PRIVACY POLICY

Rarost Pty Ltd T/A Action Funding (ACN 607 725 557)
This document sets out our policy on the management of personal information which we
have about individuals. Those individuals include clients to whom we may provide or may
have provided a facility, guarantors of both individual and company clients and individuals
who may provide a guarantee and individuals who are or become customers of our clients.

1. OUR PRIVACY ASSURANCE TO YOU

Your privacy has always been important to us. As our client, or someone in a business
relationship with our client, we respect your right to be aware of who has information about
you, what they are doing with it and why, and who else they are sharing it with. We have
adopted a privacy compliance culture that cements this relationship with you. Its foundation
is the Privacy Act 1988 (as amended by the Privacy Amendment (Enhancing Privacy
Protection) Act 2012), the Privacy Regulation 2013 and the Credit Reporting Privacy Code.
This privacy policy is the privacy policy which we must have in accordance with Australian
Privacy Principle 1.3 and incorporates our credit reporting policy which we must have in
accordance with section 21B(3) of the Privacy Act 1988.

2. OVERVIEW

This privacy policy explains how we manage personal information which is not credit
information or credit eligibility information. In particular it explains, in relation to that personal
information:

  • the kinds of personal information we collect and hold;
  • how we collect the personal information;
  • the purposes for which we collect, hold, use and disclose the personal information;
  • how an individual may access personal information about the individual that we hold
    and seek the correction of that information;
  • how an individual may complain about a breach of the Australian Privacy Principles
    and the Credit Reporting Privacy Code and how we may deal with the complaint; and
  • whether we are likely to disclose the personal information to overseas recipients and
    the countries where those recipients are likely to be located.
    This privacy policy also explains how we manage credit information and credit eligibility
    information. In particular it explains, in relation to that information:
  • the kinds of credit information we collect and hold and how we collect and hold that
    information;
  •  the kinds of credit eligibility information we hold and how we hold that information;
  • the kinds of CP derived information that we usually derive from credit reporting
    information disclosed to us by a credit reporting body under Division 2 of Part IIIA of
    the Privacy Act 1988;
  • the purpose for which we collect, hold, use and disclose credit information and credit
    eligibility information;
  • how an individual may access credit eligibility information about the individual that we
    hold;
  • how an individual may seek the correction of credit information or credit eligibility
    information about the individual that we hold;
  • how an individual may complain about our failure to comply with Division 3 of Part IIIA
    of the Privacy Act 1988 or the Credit Reporting Privacy Code;
  • how we will deal with the complaint; and
  • whether we are likely to disclose credit information or credit eligibility information to
    entities which do not have an Australian link and the countries where those recipients
    are likely to be located.

3. THE KINDS OF PERSONAL INFORMATION WE COLLECT AND HOLD

  • We collect and hold credit information about individuals who are clients, guarantors, debtors
    and associates. This information includes:
  • identification information, such as the individual’s name, address and date of birth;
  • the note we make of the disclosure of credit information we make to a credit reporting
    body so that we can obtain credit information from a credit reporting body;
  • the type of commercial credit and the amount of credit sought in an application that has
    been made by the individual and in connection with which we have made an
    information request;
  • court proceedings information about the individual, this is information about a judgment
    of an Australian court against the individual in proceedings (other than criminal
    proceedings) that relate to any credit that has been provided to, or applied for by, the
    individual; and
  • personal insolvency information about the individual, this is information that is entered
    or recorded in the National Personal Insolvency Index that relates to bankruptcy of the
    individual, a debt agreement proposal given by the individual, a personal insolvency
    agreement executed by the individual, a direction given (or an order made) under

section 50 of the Bankruptcy Act 1966 that relates to the property of the individual or
an authority signed under section 188 of that Act that relates to the property of the
individual.
We obtain credit reporting information about individuals who are clients, guarantors, debtors
and associates from credit reporting bodies. We only obtain it to the extent we are entitled to
obtain it under the Privacy Act 1988. We might, for example, need to obtain the individual’s
prior authorisation. Credit reporting information includes:

  • the credit information outlined above but which relates to the individual’s dealings with
    other credit providers;
  • consumer credit liability information, default information, payment information, new
    arrangement information and publicly available information concerning consumer credit
    which the individual has obtained from other credit providers; and
  • credit worthiness information about the individual that credit reporting bodies derive
    from the above information. This could include credit scores, risk ratings and other
    evaluations.

A client, a debtor or an associate may decide to make payments to us by using a credit card
or debit card. In that case we may collect and hold particulars concerning the credit card or
debit card which will be used to effect payment in accordance with an authorisation from the client or debtor.
The personal information, other than credit information and credit reporting information, we
collect and hold varies depending on the person we are dealing with and the reason why we are dealing with them. We collect this general personal information from individuals who are clients, guarantors, debtors, associates, prospective employees, contractors, suppliers,
brokers, introducers, merchants, agents, professional advisers, mercantile agents, mailing
houses, call centre operators, archivers and service providers. This information will generally include the individual’s name and contact details. We will only collect sensitive information about an individual with the individual’s consent or when permissible under Australian law.
Under various laws we will be (or may be) authorised or required to collect personal
information about an individual. These laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Personal Property Securities Act 2009, Corporations Act 2001, Autonomous Sanctions Act 2011, Income Tax Assessment Act 1997, Income Tax Assessment Act 1936, Income Tax Regulations 1936, Tax Administration Act 1953, Tax Administration Regulations 1976, A New Tax System (Goods and Services Tax) Act 1999 and the Australian Securities and Investments Commission Act 2001 as those laws are amended and includes any associated regulations.

4. HOW WE COLLECT PERSONAL INFORMATION

We collect personal information, other than credit eligibility information, about individuals in a
variety of ways. For example, we may obtain the information from the individual or from
persons acting on the individual’s behalf. When it is possible and practical we will collect the
information direct from the individual. When it is not practical or reasonable to do so we will
collect the information from a third party. The third party could be an authorised
representative (such as a broker, agent, accountant or lawyer), another financial institution, a
referee, an employer or a government body. When the individual is a debtor or an associate
we may obtain the information from the client.
The credit eligibility information is obtained from a credit reporting body.

5. HOW WE HOLD CREDIT INFORMATION AND CREDIT ELIGIBILITY INFORMATION

We take all reasonable steps to ensure that an individual’s personal information which we
hold is protected from misuse, interference or loss and from unauthorised access,
modification or disclosure.
We do this by having physical, electronic and procedural safeguards which protect the
personal information we hold. For example, the personal information is stored in secure
office premises or in secure archiving facilities and logins and passwords are required to
access electronic databases. Our staff are required to maintain the confidentiality of personal
information and access to personal information is restricted to persons who require access
to perform their duties.

6. THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION

We collect, hold, use and disclose credit information and credit eligibility information on
individuals for purposes permitted by law which are reasonably necessary for our business
activities. Those purposes include:

  • if the individual is a client, to determine if we should provide a facility which includes
    the provision of commercial credit to the individual and, if we decide to provide it, to
    assist in the provision of the facility. This includes the assessment of the application,
    managing the account, recovering money and dealing with security the individual
    gives;
  • if the individual is a guarantor, to determine whether we should accept a guarantee
    from the individual and, if the guarantee is given, to deal with or enforce our rights
    under the guarantee and any security which may be given to secure it;
  • if the individual is a debtor, to assess and verify the debt which the client sells to us or
    in which the client gives us a security interest, to collect the debt and to enforce the
    debt and any security which may be given to secure payment of the debt;
  • if the individual is an associate of the client, to determine if we should provide a facility
    which includes the provision of commercial credit to the client and to assist in the
    provision of that facility;
  • if the individual is an associate of the debtor, to assist us to verify the debt owed by the
    debtor and to collect and enforce the debt. For example, we may record the name and
    office phone number of a person in the debtor’s accounts payable department and
    telephone that person to verify the debt; test
  • to assist in the management and enforcement of the facilities we provide, for data
    analysis and internal management;
  • to provide information to credit reporting bodies to the extent this is permitted by the
    Privacy Act 1988;
  • to undertake securitisation activities, raise funding, assign debts and other rights, enter
    into insurance arrangements (for example insurance policies for debts) and provide
    information to and obtain information from insurers (including under policies which are
    taken out by us, which are assigned to us or under which we are the loss payee);
  • to deal with complaints and legal proceedings;
  • to meet our legal and regulatory requirements; and
  • to assist other credit providers by giving personal information to them in accordance
    with an authorisation which the individual has provided to them or us.

We do not hold any CP derived information.
We may disclose credit information (such as identification information) about an individual to
a credit reporting body. The credit reporting body may include that information in the reports
it provides to other credit providers.
We disclose credit information to the following credit reporting bodies:

Name: Veda Advantage Information Services and Solutions Limited / Equifax
Website: www.equifax.com.au
Mail: PO Box 964
NORTH SYDNEY NSW 2059

Name: Dun & Bradstreet (Australia) Pty Ltd
Website: www.dnb.com.au
Mail: PO Box 7405
St Kilda Road
MELBOURNE VIC 3004