ensure that the Personal Information we collect, use or disclose is accurate, up to date, complete and relevant.

9.2 Please contact us if any of the details you have provided to us change or if you believe that the information we have about you is not accurate or up to date.

9.3 We may also take steps to update information we hold, for example, an address, by collecting Personal Information from publicly available sources such as telephone directories or electoral rolls.

10. HOW DO WE PROTECT AND HOLD YOUR PERSONAL INFORMATION?

10.1 We are committed to ensuring that we protect any Personal Information we hold from misuse, interference, loss, unauthorised access, modification and disclosure.

10.2 For this purpose, we have a range of practices and policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.

10.3 We have the following security measures in place to protect against misuse, loss and alteration of Personal Information under our control. Our security measures include, but are not limited to:

(a) educating our staff as to their obligations with regard to your personal information;

(b) requiring our staff to use passwords when accessing our systems;

(c) encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;

(d) employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;

(e) using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;

(f) providing secure storage for physical records; and

(g) employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.

10.4 Where Personal Information we hold is identified as no longer needed for any purpose, we ensure it is effectively and securely destroyed, for example, by shredding or pulping in the case of paper records or by degaussing (demagnetise of the medium using alternating electric currents) and other means in the case of electronic records and equipment.

10.5 The Personal Information retained by us could include transactional and financial information along with contact details. The Personal Information does include the records that have been stored on the secure server. Where we retain adequate records for legal and accounting purposes, the Personal Information will be stored and held securely in controlled facilities.

SECTION G – DISCLOSURE OF PERSONAL INFORMATION

11. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

11.1 We may share your Personal Information with third parties to help deliver or support the provision of products or services to you.

11.2 In all circumstances where your Personal Information may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose Personal Information for any purposes other than our own.

11.3 We take our obligations to protect your Personal Information very seriously we make every effort to deal only with parties who share and demonstrate the same attitude.

11.4 Depending on the product or service you have, the entities we exchange your Personal Information with include but are not limited to:

(a) brokers and agents;

(b) affiliated product and service providers and external product and service providers for whom we act as agent (so that they may provide you with the product or service you seek or in which you have expressed an interest);

(d) any person acting on your behalf, including your solicitor, settlement agent, accountant, executor, administrator, trustee or guardian;

(e) your referee (to confirm details about you);

(f) if required or authorised to do so, regulatory bodies and government agencies;

(g) credit reporting bodies;

(h) debt collectors;

(i) insurers, including proposed insurers and insurance reference agencies (where we are considering whether to accept a proposal of insurance from you and, if so, on what terms);

(j) medical practitioners (to verify or clarify, if necessary, any health information you may provide);

(k) other financial institutions and organisations at their request if you seek credit from them (so that they may assess whether to offer you credit);

(l) investors, advisers, trustees and ratings agencies where credit facilities and receivables are pooled and sold (securitised);

(m) other organisations who in conjunction with us provide products and services (so that they may provide their products and services to you); and

(n) professional associations or organisations with whom we conduct an affinity relationship (to verify your membership of those associations or organisations).

11.5 We may also disclose your Personal Information to others where:

(b) you may have expressly consented to the disclosure or your consent may be reasonably inferred from the circumstances; or

12. DO WE DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?

12.1 We may utilise overseas service providers for some of our activities. These service providers may be located in:

(a) Australia; and

(b) New Zealand.

12.2 We will only disclose your Personal Information when permitted to do so by the Privacy Act and after we ensure that:

(a) the overseas recipient does not breach the APPs; or

(c) you have consented to the disclosure after we expressly informed you that there is no guarantee that the overseas recipient will not breach the APPs; or

(d) the disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order.

12.3 We may store your Personal Information in cloud-based software or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your Personal Information may be held. If your Personal Information is stored in this way, disclosures may occur in countries other than those listed.

12.4 Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

13. DO WE USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

13.1 We will only use or disclose the Personal information we hold about you for the purpose of direct marketing if we have received the Personal Information from you and you have not requested not to receive such information.

13.2 Direct marketing includes, but is not limited to, contacting our clients to provide you with information on our products and services that may interest you.

13.3 If you wish to opt-out of receiving marketing information altogether, you can:

(a) call us on 02 8365 2322; or

(b) write to us at privacy@speedle.com.au.

13.4 In direct marketing communication we always inform you of your right to opt out of receiving direct marketing communications.

SECTION H – ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

14. HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION?

14.1 You can request us to provide you with access to the Personal Information we hold about you.

14.2 Requests for access to limited amounts of Personal Information, such as checking to see what address or telephone number we have recorded, can generally be handled over the telephone.

14.3 If you would like to request access to more substantial amounts of Personal Information such as details of what is recorded in your account file, we will require you to complete and sign a “Request for Access” form.

14.4 Following receipt of your request, we will provide you with an estimate of the access charge and confirm that you want to proceed.

14.5 We will not charge you for making the request for access, however access charges may apply to cover our costs in locating, collating and explaining the information you requested.

14.6 We will respond to your request as soon as possible and in the manner requested by you. We will endeavour to comply with your request within fourteen (14) days of its receipt but, if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within thirty (30) days. It will help us provide access if you can tell us what you are looking for.

14.7 Your identity will be confirmed before access is provided.

15. CAN WE REFUSE TO GIVE ACCESS?

15.1 In particular circumstances we are permitted by law to deny your request for access or limit the access we provide. We will let you know why your request is denied or limited if this is the case. For example, we are not required to give you access where giving you access to your Personal Information would pose a serious threat to any person’s life, health or safety or giving access would be unlawful or where we reasonably conclude your request to be frivolous or vexatious.

15.2 If we refuse to give access to the Personal Information or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.

16. CORRECTION

16.1 We are committed to and will take all reasonable steps in respect of maintaining accurate, timely, relevant, complete and appropriate information about our clients, website users and other people that we deal with in our business

16.2 We will correct all Personal information that we believe to be inaccurate, out of date, incomplete, irrelevant or misleading given the purpose for which that information is held or if you request us to correct the information.

16.3 If we correct your Personal Information that we previously disclosed to another APP entity you can request us to notify the other APP entity of the correction. Following such a request, we will give that notification unless it is impracticable or unlawful to do so.

16.4 We will respond to any requests for correction within a reasonable time of receipt of the request. A reasonable time period will be no longer than thirty (30) days after the request being received.

17. REFUSAL TO CORRECT INFORMATION

17.1 If we refuse to correct the Personal Information as requested by you, we will give you a written notice setting out the reasons for the refusal. Such reason will set out the grounds for refusal, the mechanisms available to complain and any other relevant matter.

18. REQUEST TO ASSOCIATE A STATEMENT

18.1 If we refuse to correct the Personal Information as requested by you, you can request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then associate the statement in such a way that will make the statement apparent to users of the information.

SECTION I – NOTIFIABLE DATA BREACHES

19. NOTIFIABLE DATA BREACHES SCHEME

19.1 From February 2018, the Privacy Act includes a new Notifiable Data Breaches (“NDB”) scheme which requires us to notify you and the Office of the Australian Information Commissioner (“OAIC”) of certain data breaches that is likely to result in serious harm to affected individuals and provide recommendations of steps you can take to limit the impacts of the breach.

19.2 If we believe there has been a data breach that impacts your Personal Information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.

19.3 If you believe that any Personal Information we hold about you has been impacted by a data breach, you can contact us using the contact details set out as per clause 21 below.

SECTION J – MAKING A PRIVACY COMPLAINT

20. COMPLAINTS

20.1 We offer a free internal complaint resolution scheme to all of our customers. Should you have a privacy complaint, please contact us to discuss your concerns. Our contact details set out as per clause 21 below.

20.2To assist us in helping you, we ask you to follow a simple three-step process:

(a) gather all supporting documents relating to the complaint;

(b) contact us and we will review your situation and if possible, resolve your complaint immediately; and

(c) if the matter is not resolved to your satisfaction, please contact our Compliance Officer on 02 8365 2322 or put your complaint in writing and send it to Speedle, Level 22-23, Salesforce Tower, 180 George Street Sydney NSW 2000.

20.3 We will rectify any breach if the complaint is justified and will take necessary steps to resolve the issue.

20.4 In certain situations, to deal with a complaint it may be necessary to consult with third parties. However, please note any disclosure of Personal Information to third parties will be provided with your authority and consent.

20.5 After a complaint has been received, we will send you a written notice of acknowledgement setting out the process. The complaint will be investigated, and the decision will be sent to you within thirty (30) days unless you have agreed to a longer time. If a complaint cannot be resolved within the agreed time frame or a decision could not be made within thirty (30) days of receipt, a notification will be sent out to you setting out the reasons and specifying a new date when you can expect a decision or resolution.

20.6 If you are not satisfied with our internal privacy practices or the outcome in respect to complaint, you may approach the OAIC with your complaint:

Office of the Australian Information Commissioner

Address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Website: oaic.gov.au

SECTION K – CONTACT US

21. CONTACT DETAILS

21.1 If you have any questions or would like further information about our privacy, credit reporting and information handling practices, please contact us by:

(a) Email privacy@speedle.com.au ;or

(b) Phone: 02 8365 2322

‍

Feedback and complaints

Updated on

January 15, 2024

Download PDF

1. INTRODUCTION

1.1 Speedle Pty Limited (“Speedle, we or us”) is committed to effective and efficient complaints management and to fair and transparent dealings in the financial marketplace

1.2 A complaint is an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

2. OUR COMPLAINTS MANAGEMENT PROCESS

2.1 We take your feedback seriously and will work proactively to investigate and resolve your complaint. If you have a complaint, please contact us by any of the following methods:

(a) Email: complaints@speedle.com.au;

(b) Telephone: 02 8365 2322;

2.2 If your complaint is about hardship or the postponement of enforcement proceedings, please contact us by:

(a) Email: complaints@speedle.com.au;

(b) Telephone: 02 8365 2322;

2.3 Any material relating to [insert defined company name]’s Internal Dispute Resolution (“IDR”) process will be provided to you free of charge.

2.4 We will collect certain information from you, including:

(a) Your name;

(b) Your contact details;

(d) A description of your complaint; and

(e) How you would like the complaint resolved.

2.5 We will acknowledge your complaint, generally within one (1) business day, and give you the contact details of the person responsible for dealing with your complaint.

2.6 The person responsible for dealing with your complaint will commence their investigation and may require further details from you. Upon completion of their investigation, the person responsible for dealing with your complaint will contact you with an IDR response. This will provide you with information about:

(a) the final outcome of your complaint at IDR; and

(b) your right to take the complaint to the Australian Financial Complaints Authority (“AFCA”) if you are not satisfied with the IDR response and how to contact AFCA.

2.7 Except where your complaint involves hardship, an IDR response is not required to be provided to you when a complaint is resolved by the end of the fifth (5th) business day of receipt of the complaint, where we have:

(a) resolved the complaint to your satisfaction; or

(b) given you an explanation and/or apology when no further action to reasonably address the complaint can be taken.

2.8 A written response will be provided if:

(a) you request a written response; or

(b) the complaint is about hardship.

3. TIMEFRAME FOR RESOLVING COMPLAINTS

3.1 We endeavour to resolve all complaints as quickly as practicable. Many complaints can be resolved within days or on the spot. We will keep you informed in relation to your dispute and will provide you with an IDR response within the following timeframes:

Type of Complaint / Maximum Timeframe to provide IDR Response

Complaints involving default notices = No later than twenty-one (21) calendar days after receiving the complaint.

Complaints involving applications for hardship notices or a request for postponement of enforcements proceedings made = No later than twenty-one (21) calendar days after receiving the complaint. Exceptions apply where we do not have sufficient information to make a decision or if an agreement is reached with you.

All other complaints = No later than thirty (30) calendar days after receiving the complaint.

4. IF YOU ARE UNHAPPY WITH OUR RESPONSE

4.1 If your complaint is not resolved to your satisfaction through our IDR process, you have the right to refer your complaint to AFCA. AFCA is an independent and external dispute resolution scheme, of which Speedle is a member.

4.2 You can lodge your complaint with AFCA by sending the relevant information and documents to:

Australian Financial Complaints Authority Limited

GPO Box 3

Melbourne VIC 3001

Phone: 1800 931 678

Fax: (03) 9613 6399

Email: info@afca.org.au

Website: https://www.afca.org.au/

5. ACCESSIBILITY SERVICES

5.1 We take our commitment to provide accessible services to customers seriously.

5.2 If you require this Policy is another language, please contact us at the details below.

6. CONTACT US

6.1 If you have any questions or would like further information about our complaints handling process, please contact us by:

(a) Email: complaints@speedle.com.au;

(b) Telephone: 02 8365 2322;

‍

Dispute Resolution Process

Updated on

January 15, 2024

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SECTION A – INTRODUCTION

1. PURPOSE

1.1 The purpose of Speedle Pty Limited (“Speedle’s”) Dispute Resolution Policy (“Policy”) is to ensure Consumer Complaints in respect of financial services are dealt with promptly, fairly and consistently.

1.2 This Policy represents Speedle’s commitment to effective and efficient Complaints handling and to fair and transparent dealings in the financial marketplace.

1.3 The standards and requirements set out in the ASIC Corporations, Credit and Superannuation (Internal Dispute Resolution) Instrument 2020/98 as outlined in this Policy are enforceable.

2. POLICY STATEMENT

2.1 Speedle must have a Dispute Resolution system that consists of:

(a) an Internal Dispute Resolution (“IDR”) process that complies with the standards and requirements made or approved by ASIC that cover Complaints made by Consumers in relation to the credit services provided; and

(b) membership of AFCA.

2.2 The benefits of effectively resolving Consumer Complaints through an IDR system with broad coverage include:

(a) the opportunity to resolve Complaints quickly and directly;

(b) the promotion of trusted relationships between Speedle and its Consumers;

(d) a greater understanding of the key drivers of Complaints;

(e) the ability to identify emerging issues and inform product and service delivery improvements; and

(f) reduced AFCA fees and future remediation costs.

2.3 Speedle takes a proactive approach to identifying and resolving Complaints. It is better for Speedle and its Consumers that a Complaint is dealt with at the earliest possible stage because it:

(a) prevents Complaints from becoming entrenched;

(b) preserves Consumer relations;

(d) may improve customer satisfaction.

2.4 When reviewing and establishing this Policy, Speedle has taken into account:

(a) the size of its business and the number of people in the organisation;

(b) the products and services offered and the volume and size of transactions Speedle is responsible for;

(d) the diversity and structure of its operations; and

(e) the likely number and complexity of Complaints.

3. AIMS

3.1 This Policy aims to resolve minor Complaints during the Consumer’s initial contact with Speedle.

3.2 To action all other Complaints, however received, within 21 calendar days of them being received.

3.3 To resolve all Complaints and provide an IDR response no later than thirty (30) calendar days after receipt of a Complaint.

4. DEFINITIONS

4.1 AFCA means the Australian Financial Complaints Authority, an Australian Securities and Investments Commission (“ASIC”) approved EDRS.

4.2 Complaint means an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a Complaint, where a response or resolution is explicitly or implicitly expected or legally required.

4.3 Consumer means a Consumer as defined by section 5 of the NCCP Act and for the purposes of this Policy, includes Small Businesses.

4.4 EDRS means External Dispute Resolution Scheme.

4.5 IDR Response means a written response to the Consumer informing them of:

(a) the final outcome of their Complaint at IDR (including either confirmation of actions taken by Speedle to fully resolve the Complaint or reasons for Speedle’s rejection or partial rejection of the Complaint;

(b) their right to take their Complaint to AFCA if they are not satisfied with Speedle’s with the outcome at (a); and

4.6 Speedle means Speedle Pty Limited.

4.7 NCCP Act means the National Consumer Credit Protection Act 2009 (Cth).

4.8 Small Business means, for the purposes of dispute resolution, a business that had less than one hundred (100) employees at the time of the act or omission by Speedle that gave rise to the Complaint. A small business includes a primary producer, if that primary producer is also a small business.

4.9 Unreasonable Consumer Conduct means behaviour which because of its nature or frequency raises substantial health, safety, resource or equity issues for Speedle, its employees and representatives, other Consumers or the particular Consumer themselves.

5. DEFINITION OF COMPLAINT

5.1 Speedle must deal with expressions of dissatisfaction that meet the definition of Complaint as specified in section 4.

5.2 The following expressions of dissatisfaction are included in the definition of Complaint:

(a) posts on a social media channel or account owned or controlled by Speedle that is subject of the post, where the author is both identifiable and contactable; and

(b) Complaints about a matter that is subject of an existing remediation program or about the remediation program itself.

5.3 Speedle does not limit its categorisation of Complaints to those expressions of dissatisfaction where a response or resolution is explicitly expected. Speedle also categorises expressions of dissatisfaction where a response or resolution is ‘implicitly expected’ as a Complaint.

6. SPEEDLE’S COMMITMENT TO IDR

6.1 Speedle’s Director ensures they:

(a) have adequate oversight of Speedle’s IDR processes;

(b) provide adequate resources to Speedle’s employees who have responsibility for managing Complaints including but not limited to providing ongoing training and appropriate human resources;

(d) implement IT systems and reporting procedures to ensure timely and effective Complaint management and monitoring; and

(e) establish clear roles, responsibility and authority for the management and resolution of Complaints.

7. COMPLAINTS MANAGEMENT POLICY

7.1 Speedle must ensure that Speedle’s Complaints Management Policy is available free of charge. Speedle’s Complaints Management Policy is available on its website.

7.2 If the Complaints Management Policy is requested in a particular form, Speedle takes such steps as are reasonable to provide the Complaints Handling Policy in the form requested.

SECTION B – PROCEDURES: RECEIVING COMPLAINTS

8. ENABLING COMPLAINTS

8.1 Speedle publicises information about how and where Complaints can be made by:

(a) publishing its Complaints Management Policy on Speedle’s website and making the Complaints Management Policy available in hard copy free of charge upon request;

(b) including information about the IDR process in product welcome packs;

(d) providing training to all staff about Speedle’s IDR process.

8.2 Where appropriate, Speedle makes its IDR process accessible for Consumers with disabilities or language difficulties by:

(a) Speedle proactively identifying Consumers who might need additional assistance;

(b) ensuring that information provided to the public about Speedle’s IDR process is available in a range of languages and formats (including large print, Braille or audiotape);

(d) offering translation services to Consumers or making staff available who are cross-culturally trained.

8.3 Speedle offers multiple Complaint lodgement methods including:

(a) telephone number;

(b) email;

(d) social media platforms owned or controlled by Speedle;

(e) in person; or

(f) online.

8.4 Speedle allows representatives of the Consumer to lodge Complaints on the Consumer’s behalf and accepts authorities from representatives lodging Complaints on behalf of Consumers. In these circumstances, Speedle does not contact the Consumer directly, unless:

(a) the Consumer requests direct communication with Speedle;

(b) Speedle reasonably believes the representative is not acting in the Consumer’s best interests;

(c) Speedle reasonably believes the representative is acting in a deceptive or misleading manner with the Consumer and/or Speedle;

(d) Speedle reasonably believes the representative is not authorised to represent the Consumer; and

(e) at the time insert defined company name] is dealing with the Complaint, the representative has been excluded by AFCA from representing Consumers in relation to a Complaint lodged with AFCA.

9. RECEIVING COMPLAINTS

9.1 Speedle’s employees must immediately refer Consumers wishing to make a Complaint to the Complaints Officer. This ensures that wherever possible, the Complaint is investigated by a staff member not involved in the subject matter of the Complaint.

9.2 On receiving a Complaint, the following information must be recorded:

(a) Date of Complaint;

(b) Name of Consumer;

(d) Contact details of Consumer;

(e) Format of Complaint (phone / email / letter / fax);

(f) Preferred contact method of Consumer (phone / email / letter / fax);

(g) Details of the Complaint; and

(h) Classification of the Complaint (Refer to section 11).

10. COMPLAINTS RECEIVED OVER THE PHONE

10.1 The following procedure must be followed when a Complaint is received orally:

(a) Identify yourself, listen, record details and determine what the Consumer wants;

(b) Confirm the details received;

(d) Explain the courses of action available;

(e) Do not attempt to lay blame or be defensive;

(f) Resolve the Complaint if possible or commit to do something immediately, irrespective of who will ultimately handle the Complaint;

(g) Don’t create false expectations;

(h) Inform the Consumer of the name and contact details of the person who will be formally dealing with the Complaint (i.e. the Complaints Officer);

(i) Refer the matter immediately to the Complaints Officer (even if you resolved the matter); and

(j) Record the details in the Complaints Register.

11. CLASSIFICATION OF COMPLAINTS

11.1 All Complaints must be classified by Speedle and then analysed to identify systemic, recurring and single incident problems and trends. Complaints should be prioritised according to the urgency and severity of the issues raised. Examples of matters that should be prioritised include where:

(a) the Consumer is experiencing domestic or financial abuse;

(b) the Consumer has a serious or terminal illness; or

11.2 Level 1 – the least serious Complaints. The Complaint could not be resolved at first contact with the Consumer. Some Complaints at this level require the assistance of other employees at Speedle (e.g. Information Technology and Investment Research). The Complaint can be resolved without escalating it to the Director.

11.3 Level 2 – more serious Complaints. The Director must be informed of the Complaint and may provide input where necessary to help resolve the Complaint.

11.4 Level 3 – the most serious Complaints. This type of Complaint requires the involvement of the Director.

12. RESPONSIBILITY FOR AND INVESTIGATION OF COMPLAINTS

12.1 At first instance the Complaints Officer is responsible for dealing with Complaints.

12.2 If the Complaints Officer is unable to resolve the Complaint within 21 days, the details of the Complaint must be immediately forwarded to the Director who has overall responsibility for Speedle’s IDR process.

12.3 The Director is to review the circumstances involving the Complaint and attempt to provide the Consumer with an IDR Response to the Complaint (Refer sections 16 and 17 below).

SECTION C – PROCEDURES: RESPONDING TO COMPLAINTS

13. RESPONDING FLEXIBLY

13.1 Speedle deals with Complaints with as little formality as possible to ensure that Consumers are not restricted in their access to Speedle’s IDR process.

14. ACKNOWLEDGING COMPLAINTS

14.1 Once the Complaint is received, the Complaints Officer must acknowledge receipt of the Complaint within twenty-four (24) hours (or one (1) business day) of receiving the Complaint, or as soon as practicable. The Complaints Officer must attempt to resolve the Complaint within thirty (30) calendar days of it being received.

14.2 When selecting a method to acknowledge a Complaint, Speedle takes into account the method used by the Consumer to lodge the Complaint and any preferences the Consumer has expressed about receiving communication from Speedle. Speedle may acknowledge Complaints:

(a) verbally; or

(b) in writing (including by email, mail or social media channels).

14.3 Please refer to Appendix 2 for a template Complaint Acknowledgement.

15. COMPLAINTS CLOSED WITHIN FIVE (5) BUSINESS DAYS OF RECEIPT

15.1 An IDR Response (refer section 16 below) is not required where a Complaint has been closed within five (5) business days of receipt because:

(a) Speedle has resolved the Complaint to the Consumer’s satisfaction and this is either:

(i) confirmed verbally or in writing by the Consumer; or

(ii) a reasonable view to take given the circumstances; or

(b) Speedle has given the Consumer an explanation and/or apology when it can take no further action to reasonably address the Complaint.

15.2 A written IDR Response must be provided even where a Complaint is closed within five (5) business days if:

(a) the Consumer requests a written response; or

(b) the Complaint is about hardship.

16. IDR RESPONSES

16.1 Complaints referred to the Complaints Officer must be responded to in the same manner they are received unless otherwise requested by the Consumer. For example, a telephone Complaint must be initially responded to with a telephone call.

16.2 The time and date of all telephone calls to the Consumer made in connection with a Complaint must be recorded with other details about the Complaint outlined in section 9.2 of this Policy.

16.3 An IDR Response must be provided to the Consumer upon resolving a Complaint. The written communication must inform the Consumer of:

(a) the final outcome of their Complaint at IDR, including either:

(i) confirmation of the actions taken by Speedle to fully resolve the Complaint; or

(ii) reasons for the rejection or partial rejection of the Complaint;

(b) their right to take the Complaint to AFCA if they are not satisfied with the IDR Response; and

16.4 If Speedle rejects or partially rejects the Complaint, the IDR Response must clearly set out the reasons for the decision by:

(a) identifying and addressing the issues raised in the Complaint;

(b) setting out Speedle’s finding on material questions of fact and referring to the information that supports those findings; and

(c) providing enough detail for the Consumer to understand the basis of the decision and to be fully informed when deciding whether to escalate the matter to AFCA or another forum.

16.5 Please refer to Appendix 3 for a template IDR Response.

17. TIMEFRAMES FOR IDR RESPONSES

17.1 Speedle must provide an IDR Response (in accordance with section 16) to the Consumer within the timeframes noted in the below table:

17.2 Type of Complaint / Maximum Timeframe to provide IDR Response / Further Detail

Complaints involving default notices = No later than twenty-one (21) calendar days after receiving the Complaint = Section 18

Complaints involving applications for hardship notices or a request for postponement of enforcements proceedings made = No later than twenty-one (21) calendar days after receiving the Complaint.

Exceptions apply where Speedle does not have sufficient information to make a decision or if an agreement is reached with the Consumer = Section 19

All other complaints = No later than thirty (30) calendar days after receiving the Complaint.

18. COMPLAINTS INVOLVING DEFAULT NOTICES

18.1 A Complaint may involve a default notice where the Consumer:

(a) alleges that the default notice was not served;

(b) disputes the amount specified in a default notice or whether the default notice was rectified;

18.2 Speedle must give the Consumer a default notice before commencing enforcement proceedings to recover money, take possession of property or sell property. The default notice must

(a) inform the Consumer that they must remedy the default within thirty (30) calendar days; and

(b) substantially meet the pro forma notice requirements in Form 12A and Form 18A of the National Consumer Credit Protection Regulations 2010 (Cth).

18.3 Speedle must refrain from commencing or continuing legal action, including enforcement proceedings, against a Complainant, except where the statute of limitations is about to expire. This only applies while:

(a) the Complaint is being handled by Speedle’s IDR process; and

(b) for at least fourteen (14) calendar days thereafter to allow the Consumer to lodge their Complaint with AFCA (where the Complaint cannot be resolved by Speedle’s IDR procedures.

19. COMPLAINTS INVOLVING HARDSHIP OR POSTPONEMENT REQUESTS

19.1 Speedle treats Complaints involving hardship notices or postponement requests as urgent matters and these are prioritised over other Complaints.

19.2 Speedle’s Hardship Policy provides further information regarding how Speedle deals with hardship notices, including how to identify and respond to hardship notices.

19.3 Speedle’s Complaints Officer is responsible for ensuring the following occurs within twenty-one (21) calendar days of receiving a Complaint involving a hardship notice or postponement request:

(a) consider and determine whether to agree to:

(i) a change in the terms of the credit contract/consumer lease between Speedle and the complainant for hardship (pursuant to section 72 and section 177B of the National Credit Code); or

(ii) a request to postpone enforcement proceedings.

19.4 Where additional information is required from the Complainant:

(a) Where Speedle requires further information about a hardship notice, the Complaints Officer is responsible for ensuring Speedle requests the additional information with twenty-one (21) calendar days of receiving a Complaint.

(b) Where Speedle has requested additional information from the Complainant, the Complainant has twenty-one (21) calendar days to respond to this request for information.

(c) Additional time to provide an IDR Response is permitted where the credit contract/consumer lease was entered into after 1 March 2013. The additional time is up to:

(i) twenty-eight (28) calendar days from when the additional information was requested, but not received; or

(ii) twenty-one (21) calendar days from when the additional information was received by Speedle.

19.5 If the Complaint cannot be resolved within the required timeframe, the Consumer must be referred to AFCA.

19.6 Where Speedle has reached an agreement with the Complainant about a hardship notice or postponement request, Speedle’s Director will confirm in writing:

(a) the terms of change to the credit contract/consumer lease; or

(b) the conditions of postponement of enforcement proceedings;

within thirty (30) calendar days of the agreement being reached.

19.7 Speedle must inform the Complainant of their right to complain to AFCA and provide AFCA’s contact details where Speedle:

(a) does not agree to a change in the terms of a credit contract/consumer lease or to negotiate a postponement of enforcement proceedings; or

(b) where an agreement has been reached per section 19.6, within thirty (30) calendar days of the agreement being reached.

20. COMPLAINT MANAGEMENT DELAYS

20.1 Speedle is not required to provide a Consumer with an IDR Response within the IDR timeframe where:

(a) there has been no reasonable opportunity to provide the IDR Response within the IDR timeframe because:

(i) the resolution of the Complaint is particularly complex, for example, the individual Complaint is about a transaction or event that occurred more than six (6) years ago and requires reconstruction of account information; and/or

(ii) circumstances beyond Speedle’s control are causing Complaint management delays, for example, the Consumer is waiting on a medical appointment that Speedle reasonably requires the Consumer to attend or the Consumer is unable to respond to Speedle due to illness or absence; and

(b) an IDR Delay Notification has been sent to the Consumer prior to the expiry of the IDR timeframe (ie: thirty (30) calendar days).

Note: Complaint management delays caused by authorised representatives of Speedle is not a valid reason for Speedle to have not provided an IDR Response within the required timeframe.

20.2 The IDR Delay Notification must inform the Consumer about:

(a) the reasons for the delay;

(b) their right to complain to AFCA if they are dissatisfied; and

20.3 Please refer to Appendix 4 for a template IDR Delay Notification.

20.4 The exceptions to providing an IDR Response outlined in 20.1 and 20.2 do not prevent the Consumer from escalating their Complaint to AFCA and do not affect AFCA’s ability to register a Complaint.

SECTION D – RECORD KEEPING

21. COMPLAINTS REGISTER

21.1 A Complaints Register is to be compiled and managed by the Complaints Officer.

21.2 A copy of the Complaints Register is to be provided to the Director on a quarterly basis for review.

21.3 The Complaints Officer must maintain a soft copy record of the Complaints Register.

22. COMPLAINTS DATA

22.1 Speedle must provide reports about Complaint’s data on a quarterly basis to Speedle’s Director and senior management.

22.2 These reports should include:

(a) the number of Complaints received;

(b) the number of Complaints closed;

(d) the time taken to acknowledge Complaints;

(e) the time taken to resolve or finalise Complaints;

(f) Complaint outcomes, including:

(i) the number of Complaints resolved;

(ii) the number of Complaints unresolved;

(iii) the number of Complaints that were abandoned or withdrawn; and

(iv) details of amounts paid to Consumers to resolve Complaints;

(g) possible systemic issues identified;

(h) the underlying causes of Complaints;

(i) Complaint trends;

(j) the number of Complaints escalated to AFCA; and

(k) recommendations for improving products or services.

23. REPORTING TO ASIC

23.1 Speedle must lodge their IDR data with ASIC by 31 January and 31 July each year, for the reporting periods of 1 January to 30 June and 1 July to 31 December respectively.

23.2 Complaints that must be included in an IDR data report include:

(a) any complaints required to be covered by Speedle’s IDR procedures; and

(b) any complaints that were:

(i) made in the reporting period; and

(ii) not closed as at the start of the reporting period.

23.3 Speedle must also report a complaint if Speedle has reopened a previously closed complaint.

23.4 The Complaints Officer collates the IDR data for each reporting period in the template provided by ASIC to ensure that the IDR data passes ASIC’s verification.

23.5 The Complaints Officer is responsible for lodging Speedle’s IDR data CSV file with ASIC via the Regulatory Portal within the required time frame.

24. IDENTIFYING AND RECORDING SYSTEMIC ISSUES

24.1 The Complaints Officer aims to identify any systemic issues or recurring Complaints as a result of compiling the Complaints Register.

24.2 Where any systemic issues or recurring Complaints are identified, these are notified to the Director by preparing a report to accompany the Complaints Register. The report must include metrics and analysis of Consumer Complaints including the systemic issues identified through those Complaints. This encourages the identification of compliance issues or risks, which can be investigated to determine their causes and then rectified.

24.3 The Director must ensure that prompt action is taken to rectify systemic issues and:

(a) identify affected Consumers; and

(b) provide fair remediation to affected Consumers.

24.4 Speedle must:

(a) encourage and enable staff to escalate potential systemic issues identified from individual Complaints;

(b) regularly analyse Complaint data to identify systemic issues;

(d) report internally on the outcome of investigations, including actions taken, in a timely manner.

24.5 Where any systemic issue results in a breach of Speedle’s obligations under its AFSL, the Corporations Act or any other financial services laws; the breach is reported by the Compliance Officer in accordance with Speedle’s Breaches and Incidents Reporting Policy.

25. COMPLIANCE AUDITS

25.1 Speedle must undertake compliance audits at least annually, unless the number of Complaints is very small.

SECTION E – REMEDIES

26. TYPES OF REMEDIES AVAILABLE FOR RESOLVING COMPLAINTS

26.1 If the Complaints Officer is of the opinion that a Complaint requires a remedy, the matter must be referred to the Director to make a determination. The Director is appropriately authorised to determine and approve any remediation to be paid to Consumers.

26.2 In determining the appropriate remedy, the Director considers a broad range of remedies to facilitate the fair and efficient resolution of the Complaint, including:

(a) an explanation of the circumstances giving rise to the Complaint;

(b) an apology;

(d) a refund or waiver of a fee or charge;

(e) a goodwill payment;

(f) a compensation payment;

(g) a waiver of debt;

(h) correcting incorrect or out of date records;

(i) changing the terms of a contract; and

(j) undertaking to set in place improvements to Speedle’s systems, procedures or products.

27. CLOSING COMPLAINTS

27.1 Speedle should record the Complaint outcome, Complaint remedy and financial compensation amount (if any).

27.2 Speedle must ensure that Complaint resolution outcomes are implemented in a timely manner when a Complaint is closed.

SECTION F - EXTERNAL DISPUTE RESOLUTION

28. AUSTRALIAN FINANCIAL COMPLAINTS AUTHORITY

28.1 Speedle is a member of AFCA. Speedle’s AFCA membership number is 99505. If membership with AFCA is changed or cancelled, Speedle must notify ASIC within ten (10) business days of the change.

28.2 Where Speedle has failed to renew its AFCA membership or where its AFCA membership has been cancelled because of failure to pay membership fees, non-compliance with the Terms of Reference or decision of AFCA, Speedle will prepare a written report to ASIC within three (3) business days of the change.

28.3 The Compliance Officer ensures Speedle’s AFCA membership is renewed on the appropriate date.

28.4 Speedle liaises with AFCA and ensures full cooperation with it.

28.5 Speedle must provide details about how a Consumer can access AFCA in a range of documents including:

(a) its website;

(b) Financial Services Guides;

(d) Periodic Statements (including exit statements).

SECTION G – CONCLUSION

29. DUTY OF CARE TO CLIENTS AND STAFF

29.1 The Director is responsible for ensuring Speedle’s IDR process does not involve the release of information in relation to:

(a) Speedle generally;

(b) Consumers or Speedle’s employees’ individual information;

that contravenes the privacy laws, any of Speedle’s policies in relation to confidential information or the contractual obligations of Speedle. Further information and advice on this matter can be obtained from the Director.

29.2 Reponses to IDR matters that contain personal information about a Consumer or an employee of Speedle’s must be provided to the Director for final approval, prior to publication or release.

29.3 The Director must ensure express consent has been obtained from the Consumer prior to disclosing any personal information.

30. OUTSOURCING

30.1 Where Speedle outsources part, or all, of its IDR process, Speedle must:

(a) have measures in place to ensure that due skill and care is taken in choosing suitable service providers;

(b) monitor the ongoing performance of service providers; and

(c) appropriately deal with any actions by service providers that breach service level agreements or fall short of their obligations.

30.2 Speedle’s outsourcing procedures are included in its Outsourcing Policy.

31. TRAINING

31.1 Employees of Speedle who deal with Consumers, not just Complaints handling staff, need to have an understanding of the IDR process. Consequently, all employees of Speedle receive targeted induction and ongoing training about the IDR process. This training is scheduled and conducted at the discretion of the Compliance Officer.

31.2 Training includes the following topics:

(a) Speedle’s IDR process and applicable policies;

(b) the requirements of RG271;

(d) any changes to Speedle’s products and services which may impact Consumers and lead to expressions of dissatisfaction;

(e) how to identify Consumers who may need additional assistance;

(f) dealing with Unreasonable Consumer Conduct;

(g) effective communication and negotiation techniques;

(h) effective written communications;

(i) Complaint data capture and internal reporting;

(j) issue identification and analysis; and

(k) identifying and escalating systemic issues, including reporting lines.

32. RESOURCES

32.1 The Director at all times ensures there are adequate resources for IDR processes to operate effectively and efficiently. The Director conducts an annual review of the resources allocated to Speedle’s IDR process to ensure they are adequate.

32.2 To ensure adequate systems are in place to handle Complaints promptly, fairly and consistently, the Director:

(a) reviews IDR processes on a regular basis and provide additional resources without delay where required;

(b) ensures at all times, there is an established contact point for Consumers;

(c) ensures personnel involved in handling Complaints are adequately trained and competent to deal with Complaints, including the authority to settle Complaints or have ready access to someone with the necessary authority; and

(d) ensures there is appropriate documentation, specialist support, materials and equipment, computer hardware and software, and finances to assist with the IDR process.

33. DOCUMENT RETENTION AND AUDIT

33.1 Directors, officers and employees of Speedle are required to retain copies of all Complaints handling documents in accordance with Speedle’s Document Retention Policy. These files are maintained at the premises of Speedle. A copy must also be provided to the Compliance Officer for storage and inspection by ASIC as required.

34. POLICY REVIEW

34.1 This Policy is reviewed on at least an annual basis by the Compliance Officer, having regard to the changing circumstances of Speedle. The Compliance Officer then reports to the Director on compliance with this Policy.

35. LEGISLATIVE BASIS

35.1 This Policy gives effect to the reforms introduced by the Treasury Laws Amendment (Putting Consumers First – Establishment of the Australian Financial Complaints Authority) Act 2018 and complies with ASIC Regulatory Guide 271: Internal Dispute Resolution and Speedle’s obligations under section 47(1)(h) of the National Consumer Credit Protection Act 2009 (Cth).

35.2 This Policy has been developed in accordance with the principles outlined in Australian Standard AS/NZS 10002: 2014.

Issued by Speedle Pty Limited – 15 January 2024

‍

Fee Statement

Updated on

January 15, 2024

Download PDF

SPEEDLE SMALL LOANS

General specifications:

Minimum loan amount: $ 500
Maximum loan amount: $ 2,000
Minimum repayment period: 1 month
Maximum repayment period: 12 months

Interest, Fees and changes:

Establishment Fee 20% of original loan amount
Monthly Fee: 4% per month of the original loan amount
Overdue Account Fee: Zero
Early Repayment Fee: Zero
Dishonour Fee: $10 but if you call us before, we’ll waive it.

Other specifications:

Repayment frequency: Weekly or fortnightly
Redraw: Not available
Early repayment permitted: Yes

‍

SPEEDLE MEDIUM LOANS

General specifications:

Minimum loan amount: $ 2,001
Maximum loan amount: $ 5,000
Minimum repayment period: 1 month
Maximum repayment period: 12 months

Interest, Fees and changes:

Establishment Fee $400
Interest (APR): 47.8%
Overdue Account Fee: Zero
Early Repayment Fee: Zero
Dishonour Fee: $10 but if you call us before, we’ll waive it.

Other specifications:

Repayment frequency: Weekly or fortnightly or monthly
Redraw: Not available
Early repayment permitted: Yes

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APR

An annual percentage rate (APR) does not apply to Small Loans.
Medium Loans have an APR of 47.8% p.a. The comparison rate for a Medium Loan of $3,000 over 52 weeks with a $400 Establishment Fee is 79.17% p.a.
WARNING: This comparison rate is true only for the examples given and may not include all fees and charges. Different terms, fees or other loan amounts might result in a different comparison rate.

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Warning about borrowing

Updated on

January 15, 2024

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WARNING - DO YOU REALLY NEED A LOAN TODAY? *

It can be expensive to borrow small amounts of money and borrowing may not solve your money problems.

Check your options before you borrow:

For information about other options for managing bills and debts, ring 1800 007 007 from anywhere in Australia to talk to a free and independent financial counsellor
Talk to your electricity, gas, phone or water provider to see if you can work out a payment plan
If you are on government benefits, ask if you can receive an advance from Centrelink or phone 13 17 94

The Government's MoneySmart website shows you how small amount loans work and suggests other options that may help you.

*This statement is an Australian Government requirement under the National Consumer Credit Protection Act 2009.

Target Market Determination

Updated on

January 15, 2024

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PART A - TARGET MARKET DETERMINATION FOR SPEEDLE SMALL LOANS

About this document

This Target Market Determination (TMD) seeks to offer consumers, distributors and staff with an understanding of the class of consumers for which this credit product has been designed, having regard to the objectives, financial situation and needs of the target market.

The TMD will also describe how the product is distributed, when this document will be reviewed and what information is required to be provided to help maintain the accuracy of this document.

The product is issued by Speedle Pty Ltd (“Speedle”). More information about this product is contained on Speedle’s website (www.speedle.com.au). Consumers should consider whether the product is appropriate for them before making any decision about whether to apply for or enter into the product.

This document is not a product disclosure statement and is not to be treated as a full summary of the product’s terms and conditions. It has been prepared without taking into account any person’s particular objectives, financial situation or needs and is not intended to provide financial advice. Consumers should consider the product’s full terms and conditions when making a decision about this product.

Description of this product

The Speedle Small Loan key attributes include:

General specifications:

Minimum loan amount: $ 500
Maximum loan amount: $ 2,000
Minimum repayment period: 1 month
Maximum repayment period: 12 months
Security: Nil

Interest, Fees and changes:

Establishment Fee 20% of original loan amount
Interest (APR): Nil
Monthly Fee: 4% per month of the original loan amount
Dishonour Fee: $10
Overdue Account Fee: Nil
Early Repayment Fee: Nil
Card Fee: Dependant on card provider and payment method

Other specifications:

Repayment frequency: Weekly or fortnightly
Redraw: Not available

Early repayment permitted: Yes

Who this product is designed for

The Speedle Small Loan has been designed for customers who:

meet our eligibility criteria, including (but not limited to):
are over the age of 18 years;

have income exceeding $1,700 per month;
are a permanent resident of Australia or having an acceptable work visa,

require a loan for an amount between $500 and $2,000 (or, where the initial request is for a higher amount, are willing to accept a loan between those amounts) for a specified purpose;
are seeking a loan that is repayable over a fixed term of between 1 month and 12 months, with the scheduled term to be agreed in the credit contract;
do not want a revolving or continuing line of credit or a long term credit contract that is repayable over a number of years;
require the loan proceeds to be promptly disbursed to their nominated bank account;
are willing to apply online and provide Speedle with access to their bank transaction history and credit history to help us assess their application.

Who this product is not suitable for

This product is not suitable for customers who:

are unable to access the internet;

require a loan for an amount less than $500 or more than $2,000;
are seeking an ongoing credit limit that may be drawn down as required from time to time;
are unlikely to be able to meet their payment obligations under the loan either at all or only with substantial hardship;
receive less than an average of $1,700 in income per month
if less than 21 years of age are unemployed or receive more than 50% of their income from Government benefits;
require a longer term loan that can be repaid over more than 12 months;
are under 18 years of age.
need to allocate more than 10% of their net income towards the repayments of small loans;

Distribution conditions

An application for a Speedle Small Loan can only be made via the Speedle website, with support provided by employees in Speedle’s contact centre where required. Speedle employees can only provide assistance in relation to an application for a Speedle Small Loan if they have received adequate training and they must follow Speedle’s applicable policies and processes. The online application assessment process includes a number of questions that help to determine if the applicant is within the target market for this product. The information provided by the applicant during the application process will be used to determine if we will offer to provide a loan to the customer and, if so, for what range in amount and loan term. The customer should always answer these questions accurately and check with Speedle if they are not sure what a question means.

Additionally, the product may be distributed to the target market via comparison websites such as Finder. These third party websites provide information about the product on their website and provide consumers with an opportunity to make an application through an electronic link. Any such applications must be completed and processed via our online application process, which contains the questions set out above used to determine if the applicant is within the target market for this product.

These conditions make it likely that Speedle Small Loans will only be offered to customers within the target market for this product because:

any comparison websites are vetted and authorised by Speedle;
Speedle’s employees have knowledge of the product terms and conditions and Speedle’s processes are designed to identify instances where a product is not suitable for the applicant; and
Speedle has the sole determination of whether a consumer acquiring the product meets the eligibility criteria, assessed according to the consumer’s requirements and objectives.

Reviewing this document

Speedle, as the issuer and distributor of this product, collects information and prepares reports regarding loan volumes, average loan amounts, default rates, complaints and any occasions where this product has been provided contrary to the TMD on an at least annual basis to help improve our products and services.

We will review this TMD if:

there is an amendment to the National Consumer Protection Act 2009 (Cth) or any associated law which effects this product;
there is a material change to the design or distribution of the product, including the terms and conditions applicable to the product and/or related documentation;
we introduce other ways in which this product can be provided or distributed;
the number of funded complaints received from customers as a percentage of total funded loans is greater than 5% in any given calendar quarter;
in respect of the total funded loans in any given calendar quarter, the total number of hardship applications received from those funded customers exceeds 10%;
if ASIC, AFCA, or community based consumer organisations communicate to us that they have identified a systemic issue in relation to this product;
the percentage of bad debts in in any given calendar quarter exceeds 18% of total funded loans;
the total outstanding balance of payments more than 30 days overdue as a percentage of total amount originated is greater than 10% in any given calendar quarter;
there is an external events such as adverse media coverage or regulatory attention;
the business performance and value provided by the product indicates that the TMD is no longer appropriate, having regard to appropriate data such as customer demand for the product, loan volumes, application approval rates, customer default or loss rates and the nature and number of customer complaints;
we identify that there has been a significant dealing in the product that is not consistent with the TMD.

Our review will occur within 10 business days of any of the above events occurring.

In any event, a review of this TMD will be completed no later than six months from the publication date of this TMD and subsequently at twelve month intervals.

Distribution Information Reporting Requirements

In the event that distributors engage in retail product distribution, the following information must be provided to Speedle by distributors who engage in that retail product distribution in relation to this product:

Type of information / Description / Reporting period

Specific complaints / Details of the complaint, including the name and contact details of the complainant and the substance of the complaint /As soon as practicable, and in any event within 10 business days of receipt of the complaint

General complaints / Number of complaints / Every 3 months

Significant dealing(s) / Date or date range of the significant dealing(s) and a description of the significant dealing (eg, why it is not consistent with the TMD) / As soon as practicable, and in any event within 10 business days after becoming aware of the significant dealing

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Questions?

If you have any questions about our credit products or this TMD, please contact us on 02 8365 2322 or by email at compliance@speedle.com.au

First publication date: 15 January 2024

Last review date: 30 June 2024

Issuer: Speedle Pty Ltd (ACN 668 001 045, ACL 549307)

PART B - TARGET MARKET DETERMINATION FOR SPEEDLE MEDIUM LOANS

About this document

This target market determination (TMD) seeks to offer consumers, distributors and staff with an understanding of the class of consumers for which this credit product has been designed, having regard to the objectives, financial situation and needs of the target market.

The TMD will also describe how the product is distributed, when this document will be reviewed and what information is required to be provided to help maintain the accuracy of this document.

Description of this product

The Speedle Medium Loan key attributes include:

General specifications:

Minimum loan amount: $ 2,001
Maximum loan amount: $ 5,000
Minimum repayment period: 1 month
Maximum repayment period: 12 months
Security: Nil

Interest, Fees and changes:

Establishment Fee $400
Interest (APR): 47.8%
Monthly Fee: Nil
Dishonour Fee: $10
Overdue Account Fee: Nil
Early Repayment Fee: Nil
Card Fee: Dependant on card provider and payment method

Other specifications:

Repayment frequency: Weekly or fortnightly or monthly
Redraw: Not available
Early repayment permitted: Yes

Who this product is designed for

The Speedle Medium Loan has been designed for customers who:

meet our eligibility criteria, including (but not limited to):

are over the age of 18 years;
have income exceeding $1,700 per month

are a permanent resident of Australia or having an acceptable work visa,

require a loan for an amount between $2,001 and $5,000 (or, where the initial request is for a higher amount, are willing to accept a loan between those amounts) for a specified purpose;
are seeking a loan that is repayable over a fixed term of between 1 month and 12 months, with the scheduled term to be agreed in the credit contract;
do not want a revolving or continuing line of credit or a long term credit contract that is repayable over a number of years;
require the loan proceeds to be promptly disbursed to their nominated bank account;
are willing to apply online and provide Speedle with access to their bank transaction history and credit history to help us assess their application.

Who this product is not suitable for

This product is not suitable for customers who:

are unable to access the internet;
require a loan for an amount less than $2,001 or more than $5,000;

are seeking an ongoing credit limit that may be drawn down as required from time to time;
are unlikely to be able to meet their payment obligations under the loan either at all or only with substantial hardship;
receive less than an average of $1,700 in income per month
if less than 21 years of age are unemployed or receive more than 50% of their income from Government benefits;
require a longer term loan that can be repaid over more than 12 months;
are under 18 years of age.

Distribution conditions

An application for a Speedle Medium Loan can only be made via the Speedle website, with support provided by employees in Speedle’s contact centre where required. Speedle employees can only provide assistance in relation to an application for a Speedle Medium Loan if they have received adequate training and they must follow Speedle’s applicable policies and processes. The online application assessment process includes a number of questions that help to determine if the applicant is within the target market for this product. The information provided by the applicant during the application process will be used to determine if we will offer to provide a loan to the customer and, if so, for what range in amount and loan term. The customer should always answer these questions accurately and check with Speedle if they are not sure what a question means.

These conditions make it likely that Speedle Medium Loans will only be offered to customers within the target market for this product because:

any comparison websites are vetted and authorised by Speedle;
Speedle’s employees have knowledge of the product terms and conditions and Speedle’s processes are designed to identify instances where a product is not suitable for the applicant; and
Speedle has the sole determination of whether a consumer acquiring the product meets the eligibility criteria, assessed according to the consumer’s requirements and objectives.

Reviewing this document

We will review this TMD if:

there is an amendment to the National Consumer Protection Act 2009 (Cth) or any associated law which effects this product;
there is a material change to the design or distribution of the product, including the terms and conditions applicable to the product and/or related documentation;
we introduce other ways in which this product can be provided or distributed;
the number of funded complaints received from customers as a percentage of total funded loans is greater than 5% in any given calendar quarter;
in respect of the total funded loans in any given calendar quarter, the total number of hardship applications received from those funded customers exceeds 10%;
if ASIC, AFCA, or community based consumer organisations communicate to us that they have identified a systemic issue in relation to this product;
the total outstanding balance of payments more than 30 days overdue as a percentage of total amount originated is greater than 10% in any given calendar quarter;
the percentage of bad debts in in any given calendar quarter exceeds 18% of total funded loans;
there is an external events such as adverse media coverage or regulatory attention;
the business performance and value provided by the product indicates that the TMD is no longer appropriate, having regard to appropriate data such as customer demand for the product, loan volumes, application approval rates, customer default or loss rates and the nature and number of customer complaints;
we identify that there has been a significant dealing in the product that is not consistent with the TMD.

Our review will occur within 10 business days of any of the above events occurring.

In any event, a review of this TMD will be completed no later than six months from the publication date of this TMD and subsequently at twelve month intervals.

Distribution Information Reporting Requirements

‍

Type of information / Description / Reporting period

Specific complaints / Details of the complaint, including the name and contact details of the complainant and the substance of the complaint / As soon as practicable, and in any event within 10 business days of receipt of the complaint

General complaints / Number of complaints / Every 3 months

Significant dealing(s) / Date or date range of the significant dealing(s) and a description of the significant dealing (eg, why it is not consistent with the TMD) / As soon as practicable, and in any event within 10 business days after becoming aware of the significant dealing

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Questions?

If you have any questions about our credit products or this TMD, please contact us on 02 8365 2322 or by email at compliance@speedle.com.au

First publication date: 15 January 2024

Last review date: 30 June 2024

Issuer: Speedle Pty Ltd (ACN 668 001 045, ACL 549307)

Responsible Lending Policy

Updated on

January 15, 2024

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SECTION A – INTRODUCTION

1. BACKGROUND

1.1 This document outlines Speedle Pty Limited’s (“Speedle”) policies and procedures for meeting an Australian Credit Licensee’s responsible lending obligations.

1.2 Under the National Consumer Credit Protection Act 2009 (Cth) (“the National Credit Act”), the Responsible Lending Obligations apply where the Licensee:

(a) enters into a Credit Contract with a customer;

(b) increases the credit limit on an existing Credit Contract; or

(c) makes an unconditional representation to a customer that the licensee considers that they are eligible to do either of the above with the licensee;

1.3 The primary obligation is to conduct an assessment that the Credit Contract is ‘not unsuitable’ for the client.

1.4 A Credit Contract will be unsuitable where it is likely that:

(a) the Credit Contract does not meet the customer’s requirements and objectives; or

(b) the customer will be unable to meet their payment obligations either at all or only with Substantial Hardship; or

1.5 To meet its responsible lending obligations, Speedle must perform the following four steps:

(a) make reasonable enquiries about the customer’s financial situation, and their requirements and objectives;

(b) take reasonable steps to verify the customer’s financial situation; and

(c) make a final assessment (based on the findings of the enquiries and verification) about whether the Credit Contract is ‘not unsuitable’ for the customer;

(d) take any steps prescribed by the regulations to verify any matter prescribed by the regulations.

1.6 These obligations apply to Speedle when Speedle:

(a) enters into a Credit Contract with a customer;

(b) increases the credit limit on an existing Credit Contract; or

(c) makes an unconditional representation to a customer that Speedle considers that they are eligible to enter into a Credit Contract with Speedle, or that the credit limit of an existing contract with Speedle will be able to be increased.

1.7 These obligations will apply to new Credit Contracts and also when Speedle considers whether to increase a credit limit under an existing Credit Contract.

2. OBJECTIVES OF POLICY

2.1 Speedle’s Responsible Lending Policy (“Policy”) has been implemented because:

(a) Speedle has an obligation under the law to have in place adequate arrangements to guarantee that its responsible lending obligations are met;

(b) Speedle also has a general obligation as a licensee to deal with customers efficiently, honestly and fairly; and

(c) where procedures for meeting the responsible lending obligations are not managed appropriately, Speedle’s Australian Credit Licence (“ACL”) may be suspended or cancelled and Speedle and/or its Representatives may be liable for fines and/or imprisonment in extreme cases.

2.2 This Policy applies to Speedle and all of its Representatives.

3. DEFINITIONS

3.1 ADI refers to an Authorised Deposit-taking Institution.

3.2 Credit Contract refers to a contract under which credit is or may be provided to which the National Credit Code applies. The National Credit Code applies when the Credit Contract is entered into or (in the case of pre-contractual obligations) is proposed to be entered into, where:

(a) the debtor is a natural person or a strata corporation; and

(b) the credit is provided or intended to be provided wholly or predominantly:

(i) for personal, domestic or household purposes; or

(ii) to purchase, renovate or improve residential property for investment purposes; or

(iii) to refinance credit that has been provided wholly or predominantly to purchase, renovate or improve residential property for investment purposes; and

(d) the credit provider provides the credit in the course of a business of providing credit carried on in this jurisdiction or as part of or incidentally to any other business of the credit provider carried on in Australia.

3.3 National Credit Act refers to the National Consumer Credit Protection Act 2009 (Cth).

3.4 Representative refers to any person who acts on Speedle’s behalf in relation to credit activities. This includes:

(a) Speedle’s employees and directors;

(b) Speedle’s authorised credit representatives; and

3.5 Small-amount Credit Contracts refers to a small-amount Credit Contract that is:

(a) for an amount of two thousand dollars ($2000.00) or less;

(b) for a term of at least sixteen (16) days but no longer than one (1) year;

(d) not a continuing Credit Contract.

3.6 Substantial/Financial Hardship arises where a customer is reasonably unable to meet their contractual obligations due to illness, unemployment or other reasonable cause (can include a change in the customer’s financial circumstances or reduction in income).

SECTION B – DISCLOSURE DOCUMENTS

4. DOCUMENTS PROVIDED TO CUSTOMERS

4.1 In addition to the responsible lending obligations, Speedle must also provide certain disclosure documents to customers at particular stages of the credit process.

4.2 The table below outlines these documentation requirements:

Document: Credit Guide

Content: The Credit Guide Must

(a) Disclose information about Speedle’s obligation to not enter a customer into an unsuitable Credit Contract;

(b) Outline how the consumer can request a copy of the written assessment;

(c) Disclose Speedle’s relationship with a mortgage manager or product designer where Speedle has entered into a Credit Contract as a result of credit assistance provided by a mortgage manager or product designer.

The Credit Guide does not need to include fees, charges and commissions.

When to Provide :

(a) As soon as practicable after Speedle become aware that the customer is likely to enter into a Credit Contract with Speedle.

(b) Speedle’s credit representatives will give a Credit Guide to the customer at the same time that they give the customer the Credit Guide of Speedle.

Document: Final Assessment that the Credit Contract is not unsuitable

Content: Please refer to Section G.

When to Provide :

(a) Speedle must give a customer the written Final Assessment, free of charge upon request.

(b) Speedle is not required to give a written Final Assessment where the Credit Contract is not entered into or the credit limit is not increased.

SECTION C – PROCEDURES FOR MAKING REASONABLE ENQUIRIES

5. MAKING REASONABLE ENQUIRIES

5.1 In making reasonable enquiries about the particular customer’s financial situation, their requirements and objectives, Speedle will consider the following:

(a) the potential impact on the customer of entering into an unsuitable Credit Contract;

(b) the potential negative impact on the customer if the Credit Contract is unsuitable, making more extensive enquiries if it is relatively likely there will be a serious impact. For example, if the size of a loan is large relative to the customer’s capacity to repay the loan;

(d) the capacity of the customer to understand the Credit Contract, making more inquires where it becomes clear that:

(i) the customer has limited capacity to understand the Credit Contract and their payment obligations under the Credit Contract. For example, customers with limited knowledge of English;

(ii) the customer has conflicting objectives;

(iii) the customer is confused about their objectives (or has difficulty articulating them); or

(iv) there is an apparent mismatch between the customer’s objectives and the product being considered by the customer;

(e) whether the customer is an existing customer or a new customer, making more extensive enquiries for new customers; and

(f) the nature of the particular service being provided, making more extensive enquiries for more complex services.

5.2 Speedle will take any other steps it considers necessary to ensure that all reasonable enquiries have been made.

6. REASONABLE ENQUIRIES ABOUT A CONSUMER’S FINANCIAL SITUATION

6.1 Speedle is required to find out about the particular customer’s current financial situation. Speedle must obtain information about the customer’s income, expenses and other circumstances that are likely to affect the customer’s ability to meet the financial obligations of the proposed Credit Contract.

6.2 In making reasonable enquiries about the customer’s financial situation, Speedle will consider the following:

(a) the customer’s current amount and source of income or benefits (including the nature and length of their employment and whether all or part of the customer’s income is sourced from Centrelink payments or similar);

(b) the extent of the customer’s fixed expenses such as:

(i) rent;

(ii) repayment of existing debts;

(iii) child support; and/or

(iv) recurring expenses such as insurance fees;

(c) the customer’s variable living expenses (including the needs of dependants and any particular or unusual circumstances);

(d) the customer’s discretionary expenditure such as entertainment, take-away food, alcohol, tobacco and/or gambling;

(e) the extent to which any existing debts are to be repaid from the credit advanced;

(f) the customer’s credit history including:

(g) the number of small amount Credit Contracts the customer has been a debtor under within the previous 90-day period; and

(h) whether the customer has defaulted on payments under those contracts;

(i) the customer’s circumstances including:

(i) their age; and

(ii) number of dependants;

(j) the customer’s assets, including their nature (such as whether they produce income) and value;

(k) any significant changes to the customer’s financial circumstances that are reasonably foreseeable such as:

(i) a change in repayments for an existing home loan due to foreseeable interest rate changes (e.g. ending of a ‘honeymoon’ interest rate); or

(ii) changes to the customer’s employment arrangements such as seasonal employment or impending retirement and plans to fund retirement (for example, from superannuation or income producing assets);

(l) geographical factors, such as remoteness, which may require consideration of specific issues (such as potentially higher living costs compared to urban areas);

(m) whether the customer will need to sell their principal place of residence to comply with their financial obligations under the Credit Contract;

(n) indirect income sources (such as income from a spouse) where that income is reasonably available to the customer, taking into account the history of the relationship and the expressed willingness of the earning person to meet repayment obligations; and

(o) any other matters that Speedle considers to be relevant in assessing whether the Credit Contract will be ‘not unsuitable’ to the customer.

6.3 If Speedle takes into consideration the relevance of indirect income to a customer’s financial situation, Speedle is required to obtain information of the earning person’s financial situation in accordance with Section 6.2 and verify that information is accordance with Section 10.1.

7. REASONABLE ENQUIRIES ABOUT A CONSUMER’S REQUIREMENTS AND OBJECTIVES

7.1 In making reasonable enquiries about the particular customer’s requirements and objectives, Speedle will consider the following:

(a) the value of the Credit Contract needed or the maximum amount of Credit Contract sought;

(b) the timeframe for which the Credit Contract is required;

(d) whether the customer seeks particular product features or flexibility, the relative importance of different features to the customer, and whether the customer is prepared to accept any additional costs or risks associated with these features;

(e) whether the customer requires any additional expenses, such as premiums for insurance related to the Credit Contract, to be included in the amount financed, and whether the customer is aware of the additional costs of these expenses being financed; and

(f) any other matters that Speedle considers to be relevant in assessing the customer’s purpose for which the Credit Contract is sought and whether the proposed Credit Contract meets that purpose.

8. PROCESSES TO ENSURE THAT REASONABLE ENQUIRIES ARE MADE

8.1 Speedle will have the following processes in place to ensure that it can satisfy sections 6 and 7 above:

(a) Speedle will collect from the prospective client all the information relevant to making the assessment as noted in sections 6 and 7 above via an online application;

(b) If further information is required a Speedle will request this information directly from the customer via telephone;

(c) Speedle will record and/or store the information received from the prospective customer in accordance with its account opening procedures; and

8.2 Speedle will ensure that there are adequate systems and enough staff in place for these requirements to be met.

8.3 Where Speedle uses a credit application and behavioural scoring systems to decide whether the contract is not unsuitable for the customer, Speedle will ensure the relevant legislative requirements for Responsible Lending are met.

9. FACTORS RELEVANT TO THE SCALABILITY OF THE REASONABLE ENQUIRIES

9.1 Speedle will partake in further extensive customer enquiries where the potential negative impact on the customer is likely to be relatively serious if the Credit Contract is unsuitable.

9.2 Less extensive inquires will be undertaken by Speedle where the Credit Contract has relatively simple terms that most customers can understand.

9.3 More extensive enquiries will be undertaken where the Credit Contract has complex terms.

9.4 More enquiries about the customer’s requirements and objectives will be undertaken when it becomes evident to Speedle that:

(a) the customer has limited capacity to understand the Credit Contract and the payment obligations under the contract;

(b) the customer has conflicting objectives;

(d) there is an apparent mismatch between the customer’s objectives and the product being considered by the customer.

9.5 If the customer is an existing customer of Speedle and Speedle already has information on file about the customer, less extensive enquiries about the customer and less extensive verification procedures can be performed.

SECTION D – PROCEDURES FOR VERIFICATION

10. VERIFICATION OF INFORMATION PROVIDED BY A CONSUMER

10.1 To verify the information collected from the customer, Speedle will collect the following:

(a) Credit Report including information/reports from other credit providers (if available);

(b) Bank account statements covering at least the 90 days but up to 180 days prior to the assessment (e.g. income and expenses can be verified by examining account statements over a period of time);

(c) In some cases for larger loans, r ecent payroll receipts/payslips and confirmation of employment with the customer’s employer or recent income tax returns, a statement from the person’s accountant setting out details of the customer’s financial position, Business Activity Statements or financial statements for self-employed customers;

(d) Statements of Expenses for larger loans in respect of liabilities e.g. mortgage statements etc; and

(e) any other information held about an existing customer.

10.2 Speedle will collect any further information it deems necessary to verify the information given by the prospective client, particularly if there are inconsistencies.

11. INFORMATION OBTAINED FROM THIRD PARTIES

11.1 Where Speedle relies on information provided from credit assistance providers or third-party sources, Speedle will conduct the following procedures to ensure the reliability of information collected:

(a) ‘spot checks’ on some of the information to re-verify it;

(b) checks to ensure that the information in preliminary assessments only comes from intermediaries that have robust compliance arrangements; and

(c) compliance procedures to actively discourage inappropriate practices (e.g. ensuring that any incentives offered to intermediaries encourage, rather than discourage, appropriate information collection practices).

11.2 Should Speedle have any reason to doubt the reliability of the information it will not rely on the information provided.

SECTION E – ENQUIRIES AND VERIFICATIONS FOR SMALL CREDIT CONTRACTS

12. ADDITIONAL ENQUIRIES AND VERIFICATION FOR SMALL CREDIT CONTRACTS

12.1 Where a customer enters into a small amount Credit Contract, Speedle will:

(a) make enquiries about whether the customer is currently in default under an existing small amount Credit Contract, or has been a debtor under two or more small amount Credit Contracts in the 90-day period before the assessment;

(b) make enquiries about the source and amount of the customer’s gross income;

(c) where the customer is in default, obtain copies of any small amount Credit Contracts under which the customer was or has been a debtor in the 90-day period before assessment;

(d) if the customer’s income includes Centrelink payments or similar, the proportion of the customer’s gross income constituted by those payments;

(e) verify the customer’s financial situation by obtaining statements for accounts into which the customer’s income is paid and recent bank account statements or credit card records (e.g. expenses can be verified by examining account statements over a period of time); and

(f) obtain and consider account statements that cover at least the immediately preceding period of 90 days if the customer holds (alone or jointly with another person) an account with an ADI into which the customer’s income is paid.

13. ‘SUBSTANTIAL HARDSHIP’ PRESUMPTIONS

13.1 Although the presumption of hardship contained in the National Credit Act has been removed, Speedle will still not enter into or offer to enter into a small amount Credit Contract with the customer if:

(a) upon making the enquiries and verifications for section 12 above, Speedle discovers that the customer:

(i) is currently in default under an existing small amount Credit Contract; or

(ii) is currently a debtor under two or more small amount Credit Contracts at the time of the assessment (wage advances and BNPL excluded); or

(b) upon making the enquiries and verifications for sections 5 to 12, Speedle discovers that the customer will only be able to comply with their financial obligations under the small amount Credit Contract by selling their principal place of residence;

13.2 However, if Speedle establishes that a customer could comply with their financial obligations under the contract without substantial hardship in spite of the circumstances described in 13.1 above, Speedle will not be prohibited from entering into a small amount Credit Contract with the customer.

14. SOURCE OF INCOME

14.1 Speedle must not enter into, or offer to enter into, a small amount Credit Contract with a customer who will be the debtor under the contract if:

(a) upon making the enquiries and verifications for subsection 12.1(b) Speedle discovers that the customer:

(i) if 21 years of age or less receives at least 50% of their gross income as payments from Centrelink payments or similar; and

(ii) receives less than an average of $1,700 in income per month; and

(iii) the repayments in a payment cycle would exceed 10% of the customer’s gross income.

SECTION F – MAKING A FINAL ASSESSMENT THAT A Credit Contract IS ‘NOT UNSUITABLE’

15. FINAL ASSESSMENT

15.1 Speedle is required to make a final assessment that a Credit Contract is ‘not unsuitable’ for the customer prior to:

(a) entering into a Credit Contract with a customer; or

(b) making unconditional representations to a customer about their eligibility to enter into a Credit Contract with Speedle; or

15.2 A final assessment must be made within:

(a) ninety (90) days before the Credit Contract is entered into; or

(b) one hundred and twenty (120) days before the Credit Contract is entered into if the credit to be provided will be used for the purchase or residential property and secured by a mortgage over the property.

16. THE ‘NOT UNSUITABLE’ REQUIREMENT

16.1 A Credit Contract is unsuitable if, at the time of the assessment, it is likely that the customer:

(a) will be unable to comply with their financial obligations under the Credit Contract (e.g. to make repayments); or

(b) will only be able to comply with their financial obligations with substantial hardship; or

16.2 In assessing whether a Credit Contract is “not unsuitable”, Speedle will:

(a) make reasonable enquiries and verifications as per sections 5 to 13 of this Policy;

(b) make an assessment that the customer is able to comply with their financial obligations without substantial hardship; and

16.3 The assessment of the customer’s capacity to meet their payment obligations will be based on the enquiries set out in section 6 and 11. Speedle will also consider the likely maximum amount to be payable under the Credit Contract (including fees) when determining whether the customer has the capacity to meet the payment obligations.

17. DETERMINING WHETHER A CREDIT WILL MEET A CONSUMER’S REQUIREMENTS AND OBJECTIVES

17.1 In determining whether a Credit Contract meets a customer’s requirements and objectives Speedle will have regard to the following factors:

(a) the nature of the Credit Contract requested by the customer, and the customer’s stated objectives in obtaining the Credit Contract;

(b) if the customer has more than one requirement or objective, the relative importance of each to the customer (e.g. whether the cost of the Credit Contract or flexibility to make later changes is more important to the customer);

(c) if the credit is to purchase a specific item, the term of the credit relative to the likely useful life of the asset;

(d) the interest rate, fees and charges applying to the Credit Contract;

(e) the customer’s understanding of the proposed Credit Contract;

(f) the complexity of the Credit Contract, and whether a more basic product could meet the customer’s needs;

(g) if other expenses, such as premiums for insurance relating to the Credit Contract, are to be financed, whether the customer is aware of this and accepts the additional costs of these expenses being financed;

(h) whether the customer will need to finance a large final payment under the Credit Contract;

(i) in relation to switching, the extent to which switching to the new Credit Contract will benefit the customer; and

(j) any other factors Speedle considers relevant.

18. ASSESSING SUBSTANTIAL HARDSHIP

18.1 In determining whether a Credit Contract will likely cause hardship to the customer, Speedle will have regard to the following factors:

(a) how much of a surplus there is between the money the customer is likely to have remaining after their ongoing expenses have been deducted from their after-tax income and the proposed additional repayments;

(b) the source of income (including whether all or part of the customer’s income is sourced from Centrelink payments or similar);

(c) how consistent and reliable the customer’s income is (and the size of the payment obligations relative to their income level);

(d) whether the customer’s expenses are likely to be significantly higher than average (e.g. because they live in a remote area);

(e) the customer’s other debt repayment obligations and similar commitments (e.g. child support);

(f) whether the customer is likely to have to sell their assets (e.g. car) to meet their payment obligations; and

(g) whether the customer is able to meet their payment obligations under a Credit Contract from income, rather than an equity asset.

18.2 Additionally Speedle has developed appropriate systems to respond to hardship requests from customers. Please refer to Speedle’s Hardship Policy.

18.3 The National Credit Act outlines two circumstances where it is presumed that a customer would only be able to comply with the financial obligations with substantial hardship, unless the contrary can be proved by the customer:

(a) the customer can only comply with their financial obligations by selling their principal place of residence; and

(b) where the contract is a small amount Credit Contract and either:

(i) at the time of the assessment, the consumer is a debtor under another small amount Credit Contract and is in default in payment of an amount under the contract; or

(ii) the consumer is a debtor under two or more small amount Credit Contracts at the time of assessment.

19. SWITCHING AND REFINANCING

19.1 Where Speedle is engaging in switching or refinancing activities, Speedle will consider the following additional factors:

(a) whether entering the new Credit Contract would result in overall cost savings to the customer that are likely to override any loss of benefits; or

(b) whether entering the new Credit Contract may result in minimal cost savings, but the new Credit Contract better meets the customer’s requirements and objectives (e.g. because of convenience, greater flexibility or particular tailored features such as a redraw facility on a mortgage); and

(d) the costs of the switch or refinancing and all associated fees and other charges.

20. KEEPING RECORDS

20.1 Speedle will keep a record of materials that it gathers and are used in making a final assessment as to whether the Credit Contract is ‘not unsuitable’.

20.2 The record must be kept in a form that will enable Speedle to give the customer a written copy of the assessment if a request is made.

20.3 All records of these enquiries and verifications and any other records in relation to this Policy must be kept for seven (7) years, or as otherwise stipulated in the Speedle Document Retention Policy.

21. PROVIDING A WRITTEN ASSESSMENT

21.1 Speedle will provide free of charge to the customer a copy of the written assessment that the Credit Contract is ‘not unsuitable’ for the customer when requested by the customer within:

(a) seven (7) business days if requested within two (2) years of the start of the Credit Contract; or

(b) twenty-one (21) business days if requested after two (2) years.

21.2 Speedle is not required to provide a copy of the written assessment if the Credit Contract is not entered into.

21.3 Speedle will ensure that the written assessment:

(a) is concise and easy for the customer to understand, and includes reference to the relevant factual information provided by the customer that Speedle used to assess the Credit Contract as ‘not unsuitable’;

(b) includes a record of the financial information obtained and the requirements and objectives communicated by the customer so that the customer has the opportunity to check the factual basis on which Speedle made the assessment;

(c) reflects the situation in which the borrower’s capacity to make payments depends on the availability of income provided by another person.;

(d) assists the customer in understanding that the Credit Contract has been assessed as ‘not unsuitable’ for them; and

(e) assists Speedle in demonstrating compliance with the responsible lending obligations.

21.4 The written assessment provided by Speedle to the customer should include a record of the financial information obtained about the customer, and the requirements and objectives communicated to Speedle by the customer.

21.5 If Speedle is an assignee, Speedle will have in place arrangements with the credit provider/lessor who assigned their rights to Speedle that will ensure Speedle can access or prepare a written copy of the assessment, and give it to the consumer if a request is made.

21.6 If the customer seeks a reverse mortgage information statement Speedle will give them Speedle’s reverse mortgage information statement.

21.7 The customer will be given the opportunity by Speedle to check the factual basis on which Speedle made the assessment which Speedle has provided to the customer.

SECTION H – CONCLUSION

22. TRAINING

22.1 Employees of Speedle who deal with clients need to have an understanding of the Responsible Lending Policy and procedures. Consequently, all employees of will receive regular training and information about Speedle’s Responsible Lending procedures and obligations. This training will be scheduled and conducted at the discretion of the Compliance Officer.

23. ENFORCEMENT AND REVIEW

23.1 Non-compliance with this Policy may result in disciplinary action being taken against the Representative involved and may also result in prosecution under the law where that act is illegal. This may include re-assessment of bonus qualification, termination of employment and/or fines and imprisonment (in cases that contravene for instance the National Credit Act).

23.2 Speedle’s Compliance Officer is responsible for monitoring the implementation and ongoing compliance with this Policy. Refer to the Breaches and Incidents Policy for further information.

24. AUDITS AND RECORDS

24.1 The policies and procedures outlined in this document must be audited as part of any Speedle’s compliance audit.

24.2 All records of these audits and any other records in relation to this Policy must be kept for seven (7) years, or as otherwise stipulated in the Speedle’s Document Retention Policy.

25. POLICY REVIEW

25.1 This Responsible Lending Policy will be reviewed on at least an annual basis by the Compliance Officer, having regard to the changing circumstances of Speedle. The Compliance Officer will then report to the Director on compliance with this Policy.

Issued by Speedle Pty Limited –15 January 2024

‍

Illion Bank Statement Terms

Updated on

October 1, 2023

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Illion's Bank Statement Terms and Conditions can be access at: End User Terms and Conditions | BankStatements

Credit Guide

Updated on

January 15, 2024

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CREDIT GUIDE

Speedle Pty Limited (“Speedle, we or us”) ACN 668 001 045, Australian Credit Licence 549307, of Salesforce Tower, Level 22, 180 George Street Sydney NSW 2000, has created this Credit Guide to help you decide whether to enter into a credit contract with us.

This guide contains important information about:

• our key obligations before providing credit to you.

• our complaints procedures and how you can access them.

Our responsible lending obligations

We are required by law to ensure that any credit we provide to you is not unsuitable. A credit contract or increase in credit limit will be unsuitable if:

• it is likely that you will be unable to comply with the financial obligations under the contract, or could only comply with substantial hardship; and/or

• the contract does not meet your requirements or objectives.

To determine whether the contract will be unsuitable, we will only take into consideration information regarding your financial situation, requirements or objectives, that, at the time of entering the contract we had reason to believe was true. We might also decline your application for other reasons.

To help us to make this assessment we will:

• make reasonable inquiries about your financial situation and requirements and objectives that we believe are relevant to the credit you are applying for;

• take reasonable steps to verify your financial information; and

• use this information to determine whether the credit is unsuitable for you.

Getting a copy of the suitability assessment

You can ask us for a copy of the suitability assessment. We’re required to give you a copy of the assessment without charge within the following timeframes:

• before you enter the credit contract or increase the credit limit if you ask us to before this time;

• within seven business days if you ask us within two years of entering into the credit contract or increasing your credit limit;

• within 21 business days if you ask us more than two years after entering into the credit contract or increasing your credit limit.

We don’t have to provide you a copy of the assessment if the credit contract is not entered into or the credit limit is not increased.

Our internal dispute resolution process

If you have any feedback or complaints you can contact us via our contact details set out below. You should explain the details of your complaint as clearly as you can. You may do this verbally or in writing. We will try to resolve your complaint quickly and fairly.

Phone: 61 2 8365 2322

Email: complaints@speedle.com.au

Mail: Salesforce Tower, Level 22, 180 George Street Sydney NSW 2000

We’ll acknowledge receipt of your complaint within 2 business days, and we’ll try to resolve it within 5 business days. If the matter is more complex, it may take a longer time to resolve. In such cases, we’ll ensure we keep you informed of the progress of the matter throughout

Our external dispute resolution scheme

If you are not satisfied with our response or handling of your complaint, you can lodge a complaint with the free, independent external dispute resolution scheme, the Australian Financial Complaints Authority (AFCA). AFCA’s details are set out below.

Phone: 1800 931 678

Website: afca.org.au

Email: info@afca.org.au

Mail: GPO Box 3 Melbourne VIC 3001

Issued by Speedle Pty Limited – 15 January 2024

‍

Privacy Policy

Updated on

January 15, 2024

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SECTION A – INTRODUCTION

1. INTRODUCTION

1.1 As part of Speedle Pty Limited’s (“Speedle”) process to ensure that it continues to maintain the highest levels of professional integrity and ethical conduct, Speedle has adopted this Privacy Policy (“Policy”) to manage Personal Information in an open and transparent manner.

1.2 The provisions of this Policy will assist Speedle in complying with the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles in protecting the Personal Information Speedle holds about its clients.

2. WHEN DOES THIS POLICY APPLY?

2.1 This Policy applies to all representatives and employees of Speedle at all times and the requirements remain in force on an ongoing basis.

3. GLOSSARY

TERM / DEFINITION

Affected Information Recipient means:

(a) a mortgage insurer; or

(b) a trade insurer; or

(d) a person who:

(i) is involved in processing an application for credit made to Speedle; or

(ii) manages credit provided by Speedle; or

(e) an entity, a legal adviser of the entity or professional adviser of the entity.

APP Entity means an agency or organisation as defined in section 6 of the Privacy Act 1988.

Australian law means

(a) an Act of the Commonwealth or of a State or Territory;

(b) or regulations, or any other instrument, made under such an Act; or

(d) a rule of common law or equity.

Collects Speedle collects Personal Information only if Speedle collects the Personal Information for inclusion in a record or generally available publication.

Court/Tribunal Order means an order, direction or other instrument made by:

(a) a court; or

(b) a tribunal; or

(d) a magistrate (including a magistrate acting in a personal capacity) or a person acting as a magistrate; or

(e) a member or an officer of a tribunal;

and includes an order, direction or other instrument that is of an interim or interlocutory nature.

CR Code refer to the Privacy (Credit Reporting) Code 2014 (Version 2). This is written code of practice about credit reporting. The CR code supplements the credit reporting provisions contained in Part IIIA of the Privacy Act 1988. A breach of the CR code is a breach of the Privacy Act 1988. The CR code is registered on the OAIC Privacy Register.

Credit Eligibility Information means Credit Reporting Information that was disclosed to the Credit Provider by a Credit Reporting Body or CP Derived Information. Credit eligibility information is generally held by a Credit Provider and may be disclosed to Affected Information Recipients and other entities in specific circumstances.

Credit Provider The following entities are included as credit providers for the purposes of the Privacy Act:

(a) a bank;

(b) an organisation or Small Business Operator if a substantial part of its business is the provision of credit, such as a building society, finance company or a credit union;

(d) an organisation or Small Business Operator that supplies goods and services where payment is deferred for seven (7) days or more, such as a telecommunications carriers and energy and water utilities; and

(e) certain organisations or Small Business Operators that provide credit in connection with the hiring, leasing or renting of goods.

Importantly, the following entities are not credit providers:

(a) real estate agents;

(b) general insurers; and

CP Derived Information means any Personal Information (other than Sensitive Information) about an individual:

(a) that is derived from Credit Reporting Information about the individual that was disclosed to a Credit Provider by a Credit Reporting Body; and

(b) that has any bearing on the individual’s credit worthiness; and

Credit Information means Personal Information that is:

(a) identification information about the individual; or

(b) consumer credit liability information about the individual; or

(d) a statement that an information request has been made in relation to the individual by a Credit Provider, mortgage insurer or trade insurer; or

(e) the type of consumer credit or commercial credit, and the amount of credit, sought in an application:

(i) that has been made by the individual to a Credit Provider; and

(ii) in connection with which the provider has made an information request in relation to the individual; or

(f) default information about the individual; or

(g) payment information about the individual; or

(h) new arrangement information about the individual; or

(i) court proceedings information about the individual; or

(j) personal insolvency information about the individual; or

(k) publicly available information about the individual:

(i) that relates to the individual’s activities in Australia or the external Territories and the individual’s credit worthiness; and

(ii) that is not court proceedings information about the individual or information about the individual that is entered or recorded on the National Personal Insolvency Index; or

(l) the opinion of a Credit Provider that the individual has committed, in circumstances specified by the provider, a serious credit infringement in relation to consumer credit provided by the provider to the individual.

Credit Reporting Body means a business or undertaking that involves collecting, holding, using or disclosing Personal Information about individuals for the purpose of, or for purposes including the purpose of, providing an entity with information about the credit worthiness of an individual.

Credit Reporting Information means Credit Information or Credit Reporting Body derived information about an individual.

De-identified Personal Information is de-identified if the information is no longer about an identifiable individual or an individual who is reasonably identifiable.

Holds Speedle holds Personal Information if it has possession or control of a record that contains the Personal Information.

Identifier of an individual means a number, letter or symbol, or a combination of any or all of those things, that is used to identify the individual or to verify the identity of the individual, but does not include:

(a) the individual’s name; or

(b) the individual’s ABN (within the meaning of the A New Tax System (Australian Business Number) Act 1999); or

Permitted General Situation As defined in s16A of the Privacy Act 1988

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a) whether the information or opinion is true or not; and

(b) whether the information or opinion is recorded in a material form or not.

Sensitive Information means

(a) information or an opinion about an individual’s:

(i) racial or ethnic origin; or

(ii) political opinions; or

(iii) membership of a political association; or

(iv) religious beliefs or affiliations; or

(v) philosophical beliefs; or

(vi) membership of a professional or trade association; or

(vii) membership of a trade union; or

(viii) sexual orientation or practices; or

(ix) criminal record;

that is also Personal Information; or

(b) health information about an individual; or

(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

Small Business Operators is a person or organisation that has an annual turnover of $3,000,000 or less. For the purposes of the Privacy Act 1988 health service providers or businesses that trade in Personal Information are not Small Business Operators.

SECTION B – COLLECTION OF INFORMATION (SOLICITED INFORMATION)

This Section B applies to the collection of information that is solicited by Speedle.

4. PERSONAL INFORMATION

4.1 The Personal Information Speedle collects may include the following:

(a) name;

(b) address;

(d) gender;

(e) marital status;

(f) occupation;

(g) bank account details;

(h) contact details (including telephone, facsimile and e-mail);

(i) financial information (including transactional and trading history); and

(j) any other information Speedle considers necessary to their functions and activities.

4.2 Speedle must not collect Personal Information (other than Sensitive Information) unless the information is reasonably necessary for one or more of Speedle’s functions or activities.

4.3 Speedle’s functions or activities include:

(a) operate as credit provider to provide unsecured personal loans that relate to:

(i) Personal loans

(ii) Small amount loans;

(iii) Medium amount loans..

(b) typical consumers are Australian Citizens and Residents, residing in Australia, over the age of 18 years, employed with a level of income which supports the affordability of credit product(s) provided by Speedle.

5. SENSITIVE INFORMATION

5.1 Speedle must not collect Sensitive Information about an individual unless:

(a) the individual consents to the collection of the information and the information is reasonably necessary for one or more of Speedle’s functions or activities (as described in section 4.3); or

(b) the collection of the information is required or authorised by or under an Australian law or a Court/Tribunal Order; or

(d) a permitted health situation exists in relation to the collection of the information by Speedle.

6. CREDIT-RELATED INFORMATION

6.1 Where Speedle receives a request for credit, the prospective client will be required to provide Speedle with Credit Information. Please refer to Speedle’s Credit Reporting Policy for further information.

7. MEANS OF COLLECTION

7.1 Speedle must only collect Personal Information by lawful and fair means.

7.2 Speedle must only collect Personal Information about an individual from the individual (rather than someone else), unless it is unreasonable or impracticable to do so or the individual has instructed Speedle to liaise with someone else.

7.3 Speedle will collect Personal Information from an individual when:

(a) Speedle’s Application Form is completed;

(b) a Client provides the information to Speedle’s representatives over the telephone or via email;

8. PURPOSE OF COLLECTION

8.1 If an individual is acquiring or has acquired a product or service from Speedle, the individual’s Personal Information will be collected and held for the purposes of:

(a) checking whether an individual is eligible for Speedle’s product or service;

(b) disclosing an individual’s Credit Information to any of Speedle’s related companies that are also are considering whether to provide credit to the individual;

(d) managing and administering Speedle’s product or service;

(e) to collect payments that are owed to Speedle in respect of any credit that has previously provided to the individual;

(f) protecting against fraud, crime or other activity which may cause harm in relation to Speedle’s products or services;

(g) responding to a complaint;

(h) where the individual otherwise expressly consents to the use or disclosure.

(i) complying with legislative and regulatory requirements in any jurisdiction;

(j) to assist Speedle in the running of its business.

8.2 Speedle may also collect Personal information for the purposes of letting an individual know about products or services that might better serve their needs or other opportunities in which they may be interested. Please refer to Section G for further information.

SECTION C – COLLECTION OF INFORMATION (UNSOLICITED INFORMATION)

9. DEALING WITH UNSOLICITED PERSONAL INFORMATION

9.1 If Speedle:

(a) receives Personal Information about an individual; and

(b) the information is not solicited by Speedle

Speedle must, within a reasonable period after receiving the information, determine whether or not it was permitted to collect the information under Section B above.

9.2 Speedle may use or disclose the Personal Information for the purposes of making the determination under paragraph 9.1.

9.3 If Speedle:

(a) determines that it could not have collected the Personal Information; and

(b) the information is not contained in a Commonwealth record,

Speedle must as soon as practicable, destroy the information or ensure that the information is De-identified, only if it is lawful and reasonable to do so.

SECTION D – NOTIFICATION OF THE COLLECTION OF INFORMATION

10. CREDIT REPORTING AND PRIVACY STATEMENT

10.1 Speedle’s Director must ensure that at all times it maintains a clearly expressed and up-to-date Credit Reporting and Privacy Statement that:

(a) is current and reflects the latest applicable Australian laws; and

(b) contains the following information:

(i) the kinds of Credit Information, Credit Eligibility Information and Personal Information that Speedle collects and holds, and how Speedle collects and holds that information;

(ii) the kinds of CP Derived Information that Speedle usually derives from Credit Reporting Information disclosed to Speedle by a Credit Reporting Body;

(iii) the purposes for which Speedle collects, holds, uses and discloses Credit Information, Credit Eligibility Information and Personal Information;

(iv) how an individual may access Credit Eligibility Information and Personal Information held by Speedle and seek a correction of such information;

(v) how an individual may complain about a failure of Speedle to comply with the Privacy Act 1988 or CR Code and how Speedle will deal with such a complaint;

(vi) whether Speedle is likely to disclose Credit Information and Credit Eligibility Information to entities that do not have an Australian link; and

(vii) where Speedle is likely to disclose Credit Information or Credit Eligibility Information to entities that do not have an Australian link, the countries in which such entities are likely to be located.

10.2 Speedle must ensure that Speedle’s Credit Reporting and Privacy Statement is available free of charge and in such form as appropriate. Speedle will make the Credit Reporting and Privacy Statement available on its website.

10.3 If the Credit Reporting and Privacy Statement is requested in a particular form, Speedle will take such steps as are reasonable to provide the Credit Reporting and Privacy Statement in the form requested.

SECTION E – USE OR DISCLOSURE OF INFORMATION

11. USE OR DISCLOSURE OF PERSONAL INFORMATION

11.1 Where Speedle holds Personal Information about an individual that was collected for a particular purpose (“the primary purpose”), Speedle must not use or disclose the information for another purpose (“the secondary purpose”) unless:

(a) the individual has consented to the use or disclosure of the information; or

(b) the individual would reasonably expect Speedle to use or disclose the information for the secondary purpose and the secondary purpose is:

(i) directly related to the primary purpose (if the information is Sensitive Information); or

(ii) related to the primary purpose (if the information is not Sensitive Information); or

(c) the use or disclosure of the information is required or authorised by or under an Australian law or a Court/Tribunal Order; or

(d) a Permitted General Situation exists in relation to the use or disclosure of the information by Speedle; or

(e) Speedle reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

11.2 Where Speedle uses or discloses Personal Information in accordance with section 11.1(e), Speedle will keep a copy of this disclosure (e.g. the email or letter used to do so).

11.3 This section 11 does not apply to:

(a) Personal Information for the purposes of direct marketing; or

(b) government related identifiers.

11.4 If Speedle collects Personal Information from a related body corporate, this section 11 applies as if Speedle’s primary purpose for the collection was the primary purpose for which the related body corporate collected the information.

12. WHO DOES Speedle DISLCOSE PERSONAL INFORMATION TO?

12.1 Speedle may disclose Personal Information collected from clients and prospective clients to the following:

(a) organisations involved in providing, managing or administering Speedle’s products or services such as third party suppliers, e.g. printers, posting services and our advisers;

(b) organisations involved in maintaining, reviewing and developing Speedle’s business systems, procedures and infrastructure, including testing or upgrading Speedle’s computer systems;

(d) organisations involved in the payments system, including financial institutions, merchants and payment organisations;

(e) organisations involved in product planning and development;

(f) other organisations, who jointly with Speedle’s, provide its products or services;

(g) authorised representatives who provide Speedle’s products or services on its behalf;

(h) the individual’s representatives, including your legal advisers;

(i) debt collectors;

(j) Speedle’s financial advisers, legal advisers or auditors;

(k) fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;

(l) external dispute resolution schemes;

(m) regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.

SECTION F – DIRECT MARKETING

13. DIRECT MARKETING

13.1 Speedle must not use or disclose the Personal Information it holds about an individual for the purpose of direct marketing.

14. EXCEPTION – PERSONAL INFORMATION OTHER THAN SENSITIVE INFORMATION

14.1 Speedle may use or disclose Personal Information (other than Sensitive Information) about an individual for the purposes of direct marketing if:

(a) Speedle collected the information from the individual; and the individual would reasonably expect Speedle to use or disclose the information for that purpose; or

(b) Speedle has collected the information from a third party; and either:

(i) Speedle has obtained the individual’s consent to the use or disclose the information for the purpose of direct marketing; or

(ii) it is impracticable for Speedle to obtain the individual’s consent; and

(c) Speedle provides a simple way for the individual to opt out of receiving direct marketing communications from Speedle;

(d) in each direct marketing communication with the individual Speedle:

(i) includes a prominent statement that the individual may opt out of receiving direct marketing; or

(ii) directs the individual’s attention to the fact that the individual may opt out of receiving direct marketing; and

(e) the individual has not made a request to opt out of receiving direct marketing.

15. EXCEPTION – SENSITIVE INFORMATION

15.1 Speedle may use or disclose Sensitive Information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.

16. REQUESTS TO STOP DIRECT MARKETING

16.1 Where Speedle uses or discloses Personal Information about an individual for the purposes of direct marketing by Speedle or facilitating direct marketing by another organisation, the individual may request:

(a) that Speedle no longer provide them with direct marketing communications;

(b) that Speedle does not use or disclose the individual’s Personal Information for the purpose of facilitating direct marketing by another organisation;

16.2 Where Speedle receives a request from an individual under section 16.1, Speedle will:

(a) give effect to the request under section 16.1(a) or 16.1(b) within a reasonable period after the request is made and free of charge; and

(b) notify the individual of the source of the information, if the individual requests it, unless it is impracticable or unreasonable to do so.

16.3 This Section F does not apply to the extent that the following laws apply:

(a) the Do Not Call Register Act 2006;

(b) the Spam Act 2003; or

SECTION G – CROSS BORDER DISCLOSURE OF INFORMATION

17. DISCLOSING PERSONAL INFORMATION TO CROSS BORDER RECIPIENTS

17.1 Where Speedle discloses Personal Information about an individual to a recipient who is not in Australia and who is not Speedle or the individual, Speedle must ensure that the overseas recipient does not breach the Australian Privacy Principles (with the exception of APP1).

17.2 The countries we may disclose an individual’s Personal Information to include:

(a) Australia; and

(b) New Zealand.

17.3 Section 17.1 does not apply where:

(a) Speedle reasonably believes that:

(ii) there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme; or

(b) both of the following apply:

(i) Speedle has informed the individual that if they consent to the disclosure of information Speedle will not take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles; and

(ii) after being so informed, the individual consents to disclosure;

(c) the disclosure of the information is required or authorised by or under an Australian law or a Court/Tribunal Order; or

(d) a Permitted General Situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) of the Privacy Act 1988) exists in relation to the disclosure of the information by Speedle.

SECTION H – ADOPTION, USE OR DISCLOSURE OF GOVERNMENT IDENTIFIERS

18. ADOPTION OF GOVERNMENT RELATED IDENTIFIERS

18.1 Speedle must not adopt a government related identifier of an individual as its own identifier unless:

(a) Speedle is required or authorised by or under an Australian law or a Court/Tribunal Order to do so; or

(b) the identifier, Speedle and the circumstances of the adoption are prescribed by regulations.

19. USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS

19.1 Before using or disclosing a government related identifier of an individual, Speedle must ensure that such use or disclosure is:

(a) reasonably necessary for Speedle to verify the identity of the individual for the purposes of the organisation’s activities or functions; or

(b) reasonably necessary for the organisation to fulfil its obligations to an agency or a State or Territory authority; or

(d) within a Permitted General Situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) of the Privacy Act 1988; or

(e) reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or

(f) the identifier, Speedle and the circumstances of the adoption are prescribed by regulations.

SECTION I – INTEGRITY OF INFORMATION

20. QUALITY OF INFORMATION

20.1 Speedle will ensure that the Personal Information it collects and the Personal Information it uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up to date, complete and relevant.

21. SECURITY OF INFORMATION

21.1 Speedle will ensure that it protects any Personal Information it holds from misuse, interference, loss, unauthorised access, modification and disclosure.

21.2 Speedle will take reasonable steps to destroy or de-identify Personal Information it holds where:

(a) Speedle no longer needs the Personal Information for any purpose for which the information may be used or disclosed by Speedle; and

(b) the information is not contained in a Commonwealth record; and

22. STORAGE OF INFORMATION

22.1 Speedle stores Personal Information in different ways, including:

(a) hard copy on site at Speedle’s head office;

(b) electronically secure data centres which are located in Australia and owned by either Speedle or external service providers;

22.2 In order to ensure Speedle protects any Personal Information it holds from misuse, interference, loss, unauthorised access, modification and disclosure, Speedle implements the following procedure/system:

(a) access to information systems is controlled through identity and access management;

(b) employees are bound by internal information securities policies and are required to keep information secure;

(d) Speedle regularly monitors and reviews its compliance with internal policies and industry best practice; and

SECTION J – ACCESS TO PERSONAL INFORMATION

23. ACCESS

23.1 Speedle must give an individual access to the Personal Information it holds about the individual if so requested by the individual.

23.2 Speedle must respond to any request for access to Personal Information within a reasonable period after the request is made.

23.3 Speedle must give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so and must take such steps as are reasonable in the circumstances to give access in a way that meets the needs of Speedle and the individual.

23.4 Speedle must not charge an individual for making a request, and must not impose excessive charges for the individual to access their Personal Information.

24. EXCEPTIONS

24.1 Speedle is not required to give an individual access to their Personal Information if:

(a) Speedle reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or

(b) giving access would have an unreasonable impact on the privacy of other individuals; or

(d) the information relates to existing or anticipated legal proceedings between Speedle and the individual, and would not be accessible by the process of discovery in those proceedings; or

(e) giving access would reveal intentions of Speedle in relation to negotiations with the individual in such a way as to prejudice those negotiations; or

(f) giving access would be unlawful; or

(g) denying access is required or authorised by or under an Australian law or a Court/Tribunal Order; or

(h) Speedle has reason that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or

(i) giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or

(j) giving access would reveal evaluative information generated within Speedle in connection with a commercially sensitive decision-making process.

25. REFUSAL TO GIVE ACCESS

25.1 If Speedle refuses to give access in accordance with section 23 or to give access in the manner requested by the individual, Speedle will give the individual a written notice that sets out:

(a) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and

(b) the mechanisms available to complain about the refusal; and

25.2 Where Speedle refuses to give access under section 24.1(j) Speedle may include an explanation of the commercially sensitive decision in its written notice of the reasons for denial.

SECTION K – CORRECTION OF INFORMATION

26. CORRECTION OF INFORMATION

26.1 Speedle must take reasonable steps to correct all Personal Information, having regard to the purpose for which the information is held where:

(a) Speedle is satisfied the information is inaccurate, out of date, incomplete, irrelevant or misleading; or

(b) the individual requests Speedle corrects the information.

26.2 Where Speedle corrects Personal Information about an individual that Speedle previously disclosed to another APP Entity and the individual requests Speedle to notify the other APP Entity of the correction, Speedle must take reasonable steps to give that notification, unless it is impracticable or unlawful to do so.

27. REFUSAL TO CORRECT INFORMATION

27.1 If Speedle refuses to correct Personal Information as requested by the individual, Speedle will give the individual a written notice that sets out:

(a) the reasons for the refusal except to the extent that it would be unreasonable to do so; and

(b) the mechanisms available to complain about the refusal; and

28. REQUEST FROM A CLIENT TO ASSOCIATE A STATEMENT WITH THEIR INFORMATION

28.1 If:

(a) Speedle refuses to correct Personal Information as requested by the individual; and

(b) the individual requests that Speedle associate a statement noting that the information is inaccurate, out of date, incomplete, irrelevant or misleading, with the individual’s information,

Speedle must take such steps as are reasonable in the circumstances to associate the statement (as described in section 28.1(b)) with the individual’s Personal Information. The statement should be associated with the information in such a way that will make the statement apparent to users of the information.

29. DEALING WITH REQUESTS

29.1 Speedle must:

(a) respond to requests under this Section K within thirty (30) days after the request is made; and

(b) must not charge the individual for the making of the request, for correcting the Personal Information or for associating the statement with the Personal Information.

SECTION L – MAKING A PRIVACY COMPLAINT

30. COMPLAINTS

30.1 Speedle offers a free internal complaint resolution scheme to all customers. Should a client have a privacy complaint, they are to contact Speedle to discuss their concerns using the following contact details:

(a) Email: complaints@speedle.com.au

(b) Phone: 02 8365 2322

30.2 To assist Speedle in helping customers, Speedle asks customers to follow a simple three-step process:

(a) gather all supporting documents relating to the complaint;

(b) contact Speedle to review your situation and if possible, resolve your complaint immediately; and

(c) if the matter is not resolved to the customer’s satisfaction, customers are encouraged to contact Speedle’s Complaints Officer on 02 8365 2322 or put their complaint in writing and send it to complaints@speedle.com.au.

30.3 Speedle will rectify any breach if the complaint is justified and takes necessary steps to resolve the issue.

30.4 In certain situations, to deal with a complaint it may be necessary to consult with third parties. However, any disclosure of Personal Information to third parties will be provided with the customer’s authority and consent.

30.5 After a complaint has been received, Speedle sends the customer a written notice of acknowledgement setting out the process. The complaint is investigated, and the decision sent to the customer within thirty (30) days unless the customer has agreed to a longer time. If a complaint cannot be resolved within the agreed time frame or a decision could not be made within thirty (30) days of receipt, a notification will be sent to the customer setting out the reasons and specifying a new date when the customer can expect a decision or resolution.

30.6 If the customer is not satisfied with Speedle’s internal privacy practices or the outcome in respect to complaint, the customer may approach the OAIC with their complaint:

Office of the Australian Information Commissioner

Address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Website: oaic.gov.au

SECTION M – MISCELLANEOUS

31. POLICY BREACHES

31.1 Breaches of this Policy may lead to disciplinary action being taken against the relevant party, including dismissal in serious cases and may also result in prosecution under the law where that act is illegal. This may include re-assessment of bonus qualification, termination of employment and/or fines (in accordance with the Privacy Act 1988.

31.2 Staff are trained internally on compliance and their regulatory obligation to Speedle. They are encouraged to respond appropriately to and report all breaches of the law and other incidents of non-compliance, including Speedle’s policies, and seek guidance if they are unsure.

31.3 Staff must report breaches of this Policy directly to the Director.

32. RETENTION OF NOTIFIABLE DATA BREACH FORMS

32.1 The Compliance Officer will retain the completed Notifiable Data Breach Forms for seven (7) years in accordance with Speedle’s Document Retention Policy. The completed forms are retained for future reference and review.

32.2 As part of their training, all staff are made aware of the need to practice thorough and up to date record keeping, not only as a way of meeting Speedle’s compliance obligations, but as a way of minimising risk.

33. POLICY REVIEW

33.1 Speedle’s Privacy Policy will be reviewed on at least an annual basis by the Compliance Officer of Speedle, having regard to the changing circumstances of Speedle. The Compliance Officer will then report to the Director on compliance with this Policy.

Issued by Speedle Pty Limited – 15 January 2024

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Terms and Conditions

Updated on

January 15, 2024

Download PDF

1. Introduction

1.1 This document is the Terms & Conditions of Speedle Pty Limited ABN: 86 668 001 045 (“Speedle, we or us”).

1.2 Before you can use the Website and the Apply Now, Application Form and Self Service Area (together referred to as the “Speedle Portal”) you must read, accept and agree to be bound by these Terms & Conditions

1.3 This Website and Speedle Portal is owned and operated by Speedle Pty Limited (Speedle) on the World Wide Web.

1.5 The Speedle Portal is available for you to:

(a) access conditional on your acceptance without alteration of the terms and conditions set out below on this linked page. By continuing to access the Speedle Portal you are agreeing to the Terms & Conditions set out below and Speedle’s Privacy Policy.

(b) provide information about you, a Customer, or Customer Account on your acceptance without alteration of the terms and conditions set out below on this linked page. By continuing to provide information about you, a Customer or Customer Account you are agreeing to the Terms & Conditions set out below and Speedle’s Privacy Policy.

1.6 To use and gain access to the Speedle Portal you must:

(a) create a Customer Account and provide a login and password;

(b) be a Customer or an Authorised Representative of a Customer;

(d) verify your identity on the Speedle Portal by providing your date of birth and any other information requested in the mandatory fields of the Speedle Portal.

1.7 You agree:

(a) to maintain and keep safe:

(i) your Customer login and password;

(ii) any the link received from Speedle via SMS and/or Email;

(b) to immediately notify Speedle of any unauthorised use or access of the link and/or Customer Account;

(c) to ensure you exit the Customer Account and Speedle Portal at the end of the session and clear your internet cookies and history;

(d) that Speedle is not liable for any claim, loss or damage if you fail to comply with Clause (a) to 1.7(c) above.

1.8 If you have any questions or comments regarding the Speedle Portal, please contact Speedle by:

Email privacy@speedle.com.au ;or

Phone: 02 8365 2322

Post: Speedle, Salesforce Tower, Level 22, 180 George Street Sydney NSW 2000

SECTION B – DEFINITIONS

2. Definitions

2.1 In these Terms & Conditions:

(a) Authorised Representative means an individual who is authorised by a Customer to act on their behalf in respect of a Customer Account.

(b) Business Day means every weekday except for Australian National Public Holidays.

(d) Customer means an individual that has applied for a Loan with Speedle or is a Client.

(e) Customer Account means an account with Speedle relating to a Loan and/or Loan application by a Customer to Speedle or a Client.

(f) Loan means the amount a Customer owes to Speedle or a Client in respect of a Customer Account.

(g) Speedle means Speedle Pty Limited ABN: 86 668 001 045.

(h) Speedle Portal means this the Website and the Apply Now, Application Form and Self Service Area owned and operated by Speedle Pty Limited on the World Wide Web.

(i) We, us and our refers to Speedle.

(j) You and your refers to the individual that has accessed the Speedle Portal.

SECTION C – SPEEDLE PORTAL

3. Speedle Portal

3.1 The Speedle Portal enables you to:

(a) Apply for a Loan with Speedle;

(b) Review Loan details and payment schedules;

(d) Send and receive information regarding:

(i) Customer Account(s);

(ii) Customer(s) details including personal information;

(iii) Customer Bank Account Data;

(iv) Customer documents;

(v) Offers and services provided by Speedle.

(e) Make Payments:

(i) Including one-off or recurring payments;

(A) By Direct Debit;

(B) By Debit Card or Credit Card.

SECTION D – USE OF MATERIAL ON THE SPEEDLE PORTAL

4. Use of Material on the Speedle Portal

4.1 Generally:

(a) Except for the limited use set out in clause 4.2 you may not use the Speedle Portal, or the material contained on it, for any purpose. This involves:

(i) the reproduction of the material in any material form;

(ii) the distribution of the material in any material form;

(iii) re-transmission of the material by any medium of communication; World Wide Web;

(iv) “framing” the material on the Speedle Portal with other material on any other World Wide Web site.

(b) The above are unlawful in any jurisdiction and are specifically prohibited by these Terms & Conditions.

4.2 Notwithstanding the above restrictions on use of the material on the Speedle Portal, you may download material from the Speedle Portal for your personal non-commercial use provided you do not remove any copyright and trade mark notices contained on the material.

4.3 You may not modify or copy:

(a) the layout of the Speedle Portal; or

(b) any computer software and code contained in the Speedle Portal.

4.4 Speedle reserves all intellectual property rights, including, but not limited to, copyright in material and/or services provided by it. The material provided on the Speedle Portal is provided for personal use only and may not be:

(a) re-sold and/or re-distributed in any material form;

(b) stored in any storage media; and/or

without the prior written consent of Speedle.

SECTION E – LINKS TO OTHER WEBSITES

5. Links to Other Websites

5.1 The Speedle Portal may contain links to sites on the World Wide Web owned and operated by third parties and which are not under the control of Speedle.

5.2 In relation to the other sites on the World Wide Web, which are linked to the Speedle Portal, Speedle:

(a) provides the links to other sites as a convenience to you and the existence of a link to other sites does not imply any endorsement by Speedle of the linked site;

(b) is not responsible for the availability or material contained on those linked sites;

(c) does not endorse and is not responsible or liable for any content, advertising, goods, services or other materials on or available on or from such linked sites; and

(d) is not responsible or liable, either directly or indirectly, for any claim, damage and/or loss caused or alleged to be caused, by or in connection with the use of or reliance on any such content, advertising, goods, services or other materials on or available on or from such linked sites.

SECTION F – PAYMENTS

6. Payments

6.1 If you make a payment, set up a payment arrangement and/or enter into a Direct Loan Service Agreement through the Speedle Portal, you agree to the collection, transmission and storage of your payment information by Zepto Payments Pty Ltd ACN 604 057 597 trading as “Zepto” or such other organisation Speedle use in that role from time to time.

6.2 Your payment information may include Bank Account, Debit Card and/or Credit Card details as well as other personal information about you.

6.3 Unless otherwise stated all amounts particularised on the Speedle Portal and all payments are to be made in Australian Dollars.

6.4 Depending on where you access this Speedle Portal, the type of payment method used and where your payment method was issued, you may be subject to financial institution fees or foreign exchange fees.

6.5 Speedle does not support all payment methods, currencies or locations for payment.

7. Debit Card & Credit Card Payments

7.1 If you’ve elected to make a payment by Debit Card or Credit Card, the Speedle Portal directs you to enter your Debit Card or Credit Card details and personal information via a payment platform maintained and operated by Zepto Payments Pty Ltd ACN 604 057 597 trading as “Zepto”.

7.2 Speedle do not charge any transaction fees or credit card surcharges for Debit Card or Credit Card payments received via the Speedle Portal.

7.3 Your financial institution may treat the payments made to the Speedle as a cash withdrawal and charge a surcharge, extra fees or interest to your account. To establish whether these apply to you, you should check with your Debit Card or Credit Card financial institution for advice on what financial products and services are affected.

8. Direct Debit Card Service Agreement

8.1 If you’ve elected to make a payment by direct debit from your Bank Account, Debit Card or Credit Card, either electronically through the Speedle Portal, via a manual form or by telephone, you request and authorise Speedle, until further notice in writing, to debit the Bank Account, Debit Card or Credit Card that you have nominated with any agreed amount and apply that payment to the Customer Account.

8.2 The first drawing under this Direct Debit arrangement will occur on the day which has been agreed to.

8.3 If any drawing falls due on a non-business day, it will be debited to your account on the next Business Day following the scheduled drawing date.

8.4 Speedle will give at least fourteen (14) days notice in writing or via some other form of communication when, changes to the initial terms of arrangement are made. This notice will state details of any changes to the initial terms. If you are not satisfied with any change or variation, you may terminate the Direct Debit arrangement by providing Speedle with at least five business days’ notice by phone or in writing. You may also contact your financial institution.

8.5 If you want to make changes to the drawing arrangements, you must contact Speedle by phone or in writing. These changes may include:

(a) Changing the due date, the scheduled frequency and/or the scheduled payment amount;

(b) Changing Bank Account, Debit Card or Credit Card Details;

(d) Suspending the Direct Debit Request.

8.6 Any requested changes to the due date, the scheduled frequency and/or scheduled repayment amount, if agreed to by Speedle, or changes to the Bank Account, Debit Card or Credit Card to be debited, will require you (or the bank account holder) to complete a new Direct Debit Request either electronically through the Speedle Portal (if available), via a manual form or by telephone.

8.7 Direct all enquires to Speedle, rather than to your financial institution, and these should be made at least seven (7) working days prior to the next scheduled drawing date.

8.8 All communications addressed to Speedle should include your name, current address, contact phone number, customer reference number and date for next Direct Debit arrangement.

8.9 In accordance with Speedle's Privacy Policy, all your personal, Customer, or third party, information held in relation to this Direct Debit Request, will be kept strictly confidential except that information provided to your financial institution necessary to initiate Direct Debit drawing against the nominated account.

8.10 If you believe that a drawing has been initiated incorrectly, Speedle encourage you to take the matter up directly with Speedle by contacting your nominated Customer Service Officer.

8.11 If you do not receive a satisfactory response from Speedle to your dispute, contact your financial institution who will respond to you with an answer to your claim:

(a) within seven (7) business days, for claims lodged within twelve (12) months of the disputed drawing, or

(b) within thirty (30) business days, for claims lodged more than twelve (12) months after the disputed drawing.

8.12 You will receive a refund of the drawing amount if Speedle cannot substantiate the reason for the drawing.

8.13 It is your responsibility to ensure that:

(a) Your nominated account can accept direct debits. Your financial institution can confirm this to you.

(b) That on each due drawing date there is always sufficient cleared funds in the nominated account to cover the scheduled repayment amount.

8.14 If there are insufficient funds in your account to meet a debit payment on the due date:

(a) Speedle is under no obligation or commitment to represent the dishonoured direct debit request to your financial institution; however, we may, at our discretion, represent a direct debit dishonoured due to insufficient funds;

(b) If a represented direct debit dishonours, then Speedle reserves the right to suspend the presentation of further direct debits requests without prior notice to you;

(d) You may also incur fees or charges imposed or incurred by Speedle;

(e) You must arrange for a dishonoured debit payment to be made by another method or arrange for sufficient clear funds to be in your account, by an agreed time, so that, if agreed, we can reprocess the debit payment;

(f) If you do not make an arrangement to rectify the dishonoured payment, and associated fees, this Direct Debit arrangement may be cancelled by Speedle, without prior notice to you, and the full outstanding balance of the Customer Account will become immediately due and payable.

9. Payment Arrangement

9.1 Depending on your individual circumstances, you may use the Speedle Portal to submit a proposal to enter into an alternate payment arrangement in respect of a Customer Account.

9.2 Speedle may accept or reject your proposal for a payment arrangement.

9.3 Where Speedle accepts your proposal for a payment arrangement, you agree that the payment arrangement is subject to and conditional upon the following terms:

(a) You acknowledge you owe the full amount of the Loan to Speedle;

(b) You agree to repay the Loan by consecutive minimum instalments of the agreed amount, the first of such instalments to be made on the agreed commencement date, and continuing weekly, fortnightly or monthly, as agreed, until the whole of the Loan has been repaid in full;

(c) Should you make an interim payment of any amount; that is, a non-scheduled payment, or an overpayment of the minimum instalment, your scheduled minimum instalment still remains due and payable on the next scheduled instalment date, as if you had not made the interim payment or overpayment;

(d) Speedle will continue to charge interest on the outstanding balance of the Loan, under your agreement with Speedle;

(e) Speedle reserves the right to review this payment arrangement with the minimum interval period being every three (3) months from the commencement date, with a view to finalising payment of the Loan by requesting an update on your financial position in order to understand your ability to repay the Loan as quickly as possible;

(f) Should there be any default or delay whatsoever in the punctual payment of any instalment then, subject to any law or requirement, Speedle will be at liberty to commence or continue legal action against you, without further notice, to recover the balance of the Loan together with all moneys, charges, interest and legal costs which are payable, or have been incurred, or will be incurred under your agreement with Speedle;

(g) This indulgence to allow you to repay the Loan to Speedle under the alternate payment arrangement, at the times and in the manner agreed to, is given without prejudice to Speedle's rights to recover the whole of the Loan, including interest and other moneys, owing and payable by you under your agreement with Speedle, if you fail, neglect or refuse to pay under the payment arrangement; and

9.4 It is expressly acknowledged and agreed that the payment arrangement will not and does not compromise Speedle's rights against you in any way whatsoever.

SECTION H – UPLOADING & USE INFORMATION

10. Uploading Information

10.1 You represent and warrant in relation to any material and/or information you provide to the Speedle Portal that:

(a) you are authorised to provide the material and/or information;

(b) the material and/or information is true and correct;

(c) the material and/or information is not defamatory or a malicious falsehood in relation to any product, service, person or corporation;

(d) the material and/or information is not the “passing off” of any product or service and does not constitute unfair competition;

(e) the material and/or information does not infringe any intellectual property right including, but not limited to, trade marks, service marks or business names (whether registered or unregistered), confidential information and copyright; and

(f) the material and/or information does not infringe any legislation or regulations of the Commonwealth of Australia and the State of Queensland including, but not limited to, the Competition and Consumer Act 2010 (Cth) and the Fair Trading Act 1987 (NSW) or equivalent state / territory legislation and any other parliament competent to legislate in relation to the Speedle Portal or any law in any country where the material and/or information is or will be available electronically to users of this Speedle Portal.

11. Use of Information

11.1 Subject to the Speedle’s Privacy Policy, Speedle and/or people authorised by it may gather and process the information:

(a) which you may provide when accessing the Speedle Portal, such as your name, address, e-mail address and other personal information about you; and

(b) regarding the way in which you use the Speedle Portal including, without limitation, information acquired through the use of "cookies" programmed during the accessing of the Speedle Portal.

11.2 Subject to the Speedle’s Privacy Policy, you consent and agree that Speedle may:

(a) exchange of your personal and credit information with credit reporting bodies and government bodies in order to assess your Loan application and verify your identity;

(b) send you emails, SMS messages or Phone calls using the information acquired through clause 11.1 in order to verify your information and provide updates in respect of the Customer Account;

SECTION G – TERMINATION OF ACCESS

12. Termination of Access

12.1 Speedle may terminate access to the Speedle Portal at any time without giving any explanation or justification for the termination of access, and Speedle has no liability for any costs, losses or damages of any kind arising as a consequence of terminating access to the Speedle Portal.

SECTION G – DISCLAIMER

13. Disclaimer

13.1 Speedle gives no warranty, guarantee or representation about the accuracy, reliability or timeliness or otherwise, of the information contained on the Speedle Portal and/or linked sites on the World Wide Web.

13.2 To the full extent permitted by law Speedle disclaims any and all warranties, express or implied, regarding:

(a) the accuracy, reliability, timeliness or otherwise of any information contained or referred to on the Speedle Portal and/or of any linked sites; and

(b) merchantability or fitness for any particular purpose for any service or product contained or referred to on the Speedle Portal and/or on any linked sites.

13.3 Speedle will not be liable under any circumstances for any loss of profits or any damages of any kind recognised by law (even if it has been advised of the possibility of such loss of profits or damages) which are the consequence of you:

(a) acting, or failing to act, on any information contained on or referred to on the Speedle Portal and/or any of the linked Websites; and

(b) using or acquiring, or your inability to use or acquire, any service or product contained or referred to on the Speedle Portal and/or any linked sites.

13.4 Speedle does not warrant guarantee or make any representation that:

(a) the Speedle Portal, or the server that makes the site available on the World Wide Web are free of software viruses;

(b) the functions contained in any software contained on the Speedle Portal will operate uninterrupted or are error-free; and

13.5 Speedle is not liable to you for:

(a) errors or omissions in the Speedle Portal, or linked sites on the World Wide Web;

(b) delays to, interruptions of or cessation of the services provided in the Speedle Portal, or linked sites; and

whether caused through negligence of Speedle, its employees or independent contractors, or through any other cause.

13.6 You agree to accept the full cost of any necessary repair, correction and maintenance of any of your computer software or hardware, which may be necessary as a consequence of you accessing the Speedle Portal.

SECTION H – LIMITATION OF LIABILITY

14. Limitation of Liability

14.1 To the full extent permitted by law Speedle's liability for any implied warranty or condition is limited, at the choice of Speedle, to one or more of the following:

(a) If the breach of an implied warranty or condition relates to services:

(i) the supply of the services again; or

(ii) the payment of the cost of having the services supplied again; and

(b) If the breach of an implied warranty or condition relates to goods:

(i) the replacement of the goods or the supply of equivalent goods;

(ii) the repair of such goods; or

(iii) the payment of the cost of replacing the goods or acquiring equivalent goods, or having the goods repaired.

14.2 This clause may not apply to you in jurisdictions in which limitations on or exclusions of warranties or liabilities are not permitted by law.

SECTION I – ALETRATION OF TERMS & CONDITIONS

15. Alteration of Terms & Conditions

15.1 Subject to any law or regulation, Speedle reserves the right to change these Terms & Conditions:

(a) with or without further notice to you; and

(b) without giving you any explanation or justification for such change.

SECTION I – JURISDICTION

16. Jurisdiction

16.1 If any part of these Terms & Conditions is found to be void, unlawful, or unenforceable then that part will be deemed to be severable from the balance of these Terms & Conditions and the severed part will not affect the validity and enforceability of any remaining provisions.

16.2 These Terms & Conditions will be governed by and interpreted in accordance with the law of New South Wales, Australia, without giving effect to any principles of conflicts of laws.

16.3 You agree to the jurisdiction of the courts of Sydney, New South Wales, Australia, to determine any dispute arising out of these Terms & Conditions.

SECTION J – FEEDBACK OR COMPLAINT

17. COMPLAINTS

17.1 We offer a free internal complaint resolution scheme to all of our customers. Should you have feedback or a complaint, please contact us to discuss your concerns.

17.2 To assist us in helping you, we ask you to follow a simple three-step process:

(a) gather all supporting documents relating to the complaint;

(b) contact us and we will review your situation and if possible, resolve your complaint immediately; and

(c) if the matter is not resolved to your satisfaction, please contact our Compliance Officer on 02 8365 2322 or put your complaint in writing and send it to Speedle, Level 22-23, Salesforce Tower, 180 George Street Sydney NSW 2000 or to complaints@speedle.com.au.

17.3 We will rectify any breach if the complaint is justified and will take necessary steps to resolve the issue.

17.4 In certain situations, to deal with a complaint it may be necessary to consult with third parties. However, please note any disclosure of Personal Information to third parties will be provided with your authority and consent.

17.5 After a complaint has been received, we will send you a written notice of acknowledgement setting out the process. The complaint will be investigated, and the decision will be sent to you within thirty (30) days unless you have agreed to a longer time. If a complaint cannot be resolved within the agreed time frame or a decision could not be made within thirty (30) days of receipt, a notification will be sent out to you setting out the reasons and specifying a new date when you can expect a decision or resolution.

18. IF YOU ARE UNHAPPY WITH OUR RESPONSE

18.1 If your complaint is not resolved to your satisfaction through our IDR process, you have the right to refer your complaint to AFCA. AFCA is an independent and external dispute resolution scheme, of which Speedle is a member.

18.2 You can lodge your complaint with AFCA by sending the relevant information and documents to:

Australian Financial Complaints Authority Limited

GPO Box 3 Melbourne VIC 3001

Phone: 1800 931 678

Fax: (03) 9613 6399

Email: info@afca.org.au

Website: https://www.afca.org.au/

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