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PRIVACY STATEMENT

Cunnington Group’ or ‘we’ or ‘us’ means Cunnington & Co Holdings Pty Ltd (ABN 51 137 847 495) and all its related parties, financiers named in this policy (a Financier), and subsidiaries, which includes all of our banking, financing, funds management, financial planning, superannuation, insurance, broking and e-commerce organisations. The ‘website’ at https://altitude.fund, https://cunnington.com, https://paynow.asia, https://smebusinesscentre.biz, https://smecash.com.au, https://smecreditline.com.au, https://sme.management and https://brokeraltitude.azurewebsites.net/ is owned and operated by Cunnington Group.

The ‘user’ is the individual associated with personal information for the registration of an account. The ‘applicant’ refers to the business that is associated with the application of the loan or other advances. The ‘guarantor(s)’ is associated with the loan or other advances and could be:

  1. Director(s) and/or shareholder(s) of the business that is in a company.
  2. Corporate that is a shareholder of the business that is in a company
  3. Individual partners of the business that is in a partnership
  4. Corporate partners of the business that is in a partnership
  5. Sole Trader of the business

The user who may be an applicant and/or a guarantor.

In this privacy document, ‘you’ and ‘your’ means the user, applicant and/or guarantor.

As some of our related companies may have separate policies, but consistent, depending on the specific legal requirements of its business, we recommend reading those privacy policies if you interact with any those companies or the Cunnington Group.

A reference to "your credit application" includes a reference to a credit application that is made by a person within the Cunnington Group. Any financial accommodation granted to businesses by any member of Cunnington Group is not bound by the National Consumer Credit Protection (NCCP) – Click here to view the NCCP.

We are bound by the Corporations Act 2001 (Click here for Corporations Act 2001) Australian Privacy Principles (contained in the Privacy Act 1988 (Cth) - Please click here for to obtain privacy act) and are committed to ensuring the privacy of your personal information. Similarly, the terms and conditions and/or Privacy Statement will act in the same manner for business information. Where possible, we have clearly stated about the use of business information. This Privacy Statement details how we collect, handle and protect that information. We may modify and/or update this Privacy Statement from time to time to reflect its best privacy practices and policies.

We address this Privacy Statement to all stakeholders of Cunnington Group including, and not limited to, Directors, Shareholders, and all other website users both personally and in their commercial capacity.  These privacy principles have been developed and adopted by the fullest possible disclosure of the use of any information which we obtain.

The information we collect

The personal information and business information that we collect will usually depend upon the products or services that are being provided, or that may be provided to you or to another person and/or business with whom you are connected. The information we collect may include some or all of the following for you:

  • name, address, date of birth and contact details;
  • e-mail address;
  • driver’s license;
  • photo;
  • information required for identity verification purposes;
  • details about the business financial position, which may include information about assets, expenses and any debts your business may have;
  • details of any securities the business has given to us or another person; and
  • details of specified transactions.
  • Credit History (Serious Credit infringements or connection with the infringement, credit history, credit capacity, eligibility for credit)
  • repayment history information
  • payment Information
  • activity including IP address, whether you’ve access third party sites

Before we provide a product or service to you, or a person and/or business connected, we may be required to collect your full name, residential address and date of birth or license number. We may be required to do this in order for us to comply with our customer identification obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.  As a part of such process we may need to take copies of your personal identification documents in order to verify your identity in accordance with the requirements of that Act.

Where we seek information about you but are not able to obtain some or all of the information we request, this may affect or inhibit our ability to offer or provide a financial product or service or pursue our Operational Services to you or to a person and/or business with whom you are connected.

We will not collect sensitive information about you without your consent.

Why do we collect, use and disclose personal and/or business information?

We may collect, hold, use and disclose personal and/or business information for the following purposes:

  • to enable you to access and use certain features on our website and services;
  • to operate, protect, improve and optimise our website and services, business and our users experience, such as to perform analytics, conduct research and for advertising and marketing;
  • to send you, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
  • to consider your employment application.

We may also disclose your personal and/or business information to a trusted third party or subsidiary who may also holds other information about you. Third party or subsidiary may also combine that information in order to enable them and us to develop anonymised insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

How we collect your personal and/or business information?

In most instances, we will collect information about you:

  • from the Online Loan Application or any other digital or paper forms completed by the you or a person and/or business with whom you are connected;
  • from information you otherwise provide to us, or Third Party;
  • by our accessing public databases maintained by the Australian Securities and Investment Commission;
  • by us seeking verification information in relation to your identity from a third party such as Equifax Pty Ltd;
  • by email request to you; and/or
  • by telephone contact with you.

We will normally collect personal information and/or business directly from you, unless it is unreasonable or impractical to do so.

Website activity and cookies

We refer to cookies as the ‘cookies’ or other similar digital content or technologies available that is also covered by the EU Directive. When you visit our website, we may store data files know as ‘cookies’ or tracking technologies such as pixels and web beacons and anonymous ad network tags on your computer, TV, Mobile phone or other device. If you wish to disable your cookies, you may do so at any time using via your privacy settings.

We may use cookies to collect data to help us understand your preferences, your use of the website and provide you with useful advertising on third party websites. Sometimes this information can be connected to your registration account on the website, but we will not provide the information in this format to Third Parties. We will use and disclose the information in accordance with our Privacy Statement.

Please view our policy on cookies for more information by clicking here.

Uses and disclosure of information

We will only use or disclose the personal and/or business information collected:

  • for the purpose for which it was collected;
  • for related purposes of which you would reasonably expect us to use or disclose the information;
  • where you have consented to us using or disclosing the information; or
  • where we are required or otherwise permitted to do so by law.

We may use your personal and/or business information to:

  • assess and process your request for a financial product or service;
  • assess and process a request for the provision of a financial product or service to a person or entity connected with you;
  • provide a financial product or service to you, or a person and/or entity connected with you;
  • manage our relationship with you, or a person and/or business connected with you;
  • notify you or a person or entity connected with you of any products that may be of interest;
  • audit and monitor the services we provide to you or a person or entity connected with you;
  • assist us to perform administrative or Operational Services (including risk management, systems development and testing, credit scoring, staff training and customer research);
  • investigate, identify or prevent any actual or suspected fraud or unlawful activity;
  • update the personal information we hold about you or the files of a person or entity connected with you; and/or
  • enable us to meet our obligations under law, for example, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or under Australian taxation laws and Australia regulations.

 We may disclose your personal information and/or business information to:

Financiers

  • Altitude TrustServices Pty Ltd ABN 65 083 409 429 (‘SME Fund’) as trustee for
    • SME Finance Trust ABN 52 650 151 651
    • Any other trust for which Altitude TrustServices Pty Ltd is the trustee and that trust makes you an offer for finance.
  • The note holders from time to time who are providing finance to the trustee
  • The beneficiaries of the Trusts including Altitude Funds Management Limited ABN 71 631 299 137
  • SME CreditLine Limited (‘CreditLine’) ABN 25 631 298 952and SMEBL Limited (‘SMEBL’) ABN 23 631 717 265 and any Trustee which is a wholly owned subsidiary of either CreditLine and/or SMEBL
    • Any trust for which SME CreditLine Limited or SMEBL Limited are the beneficiaries.
  • Other financial institutions in connection with your credit application or your dealings with us;

 

Other Related Entities of Cunnington Group

  • C & Co Corporate Services Pty Ltd t/a SME BusinessCentre ABN 56 083 409 330 and its subsidiary FinanceCloud.com.au Pty Ltd ABN 88 630 707 087 including subsidiaries or other parties in the jurisdiction outside of Australia, who will act as the Servicer of your Loan or other advance
  • Ulysses IT Pty Limited ABN 48 087 970 938 who will act as the provider of technology
  • All employees, shareholders, subsidiaries, associates and related parties within Cunnington Group;

 

Third Parties

We may use third party service providers, who are not part of Cunnington Group that may include:

  • Our Lawyers, Accountants and Auditors
  • Those who provide and/or maintain some of our data systems and provide auxiliary services to process and manage your loan and other advance.
  • Those who assist in the review, management or processing of your credit application;
  • Any trade credit insurance provider who we may approach as part of your credit application or your loan or other advance.
  • Payment system operators (e.g. merchant receiving card payments)
  • Third party sites and services (refer below Third-Party Sites and Services)
  • Our agents, the person who introduced you to us, contractors or other third-party service providers, to enable them to provide administrative, debt collection and other services to us;
  • Credit reporting bodies or other credit providers;
  • Your authorised agents or your executor, administrator or legal representative;
  • Government agencies and any regulatory bodies as part of our statutory obligations, or for law enforcement purposes.

 

What happens when we no longer need your information?

We are responsible for keeping your Data for the period of time required as long as we require to comply with regulations and laws, for example the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act. Once your Data is no longer required, we will destroy or permanently de-identify it.

Marketing

The user agrees Cunnington Group including, and not limited to, Subsidiaries & SME WORLD may use your personal or business information to let you know about products and services that we believe may be of interest to you. Any marketing will be via email, print, telephone, SMS or any electronic or digital means including advertising on all websites, including Subsidiary websites, in accordance with the Spam Act 2003 and the Privacy Act 1988 (Cth).

We may market or connect with you through third party channels or other businesses (Social Media, Affiliate website, Publishing Websites and more) for the purpose of our products and services.

You may opt out at any time from Direct Marketing services or subscription-based services either by contacting us or clicking on the unsubscribe link located in our emails.

Protection of Personal Information

We take the protection of your personal and business information very seriously, Data is stored in electronic and paper form.

All practical steps are taken to safeguard personal data from theft, misuse, modification and unauthorized access. These include:

  • Management and employee privacy training
  • Control of data sighted by employees
  • Data only accessed by those employees needing it for their work
  • Limited access to office premises
  • IT systems secured with firewall and encrypted website
  • Use of third-party storage facility for archived documents

However, we cannot guarantee the security of your personal information. For more information on electronic Data storage & security please see Third Party Sites.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Statement, so we encourage individuals to read them before using those websites.

 

Third-Party Sites and Services

Our websites use application programming interface to connect the website of third parties who deliver the website processes and may retain processed data. You can ask us for a full list of these parties and we will provide you with copies of their privacy policies which have been made available to us. Contact us for more information.

Go Digital

You agree to provide us access to Data via Third Party accounting service provider applications (mentioned below) to collect financial statements, accounts, assets, expenses, income, revenue, dependents and other financial related information (prior to loan approval and for the remainder of the loan term) that will help complete Operational Services.

Operational Services refers all daily activities that assist with providing quality digital experiences for you on the Website.

For more information on the privacy of each accounting service provider, please see below:

We will be working with the following accounting applications soon:

We do not collect your username or password.

Digital iD

The user agrees to follow prompts on the website and complete the Digital iD process and acknowledges that partial Data is provided to Cunnington Group to assist with Operational Services, Know-Your-Customer, Anti-Money Laundering and Counter-Terrorism Financing Program of the Online Loan Application.

Partial Data is provided to Cunnington Group and its subsidiaries & related parties by Australian Postal Corporation in order to provide services to you or to a person with whom you are connected. Any data provided by Australia Post through Digital iD is subject to Digital iD Privacy Statement which can be located at https://digitalid.com/privacy.html.

We ensure to provide a digital experience for all our users, where data is used as part of the online application process for Cunnington Group to provide its products and services. We only provide the Data to the related subsidiaries and related parties, where deemed necessary. Any Data provided to us by Australia Post is solely used for the purpose of the application and is strictly confidential.

Please read the Terms of Use for Australia Post:

Terms of Use: https://digitalid.com/terms/web.html

For more information on how Digital iD comply with data and terms of their services, please see the links below:

Privacy and Security: https://www.digitalid.com/personal/privacy-and-security

Online Loan Application

You acknowledge that you will be directed to a subsidiary website such as https://smebusinesscentre.biz to complete the Online Loan Application and liaise with SME BusinessCentre for the whole application.

You agree that any data submitted in the Online Loan Application will be used to assist Operational Services and processing of your application

The Technology

The technology powering the Online Loan Application is owned by parties in Cunnington Group and licensed to Originators.

Credit Reporting Bodies

Equifax (Australia)

You agree that all Data provided to Cunnington Group via its Online Loan Application and other website form is true and honest. You also acknowledge that partial Data provided via the Online Loan Application is shared with Equifax to authorize a credit report. For more information on Equifax Credit Reporting Policy, the Data provided to Equifax, how you can access credit eligibility information,  seek correction or send complaints directly to Equifax– Please click here or see contact details below https://www.equifax.com.au/credit-reporting-policy  

Contact Details for credit reporting body

Equifax (Australia)

Online:  https://www.equifax.com.au/contact/small-business#faq

Email:  customercomplaintsAU@equifax.com

Phone: 13 8332

Mail:

Equifax

PO Box 964

NORTH SYDNEY NSW 2059

 

All Data that is exchanged between Equifax and Cunnington Group deem to be true and honest, depending on what you or to a person with whom you are connected, and/or other parties have provided. For more information on how Equifax collects other Data about you and a business associated with you, please click here: https://www.equifax.com.au/privacy

 

Anti-Money Laundering (AML) And Counter-Terrorism Financing (CTF) Program

You agree and acknowledge that we will conduct an AML/CTF check on you. We acknowledge the responsibility in seeking to combat money laundering and terrorist financing.  We are committed to ensuring that the services we provide as the trustee (Altitude) of an SME Trust are not used for, or to facilitate, such purposes. 

We are required to comply with the Australian Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws. The current AML/CTF laws, rules, regulations and guidance notes are as follows:

  1. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act);
  2. Anti-Money Laundering and Counter-Terrorism Financing Rules 2007 (Cth) (as amended) (AML/CTF Rules)
  3. The AML/CTF Rules are the responsibility of, and are overseen by, Australia's AML/CTF regulator, the Australian Transaction Reports and Analysis Centre (AUSTRAC). Having the status of law, the AML/CTF Rules impose significant obligations in addition to those contained in the AML/CTF Act;
  4. Anti-Money Laundering and Counter-Terrorism Financing Regulations (Cth);
  5. AML/CTF Guidelines issued by AUSTRAC. The guidelines are not legally binding;
  6. Charter of the United Nations Act 1945 (Cth) and Charter of the United Nations (Dealing with Assets) Regulations 2008 (Cth); and
  7. Criminal Code Act 1995 (Cth) and Criminal Code Regulations 2002 (Cth).

We only conduct business with counterparties that it reasonably believes, based on appropriate due diligence, to be whom they claim to be.  We have appropriate steps to mitigate and manage AML/CTF Risks.

Know Your Customer (KYC)

You agree and acknowledges that we will conduct a KYC on you. We acknowledge the responsibility of conducting due diligence to verify all necessary User Data before entering in a relationship. All Related Parties conduct a KYC through multiple data sources. This clause assumes the collection of such Data and is concerned with the circumstances where there may be a need to update that Data by collecting further Data, or to verify Data held or additional Data collected. 

Where necessary, we will re-verify KYC information already held or will update by collecting and/or verifying further KYC Data, in respect of customers for ongoing due diligence purposes.

 

Access and correction

How to access and correct your information

We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date. You may at any time request access to personal information that we hold about you and, if there is an error (or our information about you is incomplete, inaccurate or out of date), you can advise us about this matter and we will, if needed, correct, amend or add to the information we hold about you. If we are satisfied that the personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take such steps as are reasonable in the circumstance to correct the information within 30 days or as agreed by the user in writing. Any changes will be updated, and you will be notified in writing.

We will not charge you a fee for your access request (unless we have separately advised you that such a fee will apply) but may charge you the reasonable cost of processing your request, including fees that may be charged to us when accessing your personal information

If you would like to request access to the information that Cunnington Group hold about you, please contact our Privacy Officer by calling us at: 02 9321 3100.  If you would like to request access to the information that a Financier holds about you, in consequence of your credit application, please contact the Privacy Officer of that Financier in the manner described in the relevant Financier's Privacy Statement (that is available on its website).

Disputes and Complaints

If you have a complaint about our treatment or our records of your personal information, please contact our Privacy Officer (Go to ‘Contact Us’) or the relevant Privacy Officer of the Financier in the manner described in the relevant Financier's Privacy Statement (that is available on its website).  The relevant Privacy Officer will investigate your complaint and endeavour to resolve any issue to your satisfaction.

If we do not adequately answer your concerns, you have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC). Complaints to the OAIC must be made in writing. 

Further information about making a complaint to the OAIC can be found at:

http://www.oaic.gov.au/privacy/making-a-privacy-complaint

Financiers

The Financiers are one or more of the following to whom your credit application is or may be submitted by any of the Cunnington Group entities:

  • Altitude TrustServices Pty Ltd ABN 65 083 409 429 as trustee for:
    • SME Finance Trust ABN 52 650 151 651

Other contact details

Cunnington Group can also be contacted:

  • Via the Contact Us form
  • by mail: GPO Box 3259, Sydney, NSW,2001.
  • By phone: 1300 857 092 (SME BusinessCentre)

 

Contact Us Form

For information and assistance call (1300 857 092). Alternatively, please provide your comments/feedback to us by using this Form: