This Privacy Policy applies to Earlypay Ltd (ACN 098 952 277) and its related companies, including Cashflow Finance Australia Pty Ltd (ACN 093 756 524), Classic Funding Group Pty Ltd (ACN 057 766 551), Classic Finance Pty Ltd (ACN 098 065 162), Classic Clean Energy Finance Pty Ltd (ACN 145 265 103) and The Invoice Exchange Pty Ltd (ACN 151 085 157) ("we", "us", "our" or “Earlypay”).
We recognise the importance of privacy and are committed to protecting the privacy of individuals when handling their personal information. We handle personal information for purposes relating to our business functions and activities which include the financing of business operations and activities within the Australian and overseas market place.
Our Privacy Policy outlines how we handle personal information in an open and transparent manner in accordance with the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988 (Cth.) (the “Privacy Act”). By providing us with your personal information you consent to us handling it in accordance with our Privacy Policy. If you provide us with any personal information about another individual then we rely upon you to inform him or her of the details contained in our Privacy Policy.
The Privacy Act does not specify an age when individuals can make their own privacy decisions. As a general rule, a client under the age of eighteen (18) years has capacity to consent when he or she has sufficient understanding and maturity to understand what is being proposed. However, it will be necessary for a parent or guardian to consent on behalf of a client who lacks the maturity or understanding to do so himself or herself.
Where it is not practicable or reasonable for us to assess the capacity of clients on a case-by-case basis then we will presume that clients aged fifteen (15) years or over have capacity to consent and clients aged under fifteen (15) years of age do not to have such capacity unless there is something to suggest otherwise.
We collect, hold, use and disclose personal information for purposes relating to our business functions and activities. For example, we may collect, hold, use or disclose your personal information for one or more of the following purposes:
assessing your application, or suitability, for our products or services;
providing you with our products or services;
managing our relationship with you;
providing you with information about our products or services;
evaluating or improving our products or services;
marketing or promoting our products or services or attendance or participation by yourself in
marketing functions, activities or events;
carrying out our day to day business functions and activities; and
complying with our legal or regulatory obligations as may arise from time to time.
The kinds of personal information about you that we may collect and hold include your:
personal details including name, contact details, gender, age and personal interests;
payment information including bank account details and credit card details;
identity information including date of birth and driver’s licence details; and
product and service information including credit history.
We will not collect any sensitive information about you without your consent unless we are required or authorised by law to collect the information. Sensitive information includes information about a person’s health, biometrics, genetics, ethnic background, religious beliefs, religious affiliations, philosophical beliefs, professional memberships, trade memberships, political memberships, political opinions, sexual preferences or criminal record.
If we are not provided with the personal information about you which we request then we may not be able to provide you with our products or services.
We also collect and hold information about visitors to our website:
https://www.earlypay.com.au/ (the "Website") using a range of third party tools including cookies and session tools.
For example, when you visit our Website we may collect your server address, domain name, operating system, browser type, pages accessed, documents downloaded, previous visits, referring website and visit date and time. We collect and hold this information for the purpose of maintaining and improving our Website and enhancing your experience browsing our Website.
You may set your browser to disable cookies but some parts of our Website may not function properly if cookies are disabled. Our Website does not set tracking cookies if a "Do Not Track" request is received from your browser.
How we collect personal information
you request us to provide you with our products or services;
you request us to provide you with assistance or support for our products or services;
you attend or participate in marketing functions, activities or events;
you request us to provide you with information about our products or services or marketing functions, activities or events;
you complete a survey or provide feedback in respect of our products, services, functions, activities or events; or
you subscribe to receive news or other information about our products, services, marketing functions, activities or events.
We may also collect your personal information from a third party, or a publicly available source, for the purpose of carrying out our business functions and activities including (without limitation) for assessing your application, or suitability, for our products or services. For example, we may collect your personal information from:
your authorised representatives in connection with providing you with our products or services or your attendance at or participation in our marketing functions, activities or events;
our service providers that assist us to carry out our business functions and activities including our information technology providers and credit report providers; or
government departments and agencies in connection with carrying out our business functions and activities.
We will give you the option of not identifying yourself or using a pseudonym when dealing with us in relation to a particular matter except where it is impracticable or unlawful for us to do so. For example, you may not need to identify yourself when you request that we provide you with general information about our products, services, functions, activities or events.
If we receive any of your personal information that we have not requested then we will determine within a reasonable time whether or not we could have collected the information. If we determine that we could not have collected the information then we will destroy or de-identify the information as soon as reasonable practicable but only if it is lawful and reasonable to do so.
We disclose personal information to third parties for the purpose of carrying out our business functions and activities or otherwise comply with out lawfully imposed obligations. For example, we may disclose your personal information to:
your authorised representatives in connection with providing you with our products or services or your attendance at or participation in our marketing functions, activities or events;
our service providers that assist us to carry out our business functions and activities including our legal service providers, customer support providers, information technology providers, printing and mailing providers, sales and marketing providers, billing providers, debt recovery providers and other professional advisers and credit report providers including (without) limitation:
Equifax privacy policy
Emailage privacy policy
Alares privacy policy
Illion privacy policy
CreditorWatch privacy policy
our related companies, agents, partners, affiliates and other trusted entities that assist us to carry out our business functions and activities; or
government departments and agencies in connection with carrying out our business functions and activities.
These third parties to which we may disclose your personal information may be located in Australia or other countries.
We will not disclose your personal information to any other third parties without your consent except where required or authorised by law.
We may use your personal information to provide you with news or other information about our products, services, functions, activities or events that may be of interest to you. In each such communication we will describe how you may at any time request not to receive any further such communications from us. We will give effect to your request not to receive any further such communications from us as soon as practicable.
We hold personal information that we collect in both physical and electronic storage facilities including paper-based files, computer servers, desktop and laptop computers, tablets, mobile phones, cameras and other portable data storage devices.
We protect personal information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure using both physical and electronic security measures which include secure premises, physical access restrictions, locked cabinets, video surveillance, secure databases, password access, anti-virus software, data encryption and firewalls.
If we hold any personal information that we no longer need for any of our purposes then we will take reasonable steps to destroy or de-identify the information unless we are required by law to retain the information.
For the purposes of the GDPR we are a data controller. We use a customer review service called TrustPilot to collect feedback from our customers on our behalf. We may disclose your name and email contact details, to TrustPilot and you may receive an invitation from TrustPilot to write a review of your experience and dealings with us. You are under no obligation to accept the invitation or provide a review.
You can also unsubscribe from receiving any further communications from TrustPilot. TrustPilot’s head office is located in Denmark. For the purposes of the GDPR, TrustPilot is a data processor. It is possible that your personal information may be processed by TrustPilot in Denmark or another European Union country.
We may also use other third party service providers located in the EU to store or process your data.
Under the AML/CTF Act, we may disclose your name, residential address and date of birth (“Verification Information”) to a Credit Reporting Body (“CRB”) CRB to verify your identity electronically. If you are an individual, we will obtain your consent before we disclose your Verification Information to the CRB. When requested by us, the CRB may provide an assessment of whether your Verification Information matches the information held by them. When preparing the assessment, the CRB may use Verification Information about you as well as Verification Information that they already have about other individuals.
If your identity is unable to be verified electronically by the CRB, we will provide you with written notice of this and provide you with information about alternative ways we can verify your identity. If you do not consent to your identity being verified electronically, you will need to provide us with certified copies of your identification documents.
If we are unable to verify your identity we will not be able to provide credit to you.
We will collect and hold Personal Information that is reasonably necessary for or directly related to assessing your application for employment. We will collect and hold your Personal Information until the conclusion of our assessment process. The Personal Information collected may be disclosed to any of the companies within the group.
During the assessment process, your Personal Information will be handled and dealt with in strict confidence. We will not disclose your Personal Information to persons outside the group companies unless your consent is obtained. This includes the referees’ reports and background checks (ie police checks) that we may collect and hold.
If you are not a successful applicant and would like to have access to the Personal Information that we hold about you, we require that you do so within 28 days of the date of your application.
To protect your privacy, we will destroy or de-identify the Personal Information that we have about you after that date, as it is no longer needed. The only rare exception is where we are required to retain your Personal Information by law or under a court order.
You have the right to request access to, and correction of, any of your personal information that we hold. You should promptly notify us if you become aware that any of your personal information that we hold is inaccurate or out-of-date
We will respond within a reasonable time to a request by you for access to your personal information. We will give you access to your personal information in the manner that you request if it is reasonable and practicable to do so. If we decide not to give you access to your personal information then we will give you written reasons for our decision.
We will respond within a reasonable time to a request by you for the correction of your personal information. If we correct any of your personal information that we have previously disclosed to another organisation which is subject to the Australian Privacy Principles then you may request us to notify that other organisation of the correction. If we decide not to correct any of your personal information then we will give you written reasons for our decision and you may request us to associate with the information a statement apparent to users of the information that it is incorrect.
If you wish to access, correct or update any of your personal information that we hold, please contact our Privacy Officer using the contact details below. You will be required to verify your identity before you will be permitted to access, correct or update any of your personal information that we hold. We may charge a fee for giving you access to your personal information.
If you have an enquiry or complaint about our handling of your personal information, please contact our Privacy Officer using the contact details below. A complaint about our handling of your personal information should first be made in writing to our Privacy Officer setting out details of your complaint.
Our Privacy Officer is responsible for dealing with all enquiries and complaints about our handling of personal information and will respond on our behalf within a reasonable time after receiving an enquiry or complaint.
If you are not satisfied with our response to your complaint then you may take your complaint to the Office of the Australian Information Commissioner which may be contacted using the following contact details:
Name: Office of the Australian Information Commissioner
Phone: 1300 363 992
Email: [email protected]
Address: GPO Box 5218 SYDNEY NSW 2001
We may update our Privacy Policy from time to time to take into account changes in our information handling practices by publishing an updated version of our Privacy Policy on our Website. You should regularly review the most recent version of our Privacy Policy available on our Website.
You may contact our Privacy Officer using the contact details below:
Privacy Officer: James Beeson
Phone: 1300 760 205
Email: [email protected]
Address: Level 6, 201 Miller Street, North Sydney NSW 2060
These Notifiable Matters apply to consumer credit provided by Classic Clean Energy Finance Pty Ltd, Australian Credit Licence 434863.
We collect, hold, use and disclose your personal and credit information to assess your application for commercial or consumer credit, or to act as a guarantor. Please note that:
Our Privacy Policy tells you how we deal with the information that we collect. You can access a copy at https://www.earlypay.com.au/privacy-policy/. You can also ask us to provide you with a hard copy.
We may disclose information about you to other companies in the group and to other credit providers.
We disclose information about you to Equifax, which is a credit reporting body. Equifax uses the information to prepare credit reports for us and to verify your identity electronically.
We may need to disclose to Equifax if you default on consumer credit payments or commit a serious credit infringement.
You have the right to contact us to access or correct the information. You also have the right make a complaint about privacy matters. Our contact details are:
Classic Clean Energy Finance
Privacy Officer: James Beeson
Phone: 1300 760 205
Email: [email protected]
Address: Level 11, 201 Miller Street, North Sydney NSW 2060
You can request that Equifax refrain from using your credit information for direct marketing. You can ask Equifax not to disclose information about you if you believe you are a victim of fraud.
We cannot assess and may decline your credit application if the information that we need is not collected from you.