‘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:
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 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:
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.
We may collect, hold, use and disclose personal and/or business information for the following purposes:
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.
We will normally collect personal information and/or business directly from you, unless it is unreasonable or impractical to do so.
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.
Please view our policy on cookies for more information by clicking here.
We may use third party service providers, who are not part of Cunnington Group that may include:
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.
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.
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:
However, we cannot guarantee the security of your personal information. For more information on electronic Data storage & security please see Third Party Sites.
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.
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.
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.
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.
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
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 powering the Online Loan Application is owned by parties in Cunnington Group and licensed to Originators.
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
Phone: 13 8332
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
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:
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.
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.
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).
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:
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:
Cunnington Group can also be contacted:
For information and assistance call (1300 857 092). Alternatively, please provide your comments/feedback to us by using this Form: