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Australia Privacy Policy

Last updated: 16 October 2024 

Effective from: 21 October 2024


ClearScore Australia Pty Ltd (ABN 21 624 386 330) and its related and associated bodies corporate ( us, we, our ) maintain a policy of strict confidence concerning your ( you, your ) personal information ( Privacy Policy ). This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) ( Privacy Act ). ClearScore Australia Pty Ltd will be the data controller for the data that you provide us or we collect in relation to the provision of our services to you. We want you to be informed and empowered with respect to your privacy when you use our services. Please read this Privacy Policy carefully before using our website or apps or registering to use our services. Together with our Terms, this Privacy Policy sets out our practices regarding your personal data and how we collect, process and treat it.
By visiting www.clearscore.com/au/ ( Site ) and using our apps and services you are accepting and consenting to the practices described in this Privacy Policy. This Privacy Policy applies to information provided to us whether via this Site or any other means and demonstrates how we will comply with the Australian Privacy Principles (APPs) under the Privacy Act.
References to our website include references to our apps.

Privacy Policy
The information we collect
How we use the information
Who we may share your data with
Why are we using this information?
Direct marketing and how you can change your preference
How we keep your information secure
How long will we keep your information?
Links to and from third party websites
Your rights
Changes we make to our Privacy Policy
Contacting us and complaints

The information we collect
We collect and process information which:

  • you give to us when you register with us, such as your name and contact details
  • we obtain from Credit Reporting Bodies on your behalf
  • we obtain from our Cybercheck Partners
  • we collect about you based on your use of our website or from your mobile device if you are using our app
  • we receive from other sources, such as third parties who give us information about you
  • is collected from cookies. For more information, see our Cookies Notice.

Information you give us. You may give us information about you when you use our services or by communicating with us. This includes information you provide when you participate in discussion boards, answer specific questions on our website, provide us with feedback, participate in surveys, and when you report a problem.
The personal information you give us may include:

  • Title
  • Name
  • Income
  • Email address
  • Date of birth
  • Phone number
  • Passport details
  • Monthly expenditure
  • Residential details
  • Employment details
  • Address history
  • Bank details
  • Property value
  • Deposit amount
  • Monthly rental income
  • Mortgage details
  • Driving licence details
  • Energy and gas tariff details
  • Lifestyle information

Information we collect from Credit Reporting Bodies on your behalf. If you register to use our services, we will obtain your credit score and credit report from one or more Credit Reporting Bodies on your behalf. Credit Reporting Bodies include Experian, illion and Equifax. When you click to search for credit offers on our website or our apps, we may also obtain your credit score and report from one or more of the Credit Reporting Bodies to undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances.

Information we collect about you based on your use of our website or apps. Each time you visit our website or use our app we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address, your login information, browser type and version, time zone setting, operating system and platform
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number

Information we collect from our Cybercheck Partners on your behalf. All our registered customers benefit from our ClearScore Protect service, upon email verification. To provide you with this service, we share the email address and your passport number (if provided) connected with your ClearScore account with our Cybercheck Partners (see more here), who use this information to identify whether any of your information may have been compromised. The Cybercheck Partners will not use the information you’ve shared for any other purpose (including marketing) and will only keep it for the time necessary to conduct the check after which it will be deleted.

If you verify your email and activate the ClearScore Protect service to include dark web monitoring, we may also receive information about you such as:

Name
Addresses
Social profiles
Email addresses
Passport details
Phone numbers
Usernames
Date of birth
Education and professional history

 

Information we receive from other sources. We may receive information about you if you use any of the websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them, such as your credit report information, whether or not you have taken out a product with them, what other products you may have used, and other such details.

Information collected from cookies. We and our service providers collect information about your use of our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Cookies Notice.

Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us.

How we use the information
We use information we hold about you to provide our services to you and improve those services, administer your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.

Information you give to us or we collect from Credit Reporting Bodies, Cybercheck Partners or other third parties on your behalf as part of our services. We will use this information to:

  • administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other electronic means
  • verify your identity as part of our identity authentication process
  • provide you with information, products and services
  • where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you
  • notify you about changes to our services
  • ensure that content from our website is presented in the most effective manner for you and your device
  • aggregate it on an anonymous basis with other data for data analytical and reporting purposes
  • undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our services.

Information we collect about you based on your use of our website. We will use this information:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
  • as part of our efforts to keep our website safe and secure and to prevent fraud
  • to make recommendations about products or services that may be of interest

Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.

Recording telephone calls and other communications. We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.

What we will never do. Rest assured, we will never sell your personal information to third parties.

Who we may share your data with
We may share your data with other members of our group and with other third parties, such as our service providers, advertisers, Credit Reporting Bodies, our Cybercheck Partners and fraud prevention agencies.

We may need to disclose your data to others to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described below.

These third parties act on our instructions and are processors of your information.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.

Service providers (sub-processors). We may share your personal information with third party service providers and suppliers who provide us with services that we need in order to operate the website, apps and supply the services. These service providers do not have permission to use any of your personal information that we provide to them for any purpose other than the purpose for which we provide it to them. These third parties act on our instructions and are processors of your information.

Group company. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Selected third parties. We may also share your information with selected third parties including:

  • Credit Reporting Bodies, to obtain your credit score and credit report on your behalf and to provide our services to you (please see "Credit Reporting Bodies" below for more detail)
  • Fraud prevention agencies, to prevent crime and trace those responsible (please see "Fraud Prevention Agencies" below for more detail)
  • Product providers, such as our business partners who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products, to:
      • assess whether you are an existing customer and for fraud prevention purposes
      • conduct analysis to provide you with better products and services in the future, and for segmentation purposes
      • pre-fill an application form with the product provider
      • assess your eligibility for a product based on criteria set by the product provider

We may also share your information with product providers to:

      • assess your probability of being accepted for a product based on the information you’ve provided us, so we can indicate to you as part of our services whether or not you are likely to be accepted for a product when you search for credit offers on our website or apps;
      • assess whether you are eligible for pre-qualified offers based on the information shared against product provider criteria. Pre-qualification is dependent on the accuracy of your information and any changes made to this information directly with the product provider can lead to a change in this pre-qualified status.

You can opt out of this if you want to in your "My Account" section, however, if you do opt out of this, we will not be able to show you any pre-qualified offers or assess your probability of being accepted for a product.

The product provider does not have permission to use this data for any other purpose including marketing

  • Service providers we use (such as comparison sites and aggregators) for analysis and profiling of your credit information (and any other data provided by you or on your behalf) to identify and inform you of credit products that are likely to be suited to your credit circumstances through targeted advertising. When you click to search for credit offers on our website or our apps, these service providers will record an access by you on your credit file, but this record will be invisible to other lenders, so by itself it will not affect their lending decision and it will not affect your credit score. You can opt out of this if you want to in your "My Account" section, however, if you do opt out of this, we will not be able to show you credit offers on our website or apps that are targeted to you and will only be able to show you generic ads, which may not be suited to your credit circumstances.
  • Cybercheck Partners, to obtain details of any recorded cybersecurity incidents affecting your nominated email account and/ or passport.
  • Advertisers and advertising networks that require data to perform services on our behalf, including selecting and serving relevant adverts, to you and others and to make sure their adverts reach their intended audience. We share your personal information with these advertising partners and advertising networks for interest-based advertising or “targeted” advertising campaigns, and with advertising partners that help to analyse our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services. You may see certain “interest-based advertising” or “targeted advertising” on other websites or online services based on information relating to your access to and use of our Services and other websites. We may provide third party services with personal information to deliver ClearScore advertisements on third party websites that may be tailored to your individual interests. These interest-based advertising platforms may also use personal information about you that they have independently collected and in accordance with their privacy policy and practices, including through the use of cookies. You can opt out of these data sharing arrangements at any time in the "My Account" section on our website.
  • analytics and search engine providers that assist us in the improvement and optimisation of our service
  • external affiliate network partners. We share the information that you have clicked on a sponsored link from our website or app with our external affiliate network partner. We use a unique ClearScore URL or “hyperlink,” and will not share any personal identifiers or information in doing so. Our external affiliate network partner may track you through that lending partner’s website, including connecting our hyperlink with you in order to calculate a potential commission to ClearScore in line with their own privacy policies and practices. You can opt out of these data sharing arrangements at any time in the "My Account" section on our website
  • if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (or the buyer or seller's advisers)
  • if we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of ClearScore Australia Pty Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we share your personal information with third parties, they will be contractually bound to use the information only for the purposes of providing the services or performing the functions required by us and to store the information securely.

Credit Reporting Bodies. If you register to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated Credit Reporting Bodies. In order to provide these services to you, we will share your information with such Credit Reporting Bodies. . You authorise the Credit Reporting Bodies to hold, use and disclose any information about you that we provide to the Credit Reporting Bodies on your behalf, for the purpose of providing their credit reporting and debt collection services (including to other customers). Further information about how the Credit Reporting Bodies handle your personal information can be found at www.illion.com.au, www.equifax.com.au/privacy, and https://www.experian.com.au/privacy-policy-terms-conditions.

The information which we provide to the CRA may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.
If you choose to apply for a product, the lender may undertake a full credit check and provide you with further privacy information for that product. More information about each CRA and what it does with personal data is available here.

Fraud Prevention Agencies. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

Cybercheck Partners. We have partnered with web monitoring services to provide you with our ClearScore Protect service, which helps you to identify whether or not information associated with your email account or passport has been compromised online. To provide this service, we share your email address (the one we use to send you service emails regarding our services) with our Cybercheck Partners on a monthly basis, along with your passport number, if you have chosen to provide this. These providers will then check their databases to identify whether there are any recorded instances of your account details having been compromised. Your email address and passport number are processed solely on our instructions and will not be used by our partners for any other purpose, including marketing. We will notify you of the results of the dark web monitoring in the manner set out in our Terms. For more details about our ClearScore Protect service, please refer to our Terms here. We will not use the results of these dark web monitoring checks conducted on your behalf for any other purpose.

Why are we using this information?
We make sure we have your consent to collect, use and share data about you. If you have any questions about the purposes for which we collect and use your personal data, you can contact our Data Protection Officer.

We use your information where you have given us your consent or where use is necessary for the performance of a contract with you (such as delivering our core services to you) and our own legitimate interests.

Performance of a contract. We need you to give us the information you provide, and to collect information about you from the Credit Reporting Bodies, Cybercheck Partners or other third parties in order for us to provide you with our services as agreed in our contract with you. We cannot provide our services to you without collecting the information you give us because we need certain information from you to be able to seek your credit report and score and to show suitable financial offers to you.
For other types of information (such as the information we collect based on your use of the website and information we receive from our sources about you), we process this information for the purposes of providing our services to you as agreed in our contract and for the purpose of to enable us to:

  • provide a secure website to our customers; and
  • analyse our users' behaviour and preferences, and information collected from users' devices in order to have information required to be able to improve the services we provide to our customers and the user experience on our website.

Consent. We will always seek your consent to process your information. You have the right to withdraw or decline your consent at any time.

Our Legitimate interests. We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of our product providers or other suppliers. As an example, we may process your personal data to:

  • display tailored product offers to you
  • comply with laws that apply to us
  • provide you with our service, including for the purpose of quality control and analysis
  • protect you and us from fraud or other threats
  • improve our service and manage our customer relationships
  • analyse our users' behaviour and preferences and usage of our services, and information collected from users' devices in order to have information required to be able to improve the services we provide to our customers and the user experience on our website conduct analysis, segmentation and profiling of your data in order to provide you with direct marketing communications
  • conduct analysis, segmentation and profiling of your data in order to provide you with direct marketing communications if you have consented to receive direct marketing

We may also process it for marketing and advertising purposes, including:

  • share information about your visits to our sites and app, and/or your email address (in a hashed or other masked format) with our advertising partners, including social media networks like TikTok and Meta/Facebook, for interest-based advertising or targeted advertising campaigns. That will help us manage and deliver our marketing, including by:
      • excluding you from seeing targeted adverts if you have opted out of ClearScore marketing
      • creating audiences for our advertisements to social media network users who may be similar to you based on the data that the social media network holds about you
  • including you in audiences to receive marketing when you’re on a social media network

You can opt out of this data sharing at any time in the "My Account" section on our website.

Direct marketing and how you can change your preference
We offer you the opportunity to receive marketing information from us. You can opt out easily of receiving marketing from us at any time.

We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods.

You may receive the following types of communications from us:

  • Product recommendations- we'll get in touch with personalised, timely product recommendations that can help you improve your financial situation. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.
  • Content communications- we'll send you content such as tips, research, features and news, coaching programmes on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
  • Core communications– we will send you your credit report every month, security alerts pertaining to your ClearScore account, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a ClearScore account and cannot be opted-out of.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe. You may also update your preferences here.

You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to help@clearscore.com.au.

How we keep your information secure
We take the security of your data very seriously and use strict procedures to protect it. Whenever we transfer personal data outside of Australia, we ensure that appropriate safeguards are in place to protect the data.

All information you provide to us is stored on our secure servers.

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

Where possible, we try to only process your personal data within Australia. If we or our service providers transfer personal data outside of Australia, we consider these service providers are bound to legislation similar to the Privacy Act and APPs and we take steps, including through contractual mechanisms, to ensure your personal data is given equivalent levels of protection and rights.

If necessary to provide you with our services or support, we may share your personal data with our affiliates located in the UK. In addition, part of our customer services function is based in India. We have put in place safeguards to protect personal data processed in or accessed from India.
If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information, in accordance with our document and information retention policy.

Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.

How long will we keep your information?
While your account remains active, we keep your information for no longer than is necessary depending on the purpose for which we are using it.
How long we keep your information will depend on the purpose for which we use it. While you are a customer of ours, we will only retain your information for as long as is necessary for those purposes.
After termination of your account, we may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other users. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for fraud prevention purposes and for the exercise or defence of a legal claim.

Links to and from third party websites
If you follow a link to or from our website to a third party website, please be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies.

Your rights
You can exercise specific rights with regards to the data that we hold about you.
We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:
You can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with this policy.
You are generally entitled to correct personal information we hold about you that is inaccurate or incomplete. Please contact us at help@clearscore.com.au if you want to make a correction request.

For the exercise of any of your rights, you can also contact us at help@clearscore.com.au.

Changes we make to our Privacy Policy
We may vary the terms of this Privacy Policy at any time.
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Contacting us and complaints
You can address any questions, comments, complaints or requests regarding this Privacy Policy to the Data Protection Officer at help@clearscore.com.au.

If you have a complaint you must send it to us in writing and we will deal with it within a reasonable timeframe, usually 30 days. If you are not happy with our response you may make a complaint to the regulator, the Office of the Australian Information Commissioner. More information is available at:
https://www.oaic.gov.au/privacy/privacy-complaints/

 

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