OUR COMMITMENT TO PROTECT YOUR PRIVACY
Bank of Communications Co., Ltd ARBN 137 909 963, AFSL 409837 and its related businesses (collectively known as "BoCom" and also referred to in this Policy as "us," "we" and "our") seeks to provide a range of financial products and services to support for its customers.
We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy, where we have your consent to do so, or as otherwise required or authorised by law. It is important to us that you are confident that any personal information we collect from you or is received by us will be treated with appropriate respect ensuring protection of your personal information.
Our commitment in respect of personal information is to abide by the Privacy Act 1988 (Cth) and any other relevant law.
WHO IS BoCom?
BoCom is a joint stock company incorporated in the People’s Republic of China with limited liability and it is registered in Australia as a foreign company under the Corporations Act 2001 (Cth).
In Australia, BoCom is authorised by the Australian Prudential Regulatory Authority as a foreign authorised deposit-taking institution to carry on banking business in Australia as Bank of Communications Co, Ltd, Sydney Branch (BoComAu). It is also authorised by the Australian Securities and Investments Commission to carry on a financial services business in Australia under its Australian Financial Services Licence.
When we refer to personal information we mean information or an opinion about you, from which you are, or may reasonably be, identified.
The type of information we collect will depend on the product or service requested for. Generally, the personal information we collect includes name, address, gender, marital status, date of birth, contact details (including telephone, facsimile and e-mail), personal details, tax file number, account details, business details, personal preferences and information about the products and services we have provided.
The personal information we collect about you may also include credit information about you. Credit information is information which is used to assess your eligibility for a loan and may include information about your income, assets, liabilities and repayment history information.
Due to the nature of the services provided by us, it is not common practice for us to collect sensitive information about you (such as information about your health, religion, trade union membership, political opinion, sexual preference or criminal record), unless such information is required in order to process an application from you. We will only collect sensitive information about you with your consent.
WHY WE COLLECT YOUR PERSONAL INFORMATION
BoComAu only collects personal information about individuals that is necessary for our business.
We collect and receive personal information about you in order to provide our services, including assessing an application for a product or service made by you, arranging or providing a service to you, administering or managing our relationship with you and the direct marketing of our products and services. If you are applying for employment or work experience with us, we may also collect personal information about you.
We may also collect personal information about you in order to perform an identification check on, or obtain identification verification of you if you have applied to become a customer or a signatory on an account with us, make a deposit into an another customer’s account, apply to act as a guarantor for a lending relationship with another customer, or apply to act as an agent for another customer.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Personal information may be collected by us in a number of circumstances, including when:
You make an application for one of our products or services
We provide customer support or assist you with a query
We undertake monitoring and evaluation of our products and services
You visit our website
You attend an event hosted by us or visit our premises
You apply for employment with us
We undertake activities to administer or manage our customer relationships
Where reasonable and practical we will collect your personal information only directly from you. However, we will also collect information about you from third parties, such as a partner or spouse who contacts us on your behalf, from our contractors who supply services to us, through our referrers, from advisers such as accountants or lawyers or other organisations authorised by you.
You should also be aware that when assessing an application from you for commercial credit, we may collect credit-related personal information about you (either from you, or with your consent from a credit-reporting body).
If any personal information we need is not available, or not provided, we may not be able to provide the relevant product or service or we may delay, block or refuse to make a payment or action an instruction relating to the customer’s account.
HOW DO WE USE YOUR PERSONAL INFORMATION?
The personal information we collect is only used or disclosed for the purposes for which it is collected, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your personal information for the following purposes:
· to provide you with the products or services you requested;
· to verify your identity;
· to assess, process and manage your application to be a borrower or guarantor, including to verify your details and assess our risk;
· to assess, process and manage your application for employment;
· for complaints handling or data analytics purposes; or
· to assess, process and manage your application for accreditation as a broker or introducer of loans.
In particular, when assessing an application for commercial credit, or an application by you to act as a guarantor of a loan, we may use your credit-related personal information for the purposes of assessing the application, assessing your credit-worthiness or managing the finance provided to you.
TO WHOM WILL WE DISCLOSE YOUR PERSONAL INFORMATION?
To enable us to maintain a successful business relationship with you, we may disclose your personal information to:
· organisations that provide products or services used or marketed by us, including intermediaries (such as brokers or financial advisors), valuers, other financial institutions, surveyors and rating agencies;
· your employer/s or referees, your guarantors, your professional advisors,
· companies and contractors who we retain to provide services for us, such as IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your personal information to provide those services;
· people considering acquiring an interest in our business or assets; and
· other individuals or companies authorised by you
By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case by case basis.
Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office.
We will not sell your personal information to other organisations.
DISCLOSURE TO OVERSEAS RECIPIENTS
BoComAu is part of a global bank, with global customers and as a result we use systems located in various countries outside Australia, including China, other parts of Asia, Europe and America. As part of our activities BoComAu may provide your personal information to our overseas branches or service providers. We may also use cloud storage and IT servers that are located offshore.
We may provide your credit information to a credit reporting body. The credit reporting body may provide the information that we report about you to other credit providers to assist them to assess your credit worthiness. We may also obtain information that other credit providers have provided to the credit reporting body to use in our assessments of your credit-worthiness.
If you fail to meet your payment obligations in relation to any loan that we have provided to you, or any loan that we have arranged for you, or if you commit a serious credit infringement, we may report this to the credit reporting body.
You may access the credit information that we hold about you. Please refer to the section titled ‘Accessing your Personal Information’ below. You may also request that we correct any credit information that we hold about you if you believe the information is incorrect. Please refer to the section titled ‘Updating your Personal Information’ below.
The information that we provide to a credit reporting body may sometimes be used for ‘pre-screening’ of direct marketing offers to be made by another credit provider. You may contact the credit reporting body to request that your credit information is not used in this way.
You may also contact the credit reporting body to request that they not use or disclose the credit-reporting information they hold about you if you consider that you may have been a victim of fraud or if you believe on reasonable grounds that the information they hold about you is incorrect. The credit reporting body must not use or disclose your credit information for a period of 21 days after receiving your notice.
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From time to time we may use your personal information to provide you with current information about financing, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Officer on the contact details below. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
UPDATING YOUR PERSONAL INFORMATION
It is important to our relationship that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we will ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information (including your credit related personal information) that we hold about, you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
ACCESS TO YOUR PERSONAL INFORMATION
We will provide you with access to the personal information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the personal information we hold about you, including any credit-related personal information we hold about you, at any time.
To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
DENIED ACCESS TO PERSONAL INFORMATION
There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.
An explanation will be provided to you if we deny you access to your personal information we hold.
BUSINESS WITHOUT IDENTIFYING YOU
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where, it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.
HOW SAFE AND SECURE IS YOUR PERSONAL INFORMATION THAT WE HOLD?
We will take reasonable steps to protect your personal information, including your credit-related personal information by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure. Only employees of the BoCom Group and those who perform services on our behalf, who are allowed to handle personal information, will have access to it.
FURTHER INFORMATION AND COMPLAINTS
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer(s) on the contact details below:
You can contact us by writing to:
Bank of Communications Co, Ltd, Sydney Branch
Level 27, 363 George Street, Sydney, NSW 2000
Attention: Privacy Officer
We will use our best endeavours to respond to your request within 14 days. However, where the matter is complex, we will write to you and advise you that our response may take longer. In all cases we anticipate being able to provide you with a response within 30 days.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.