1. Scope of this policy
This Policy explains how Securegistry Pty Ltd (“eGuarantee”, “we”, “our” or “us”) collects, discloses, shares, uses and holds your Personal Information. We are bound by the Privacy Act 1988 (Cth). This Privacy Policy applies to all individuals who use our products and services, contact us or visit our website, whether or not you obtain any products or services from us.
We are committed to ensuring your Personal Information is protected. We manage your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (“Privacy Act”).
2. What Personal Information do we collect and hold?
Personal Information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.
We do not collect your Sensitive Information (as defined by the Privacy Act).
We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver our products and services to you, or as otherwise permitted by law.
We collect Persona Information about you when you interact with us, for example, when you email or phone us or visit www.eguarantee.com.au (“Website”) or when you request or use our products or services, including creating an account with us (“Account”), which can be accessed via our Website or mobile application (“App”).
If you do not provide us with your Personal Information we may not be able to provide you with our products or services, communicate with you or respond to your enquiries and you will not be able to create an Account. For each individual who registers to create an Account, we will collect your user name, email address, mobile telephone number and password and any other Personal Information which you are required to provide as part of the registration process from time to time. In respect of each individual guarantee which is provided to us, we will need to collect the names and email addresses of a guarantor contact and a tenant contact and other credit related information (for example, credit history, any repayment obligations, credit ratings or hardship applications).
When you use our Website or App, we may collect non-Personal Information about how you access, use and interact with the Website or App. This information may include:
- the location from which you have come to the Website and the pages you visited; and
- technical data, which may include your IP address, the types of devices you are using to access the Website or App, device attributes, browser type, language operating system and location data.
3. Do we collect Personal Information from third parties?
We will collect most Personal Information directly from you when you interact with us. However, we may collect Personal Information about you from third parties, such as:
- our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers;
- your employer or your landlord (if you are employed by a tenant);
- our Authorised Affiliates;
- law enforcement agencies and national and international regulatory authorities, such as the Australian Taxation Office, the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission and the Australian Transaction Reports and Analysis Centre.
We may also collect information from publicly available sources. If you provide any Personal Information to us about another person, you must:
- have the consent of that person to provide such information to us; and
- inform that person that their personal information will be used, held and disclosed by us in accordance with this Privacy Policy; and
- inform that person that they can access and correct their information in accordance with this Privacy Policy.
4. Why do we collect, hold, disclose and use your Personal Information?
We collect, hold, disclose and use your Personal Information so that we can:
- identify you and provide you with an Account, if applicable;
- provide you with products and services, and manage our products and services and our relationship with you;
- contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
- comply with our legal obligations and assist government and law enforcement agencies or regulators; and
- inform you of other products and services which may meet your needs or requirements of your business or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires, or other matters which we believe are of interest to you (such as recruitment or job opportunities);
We may also use Personal Information about you for other purposes such as:
- for credit-related purposes as set out in our credit consent policy;
- for direct marketing purposes, including personalised or tailoring advertising and advertising communications and our Website and App;
- for carrying out our internal operations, such as record keeping, training and auditing.
- for recovering funds and/or secured property when you are in default of your obligations;
- detecting, investigating or preventing actual or potential fraud in connection with the products or services that we may provide to you;
- administer, improve and manage our products and services, Website and App (including customising the advertising and content on our Website and App) and relationship with you;
- to develop and train artificial intelligence (AI) models. If we use your information or data to develop and training AI models, we will ensure that your Personal Information is deleted from the datasets and that only de-identified information or data is used.
We will notify you about the use of your Personal Information for other purposes at or around the time the Personal Information is collected.
5. Direct marketing
We may use your Personal Information to identify and tell you about products or services offered by us or third party product and services that we think may be of interest to you.
Such marketing communications may be sent by email or other electronic means. If you no longer want to receive direct marketing, you can contact us using the details below, or by following the instructions provided in the email or other electronic communication to unsubscribe.
6. Who do we disclose your Personal Information to and why?
We may disclose Personal Information to our external service providers so that they may perform services for us or on our behalf. This may include:
- authorised external service providers who perform functions on our behalf, such as financial and credit card institutions in order to process any payments, internet and technology services providers, web developers, data analytics providers, hosting companies, marketing, advertising, communications and security service providers, identity verification providers and payment verification providers, third party payment processors, fulfilment companies, credit reporting agents, ratings or reference agencies, debt collection agents, debt purchasers, financial institutions, financial services licensors, debt funders and advisors, market research and recruitment service providers (collectively, “Authorised Affiliates”);
- other companies associated in a transfer or potential transfer of all or part of our business or assets;
- professional advisors including lawyers, accountants and auditors; and
- law enforcement agencies that may assist in the prevention of crime or fraud
7. How do we hold and store your Personal Information?
We implement and maintain processes and security measures to protect Personal Information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. Our security safeguards include:
- employing end-to-end SSL encryption;
- the use of identity and access management technologies to control access to systems on which information is processed and stored;
- requiring all employees to comply with internal information security policies and keep information secure;
- requiring all employees to complete training about information security; and
- monitoring and regularly reviewing our practices against our own policies and against industry best practice.
We will also take reasonable steps to destroy or de-identify Personal Information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted by law.
8. Overseas disclosures of Personal Information
In the course of providing you with our Website, App, products and services, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to Authorised Affiliates located in the following countries: Germany and the United States.
The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, we will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
9. Cookies and analytics policy
We use cookies on the Website. A cookie is a small text file that the Website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our Website for any of your future visits to the Website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the Website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the Website. We may also collect other kinds of Personal Information from you where you have authorised us to do so, where we have provided further information in a collection statement or where we are permitted to do so by law.
Services that our Website and App may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our Website and App. By using our Website and App, you consent to Google processing your data in the manner described in Google’s Privacy Policy (www.policies.google.com/privacy) and for the purposes set out in this Privacy Policy.
Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out (see https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh/related?hl=en-GB).
10. Access to and correction of your Personal Information
You may access or request correction of the Personal Information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your Personal Information. If you have an Account, you will also be able to access and update some of your Personal Information, such as your email address and name, yourself by accessing your Account. There is no charge for requesting access to your Personal Information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the Personal Information we hold about you remains accurate, up to date and complete.
11. Complaints
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation. If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
12. Contact Details
If you have any questions, comments, complaints or concerns, please contact us at: Telephone: 1300 561 804 Email:
13. Amendment to this Privacy Policy
From time to time, we may change our policy on how we handle Personal Information or the types of Personal Information which we hold. Any changes to this Privacy Policy will be published on our Website. You may obtain a copy of our current policy from our Website or by contacting us at the contact details above.