Privacy Policy

Important Information

Privacy and credit reporting policy

(effective on and from 25th August 2021)

About this policy

At Avenue, we have great respect for your personal information – and we want you to have a clear understanding of how Avenue uses this information, and how we keep it secure. That’s why we’ve created this privacy policy. It applies to any individual whose personal information we have collected or handled, including customers, service providers, contractors, introducers and prospective employees.

Before we start, let’s clarify a few definitions:

  • “personal information”: this refers to information or an opinion about an identifiable person or someone who could reasonably be identified. This includes credit information and credit eligibility information.

  • “we/us/our/Avenue”: this refers to Avenue Bank Limited (ACN 628 073 085) and our related bodies corporate.

  • “the Privacy Act”: by this, we mean to the Privacy Act 1988 (Cth), which we are bound by.

 

The key areas this policy covers are:

  1. Collecting personal information

  2. Dealing with personal information

  3. Direct marketing

  4. Credit-related information

  5. Accessing and correcting personal information

  6. Security of personal information

  7. Contacting us

Other terms may also apply to you and the information we hold about you. For example, sometimes we also provide a privacy collection statement at the time we collect personal information from you, which may include additional terms. Or, if you are employed by Avenue, you may have specific privacy terms in your employment contract with us.

This privacy policy was last updated on (25 August 2021). We’ll continue to update the policy in line with any changes we make to our processes and systems related to the handling of your personal information. You can find the most recent copy of the policy at (https://avenuebank.com.au).

1. Collecting personal information

The kinds of personal information we collect and hold

As a restricted authorised deposit taking institution, we collect and hold personal information about you. To satisfy our legal obligations, we may need to hold on to this information after a transaction, or after our relationship with you has ended – but we won’t retain it for any longer than is reasonably necessary and permitted under Australian privacy laws.

The types of personal information we collect and hold may vary depending on the nature of our interactions with you, but may include anything on the list below.

  • your full name

  • your date of birth

  • residential address

  • contact details

  • government issued identifiers (such as your tax file number)

  • financial information

  • banking details

  • employment information

  • drivers licence number

  • assets and liabilities

  • transaction and repayment history information

  • credit-related information

  • information about your preferences relevant to any marketing activities

  • sensitive information, such as:

    • your criminal history

    • membership of a professional or trade association or union.

How we collect your personal information

There are a few ways we may collect your personal information, either from you directly, or from a third party.

The ways we may collect information directly include:

  • via our website (such as when you fill in a form)

  • over the phone (for example, when you speak to a client services representative)

  • when you apply for employment with us

We may also collect your personal information from a third party. These third parties include (but aren’t limited to):

  • credit reporting bodies

  • introducers (who refer you to Avenue)

  • current or past employers

  • referees

  • government bodies

  • other financial institutions and credit providers

  • people authorised to act on your behalf

  • sources of publicly available information (such as social media)

  • third party service providers and / or suppliers

  • recruitment consultants.

Rest assured, we’ll only collect personal information from third parties when you have given us authority to do so, and when it’s impracticable for us to collect it directly from you. 

What happens if your personal information is not provided to us?

Without access to your personal information, we may not be able to process your application or provide services to you.

2. Dealing with personal information

Why do we need your personal information?

There are a number of reasons we may need to collect, hold, use and disclose your personal information –these will depend on our relationship with you, and whether you’re a business or individual. For example, we may need personal information to:

  • verify your identity

  • assess an application for our products and services

  • provide you with our products and services

  • help detect fraud

  • assess how suitable you are as a service provider

  • collect overdue payments

  • report to various credit reporting bodies

  • research, develop and expand our products and services

  • recruit staff and contractors

  • comply with applicable laws

  • manage our relationship with you.

How we protect your personal information

Keeping your personal information safe is of the utmost importance to us at Avenue – and we have a number of protocols in place to make sure it’s kept free from misuse, interference, loss, unauthorised access, or modification. These include:

  • security measures that control access to our premises, documents and systems

  • confidentiality requirements and staff education around the importance of privacy and data security

  • limiting access to personal information to those with a legitimate need

  • keeping our systems protected with appropriate technology solutions.

When we may disclose your personal information (and who to)

For the reasons mentioned above, we may need to share your information with a range of different people and organisations. These include:

  • introducers (who have referred you to Avenue), such as landlords, leasing agents, tenant advisors, real estate consultants or advisors, business brokers, financial planners, accountants and business associations

  • service providers, including customer service organisations, payment processors, call centres, mailing houses, identification verification services, researchers, collections agents, marketing organisations, data analysts and software service companies

  • credit reporting bodies or other businesses or organisations that provide credit information or credit risk assessment services consistent with Australian laws

  • other financial institutions, government bodies and banks

  • organisations through which you choose to make payments to us

  • any current employee

  • your employer

  • your nominated referees

  • other organisations as required or authorised by law (for example to government or regulatory bodies).

We require all of these businesses and our suppliers to comply with strict confidentiality requirements and the Privacy Act.

Disclosing information overseas

While we try to store your personal information locally, there may be times when we need to disclose it to service providers located overseas. While it’s not practicable to list every country in these service providers may be located, it’s likely some will be in India and Europe – so please be aware that your personal and credit information may be disclosed to these countries. In these instances, rest assured we always take proper steps to secure and protect your personal information, wherever its being stored.

3. Direct marketing

One of the reasons we may use your personal information is to contact you about products and services we think you might be interested in. These may be our own products and services, or they may be from one of our related bodies or a third party we have an arrangement with – and in all cases, they will have been carefully selected for you. These communications, which we refer to as direct marketing, may be in the form of a phone call, text message, email or other digital formats including targeted advertising.

Consenting to receiving marketing material

By working with Avenue Bank, or becoming one of our customers, you consent to your personal information being used for direct marketing unless you opt out. You can do this at any time by:

  • calling us on 1300 283 265

  • emailing us at contact@avenuebank.com.au

  • ‘ticking the box’ on the relevant form when you apply for one of our products

  • using the ‘unsubscribe’ function that appears at the bottom of email communications

We’ll ensure your request is actioned within 5 working days, after which you’ll stop receiving direct marketing. 

Excluding your credit reporting information

You have the right to request these credit reporting bodies to exclude your credit reporting information from any permissible direct marketing activities they perform. You should contact each relevant credit reporting body directly if you wish to request this.

To provide you with an Avenue Bank product or service, we may need to obtain credit-related information about you from credit reporting bodies. This includes information related to your dealings with other credit providers and other third parties (for example, details you’ve supplied to a bank when applying for a loan), as well as credit eligibility information.

Credit information may include:

  • identification information, such as your name, address, date of birth or employer

  • commercial credit liability information (i.e. information about the commercial credit accounts you may hold or have held with a variety of credit providers)

  • consumer credit liability information (i.e. information about consumer credit accounts you hold, or have held with a variety of credit providers)

  • repayment history information (i.e. whether you have paid on time)

  • details of previous credit enquiries or applications you’ve made

  • default information (specifically, information on overdue amounts which have been overdue for greater than 60 days and greater than $150)

  • details of any credit-related court proceedings such as summons or judgements

  • personal insolvency information (i.e. whether you’ve been bankrupt).

Credit eligibility information refers to any credit scores, risk ratings and other evaluations about you that credit reporting bodies have derived from the information above. This information relates primarily to your credit-related dealings with other credit providers, and it may include:

  • credit scores risk ratings and other evaluations about you

  • credit reporting information provided by credit reporting bodies

  • credit worthiness information that we derive using credit information.

How we handle your credit-related information

If we ever collect, hold, use or disclose your credit information or credit eligibility information, it will only be if it’s necessary for our business activities. When doing so, we’ll always ensure we adhere to the restrictions that apply under the Privacy Act (for example, credit eligibility information can only be disclosed to a credit provider, and there are restrictions in how this information is used for direct marketing).

Reasons we may need to access your credit-information include:

  • to assess applications for Avenue Bank products and services, and accept guarantors

  • internal management purposes, including securitisation, risk management, and portfolio analysis

  • to assist in the collection of overdue payments

  • to help prevent defaults and deal with financial hardship

  • to deal with complaints and legal proceedings

  • to meet our legal and regulatory requirements (such as reporting matters to regulators or enforcement bodies when authorised or required by law)

  • to assist other credit providers as permitted by the Privacy Act.

Credit reporting bodies

Please be aware that we may also disclose credit information relating to your dealings with us (including any defaults on payments or serious credit infringements) to credit reporting bodies. In turn, these reporting bodies may include that information in reports to other credit providers who are assessing your credit worthiness.

We access and disclose credit information to the following credit reporting bodies:

CreditorWatch Pty Ltd

Website: https://creditorwatch.com.au/

Postal address: GPO Box 276, Sydney, NSW, 2001.,

Equifax Australia Information Services and Solutions Pty Ltd

Website: www.equifax.com.au

Postal address: PO Box 964, North Sydney, NSW 2059

Each of these bodies is required to have a policy which explains how they will manage your credit reporting information – to view these policies, please visit their respective websites and follow the "Privacy" links, or contact them directly for further information.

5. Accessing and correcting personal information

Accessing your personal information

It’s your right to access any personal information we currently hold about you. If you’d like to request something simple (such as checking the address we have on file), it’s best to speak to our Customer Service team. If you have a more complex enquiry, we recommend submitting it in writing to make sure we respond accurately.

Usually, we’ll provide the information within 30 days of receiving your request. A small admin fee may apply to retrieving information – we’ll let you know in advance if this applies to you.

There are a few reasons why we may be unable to grant your request – and if any of these apply, we’ll advise you in writing. For example, we may deny your request if disclosing the information:

  • is not allowed by law

  • may pose a threat to the health or safety of an individual or the public

  • may have an unreasonable impact on someone else’s privacy

  • may reveal internal information relating to a commercially sensitive decision-making process.

Making a correction

We take reasonable steps to ensure that personal information we hold is accurate, complete, and kept up to date. For this reason, we ask you to let us know as soon as possible if any of your information changes, such as your address or phone number.

If you consider that any information we hold about you is incorrect in any way, you’re welcome to request a correction. Just keep in mind that there are certain situations where we may not agree to make your requested correction – if this occurs, we’ll let you know in writing, and explain our reason why.

To request access to the information we hold about you, or to request a correction, you can:

Complaints

If you believe that we’ve failed to comply with the Privacy Act (including credit reporting requirements in Part IIIA) or the Credit Reporting Privacy Code, please contact our complaints team. From there, we will follow our internal dispute resolution process.

To get in touch with our complaints team:

If your complaint remains unresolved, you can refer it to a recognised external dispute resolution scheme ("EDR"). Avenue Bank is a member of the Australian Financial Complaints Authority ("AFCA"), which independently and impartially resolves disputes between customers and participating members on matters including Privacy and Credit Reporting. AFCA’s contact details are:

Australian Financial Complaints Authority

GPO Box 3

Melbourne Victoria 3001

Australia

Phone: 1800 931 678

Email: info@afca.org.au

Website: www.afca.org.au

Alternatively, you can refer the matter to the Office of the Australian Information Commissioner (the "OAIC"). Their contact details are:

The Office of the Australian Information Commissioner

GPO Box 2999

Canberra ACT 2601

Australia

Phone: 1300 363 992

Fax: 02 9284 9666

Website: www.oaic.gov.au

Can you contact us anonymously?

You’re welcome to contact us anonymously or using a pseudonym with general comments or questions – however, if your enquiry is specific to an account (or relates to your personal information), we’ll need to identify you before we can engage in further discussions and correspondence.

6. Security, websites and cookies

Protecting your personal information

At Avenue Bank, we take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. As well as following industry standard information security frameworks and best practices, we regularly assess our technology operations and partners to ensure compliance to our internal policies. We also make sure our staff are appropriately trained on privacy and information security.

Protecting your personal information is a responsibility you also share – so if you become aware of any security breaches relating to your account or your personal information, contact us right away using the details at the bottom of the page.

Tracking information on the web

For statistical purposes, we collect information on our website activity – including the number of users who visit our website, the date and time of visits, the number of pages viewed and navigation patterns. We also gather information on which countries, systems and other websites through which our website is accessed. We obtain this information by using 'cookies' (explained further below) as well as third party systems.

Our website may also contain links to other websites, provided for your convenience. While we try to link only to sites that share our high standards and respect for privacy, we are not able to guarantee the privacy practices of other websites – and they may differ from ours.

Cookies

A 'cookie' is a packet of information that allows a website to identify and interact more effectively with a computer. Cookies don’t identify you personally, but they do identify your browser type and Internet service provider.

Cookies are widely used on websites and for direct marketing purposes to help with navigation, monitor usage and to help personalise the user experience – and we may use cookies for all of these reasons, particularly to enhance your experience.

Your browser can be individually set to accept all cookies, reject all cookies, or notify when a cookie is sent. Just keep in mind that if you reject cookies, there may be limits on how our website can be used. For more information on the use of cookies, please refer to the privacy policies of the websites that install them.

Website advertising

From time to time, we place advertisements on other websites. This may involve installing a cookie on a computer when our advertisement is viewed – which simply allows us to keep track of how many unique visitors we have to our site, and which advertisements they clicked through from. In turn, this allows us to measure the effectiveness of different advertisements.

To evaluate the effectiveness of our website advertising, we also may use third parties to collect statistical data. No personal data is collected on these occasions.

7. Contacting us

If you have any questions about this privacy policy, feel free to contact our operations team by:

Or, if you’d rather contact our Privacy Officer, here are the details:

Call 1300 283 265
Mon to Fri / 9am - 5pm (AEST)
© Avenue Bank Ltd ACN 628 073 085

Avenue Bank Ltd ACN 628 073 085, AFSL 520239, is authorised by the Australian Prudential Regulation Authority (APRA) to operate under a Restricted Authorised Deposit-taking Institution (RADI) licence until 7th September 2023. Under this restricted licence we are not required to meet the full ADI prudential framework and we will not be offering banking products to the general public.

Avenue Bank acknowledges and pays respect to the past, present and future Traditional Custodians and Elders of this nation and the continuation of cultural, spiritual and educational practices of Aboriginal and Torres Strait Islander peoples.