Sunshine Loans

GENERAL PRIVACY POLICY

1. Introduction

Sunshine Loans Pty Ltd ("we"/"us"/"our") endeavour at all times to comply with the Privacy Act 1988, Australian Privacy Principles and the Credit Information Privacy Code which together will be referred to in this policy as "Australian Privacy Law."

This General Privacy Policy applies to all persons accessing our website, dealing with us or from whom we otherwise collect personal information. We also collect personal and credit information provided by persons applying for or receiving credit from us and, in doing so, endeavour at all times to comply not only with Australian Privacy Law, in general, but also with the Credit Information Privacy Code.

All persons who apply for or receive credit from us or agree to guarantee another person's credit from us, will be further protected by our Credit Information Privacy Policy.

Any person who receives credit from us and applies to vary the terms of the payments on the grounds of hardship will be additionally protected by our Hardship Privacy Policy.

2. Pseudonyms

You are not required to provide us with your name or any personal information if you do not wish to. You are free to use any name allowed by law. We, however, will not deal further with you without obtaining your real name and other verifiable pieces of personal information.

We are not permitted by law to provide you with credit without obtaining proof of your identity and that is covered in our Credit Information Privacy Policy.

3. The kinds of personal information we collect

By accessing this website, or otherwise dealing with us, you agree to our General Privacy Policy in relation to the collection of personal information by the website.

As a result of your visit to our website, we may collect and store information about your visit to this website including:

• the domain name and IP address of the computer from which you accessed the internet;
• the date and time you accessed the website;
• the internet address of the website from which you linked directly to our website;
• the pages you accessed while visiting the website; and
• through the use of website software, and internet tracking devices (such as cookies), anonymous identifiers and session variables, we may also collect your email address.

Your internet service provider or the providers of your internet browser software may also collect such information for their own purposes. We are not responsible for the collection, storage and use of such information by these entities and refer you to their respective privacy policies.

As a result of you dealing further with us, whether as a prospective customer, an actual customer, guarantor and prospective guarantor, employee, prospective employee, contractor, supplier or service provider, we may collect and store personal information from you such as:

• your name;
• address, previous addresses and how long you have lived at those addresses;
• date of birth;
• your employer, previous employers and how long you have been in such employment;
• your email address;
• your telephone numbers; and
• the details of any references you supply, including the names, phone number and addresses of your referees.

If you apply to us for credit we will collect and store credit information in addition to the above personal information and this will be governed by our Credit Information Privacy Policy.

If you receive credit from us and you apply to us to vary your payment arrangements under your credit contract due to hardship, you may supply us with sensitive information in addition to the above personal information and other credit information and this will be governed by our Hardship Privacy Policy.

If you apply to us for employment, we may also collect and store personal and, in addition, sensitive information about you including your:

• education, training and other qualifications;
• work history;
• your Curriculum Vitae (CV);
• Personal References;
• professional or trade associations or union membership;
• hobbies and other interests;
• Personal Insovency status;
• PEP and Sanctions results;
• ASIC banned and deregistered status; and
• criminal history.

4. How we collect your personal information

We may collect personal information about you from your visit to our website through the use of technologies such as anonymous identifiers, session variables, and cookies. You may be able to set your internet web browser to block or limit cookies. Some features of our website may not work as efficiently or not at all if you have done so.

As a result of you dealing further with us, we may collect personal information directly from you and this maybe over the telephone, by mail, over the internet, by email or by completion of an application or consent form whether on-line or otherwise.

If you:

• apply to us for credit;
• agree to guarantee credit from us to another person;
• receive credit from us;
• apply to us to vary the terms of your payments under your (consumer) credit contract whether or not on the grounds of hardship; or
• apply for employment with us;

we may collect personal, credit and sensitive information about you from other sources when it is impractical or unreasonable for us to collect it directly from you. Among these other sources may be:

• a credit reporting body;
• someone authorised by you such as an agent, broker, accountant, solicitor, financial counsellor, introducers or a guarantor;
• a referee;
• an employer;
• a government body;
• another financial institution;
• a professional or trade association or trade union;
• our agents.

and we may collect that information directly from them, over the telephone, by mail, over the internet, by email or by completion of an application or consent form whether on-line or otherwise.

When applying for Credit, your personal identification information entered by you as part of our application process, may be subject to an Information Match Request with the document issuer or official record holder, via a third party system, for the purpose of confirming your identity.

5. How we hold your personal information

We use our best endeavours and take all reasonable steps to secure your personal information including:

• maintenance of a secure environment for storage of information whether in hard copy or in electronic form;
• requiring that access to such information be confined to authorised personnel only; and
• using technology such as encryption and password protection to secure any information kept in electronic form.

We are not responsible for the security of any computer or other device which you use to access our website.

6. The purposes for which we collect, hold, use and disclose your personal information

If you are a user of our website, a prospective customer, a customer or guarantor of a customer's credit, a contractor or supplier of goods and services to us, a job applicant or other person from whom we collect, hold, use and disclose your personal information we shall do so only for those purposes which are:

• permitted by Australian Privacy Law;
• necessary for:
  • the administration of any contract of supply of goods or services to or by us;
  • confirming via a third party, your identification document details supplied with the document issuer or official record holder for the purpose of confirming your identity;
  • the provision of our products to our customers;
  • the consideration, assessment and administration of any proposed guarantee of credit;
  • assessment and processing of any job application; and
  • otherwise for the administration and management of our business;
• for the improvement of website useability;
• required by law;
• required in order to investigate or assist with any investigation into any complaint about the conduct of our business, in particular, under Australian Privacy Law;
• to otherwise enforce any term of any contract or other right which arises out of our dealings with you;
• to communicate with you, by way of direct marketing, information about our products and services. If you do not wish us to do so, you can "opt out" of such communication by informing us by telephone, by post or by email;
• to communicate with you, by way of direct marketing, information about the products and services of our related and allied entities. If you do not wish us to do so, you can "opt out" of such communication by informing us by telephone, by post or by email;
• to communicate, including your contact details and financial and consumer credit information, to other financial or referral service providers for marketing purposes; and that as a result of such communication, you may be offered a financial product by another lender based on their credit assessment of your application to us which is not the same type, (for instance, it may be a personal loan or line of credit) for a different amount and on different terms than the one for which you have applied for or entered into with us.
• other financial services providers with which we have entered into agreements, personal information but not credit or sensitive information for the purposes of those financial services providers directly marketing to you;
• to search and/or register any Personal Property Securities;
• necessary as part of a prospective sale, transfer or restructure of our business; or
• to otherwise communicate with you or the purposes outlined above.

In addition, if you apply to us for credit or receive credit from us, we will collect, hold, use and disclose your personal information in order to:

• assess your credit application including that of any proposed guarantor;
• manage your credit contract;
• consider any application for variation of your payments whether or not on the grounds of hardship;
• collect any debt or otherwise enforce any rights arising under your consumer credit contract.

To find out more on how we deal with your credit information or sensitive information if you apply to us for credit or receive credit from us, please see our Credit Information Privacy Policy.

We may disclose your personal information, including credit and sensitive information, to other parties as part of a process of merger, acquisition, capital raising, sale of our business or our other assets., Before doing so, we will obtain from those other parties contractually enforceable Non-Disclosure Agreements which will limit their collection, holding, use and sharing of your personal information to the specific purpose of due diligence for such merger, acquisition, capital raising, sale of business or other assets.

If, for any of the above purposes, we disclose your personal information to any supplier of services to our business or to any prospective purchaser of our business, which we shall do so only if it is necessary for the purposes listed above, we shall:

• do so in accordance with Australian Privacy Law;
• obtain assurances from those suppliers that they comply with Australian Privacy Law.

7. Whether we supply your personal information to overseas recipients

All personal information received by Sunshine Loans remains in Australia.

8. How you may access your personal information held by us

You may request access to your personal, sensitive and credit information held by us by identifying yourself according to our identification criteria and sending your request for access to us at:

Sunshine Loans (https://support.sunshineloans.com.au)

If we are unable to grant your access to personal, sensitive or credit information, we will give you our reasons in writing within a reasonable time. These include where providing the information to you may:

• reveal personal information about another individual person;
• pose a threat to the health or safety of another individual person;
• not be permitted by law;
• reveal internal information of a commercially sensitive nature which is not required to be disclosed to you by Australian Privacy Law.

9. How you may correct any personal information we hold about you which is incorrect

If you believe any personal information which we hold about you is incorrect, please contact us by telephone, by email, identify yourself in accordance with our identification criteria and tell us what information which we hold about you is, in your belief, incorrect and how you want it changed.

If we cannot agree to the change to the information which you have requested, we will give you reasons in writing.

10. How you may complain about how we deal with your personal information

If you are not satisfied with the reasons referred to above or otherwise have any complaint about how we collect, hold, use or disclose your personal information please contact our Privacy Officer who will then follow our Internal Dispute Resolution process.

Our Privacy Officer can be contacted at https://support.sunshineloans.com.au and by telephone on 07 5526 8866 or by post PO Box 823, Surfers Paradise Qld 4217

If you are not satisfied with our Internal Dispute Resolution process, you may refer your complaint to our External Dispute Resolution Scheme.

Our External Dispute Resolution Scheme is:

Australian Financial Complaints Authority, or AFCA.

AFCA provides fair and independent financial services complaint resolution that is free to consumers.

Website: www.afca.org.au
Email: info@afca.org.au
Tel: 1800 931 678 (free call)
In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001

You can, of course, at any time, refer directly to:

The Office of the Australian Information Commissioner
GPO Box 2999
CANBERRA ACT 2601
Tel: 1300 363 992
Fax: 02 9284 9666
Website: www.oaic.gov.au

11. Changes to this Policy

From time to time, we may make changes to this General Privacy Policy because of:

• changes to the law;
• changes to technology;
• changes to our systems.

We will notify such changes on our website. Where the changes may affect you in a particular way, and you have a (consumer) credit contract with us, we will notify you if required by Australian Privacy Law and our Credit Information Privacy Policy.

CREDIT INFORMATION PRIVACY POLICY

1. Introduction

Sunshine Loans ("we"/"us"/"our") endeavour at all times to comply with the Privacy Act 1988, Australian Privacy Principles and the Credit Information Privacy Code which together will be referred to in this policy as "Australian Privacy Law."

This Credit Information Privacy Policy is subject and in addition to our General Privacy Policy. It applies to you if:

• you apply to us for one of our credit products;
• you receive credit from us; or
• we otherwise hold credit information about you or information about your eligibility for credit or credit worthiness.

2. What kinds of credit information do we collect, hold, use and disclose?

As well as, and in addition to, the information collected under our General Privacy Policy, if you apply for credit from us we may collect:

• Identification information which may have been checked with the document issuer or official record holder and subject to a data match for the purpose of confirming your identity;
• Financial Information including:
  • Income (from all sources including government benefits) and current employment status and recent history;
  • Assets;
  • Expenses;
  • Debts;
  • Statements of Deposit Accounts with financial institutions for the 90 days prior to you making your application to us for consumer credit and for later periods if you receive consumer credit from us.
• Consumer credit liability information about the consumer credit accounts you hold whether with us or some other credit provider including:
  • type of account;
  • when it was opened and, if applicable, closed;
  • if a credit account, then the maximum amount of credit approved;
  • other specific terms and conditions of the account.
• Information about your credit application including:
  • The type of credit, whether consumer or commercial;
  • The amount of credit sought.
  • Whether we made an information request about you to a Credit Reporting Body.
• Default information about you, where you have failed to make a payment owed by you to us or some other credit provider which has remained overdue for more than 60 days, and after giving you notice as required by the Australian Privacy Laws, we may disclose to a Credit Reporting Body or which has already been disclosed to a Credit Reporting Body by another credit provider.
• Payment information which discloses that you have made an overdue payment whether to us or to another credit provider.
• New payment information about you as to the terms and conditions of any variation in the payments required under your credit contract with us or with another credit provider.
• Court proceedings information about a judgment of any Australian court that was made against you in relation to any credit that was provided to, or applied for by, you.
• Personal insolvency information which has been recorded in the National Personal Insolvency Index maintained by the Insolvency and Trustee Service of Australia relating to any bankruptcy, debt agreement, debt agreement proposal or a personal insolvency agreement executed by you, and any direction or order made under the Bankruptcy that relates to your property.
• Publicly available information about you that is not otherwise described above but which is relevant to your credit worthiness.
• Serious credit infringement information which relates to credit which we or some other credit provider has provided to you to the effect that you:
  • fraudulently obtained credit;
  • fraudulently evaded payments under a credit contract;
  • are not able to be contacted at the last known addresses supplied to us or have not been in contact with us for 6 months; or
  • are otherwise no longer intending to comply with your credit obligations.

3. How do we collect credit information?

We collect credit information in the same ways we collect personal information as described in our General Privacy Policy and, additionally:

• We collect credit information about you from you directly such as in an application form for credit; and
• We collect credit information about you from Credit Reporting Bodies.

4. How do we hold your credit information?

We hold and keep secure your credit information in the same ways as all your personal information as described in our General Privacy Policy.

5. How do we disclose your credit information?

In order to obtain credit information about you from Credit Reporting Bodies we may be required to disclose to them credit information about you which we hold. Those Credit Reporting Bodies may then include that credit information about you in reports they provide to other credit providers.

This includes all the credit information described above with the exception of your Financial Information. It does, however, particularly include:

• Information about your credit application;
• Default information; and
• Serious Credit Infringement information.

The credit reporting body to which we may disclose your credit information is:

Equifax Pty Ltd
PO Box 964,
NORTH SYDNEY NSW 2059
Website: equifax.com.au/contact

We refer you to the Privacy Policy of this Credit Reporting Body.

https://www.equifax.com.au/privacy

6. The purposes for which we collect, hold, use and disclose your credit information

In addition to those purposes described in our General Privacy Policy, we collect, hold, use and disclose your credit information to:

• assess your credit application and that of any proposed guarantors of your credit;
• manage your credit contract;
• consider any application for variation of your payments whether or not on the grounds of hardship;
• collect any debt or otherwise enforce any rights whether by court proceedings or otherwise arising under your credit contract;
• assist you if we consider you may be at risk of default;
• participate in the Credit Reporting Body system and provide information to Credit Reporting Bodies as described above;
• undertake securitisation activities or any assignment of debt;
• deal with any complaint by you through our Internal Dispute Resolution process or through our External Dispute Resolution scheme as described in our General Privacy Policy;
• to identify you as required by the Anti-Money Laundering/Counter-Terrorism Financing Act;
• meet our legal requirements including Information Privacy to relevant authorities;
• assist other credit providers with the same purposes as permitted by Australian Privacy law such as disclosing credit information to them with your consent or where you have committed a serious credit infringement.

We shall not disclose your credit information to any other party for the purposes of direct marketing though we may disclose other personal information for that purpose as described in our General Privacy Policy.

7. Whether we supply your personal information to overseas recipients.

We do not supply your credit information to overseas recipients.

8. How you may access your credit information held by us

You may access your credit information held by use in the same way and subject to the same restrictions as you may access any of your personal information held by us as described in our General Privacy Policy.

There is no charge to make a request for access to your credit information but we may apply an administration fee for providing access to your credit information.

We cannot give you access to credit information held about you by any Credit Reporting Body whether that body obtained the information from us or not. We refer you to the Privacy Policy of that Credit Reporting Body. https://www.equifax.com.au/privacy

9. How you may seek correction of the credit information we hold about you

You may apply to correct the credit information we hold about you in the same way and subject to the same restrictions as you may do so for any of your personal information held by us and as described in our General Privacy Policy.

We will deal with your request according to Australian Privacy Law and provide you our response and/or reasons within 7 business days of making our decision and no later than 30 days after receiving your request.

If we have supplied credit information which we have agreed to correct to a credit reporting body, we will notify that body within 7 business days of making that decision.

10. How you may complain about how we deal with your credit information

If you are not satisfied with how we have dealt with your credit information, please contact our Privacy Officer in the same way as is described in our General Privacy Policy.

Again, if you are not satisfied with our Internal Dispute Resolution Process in relation to credit information, you may refer your complaint to our External Dispute Resolution scheme as described in our General Privacy Policy or to the Office of the Australian Information Commissioner.

11. Changes to this policy

We may change this policy for the same reasons and in the same manner and with the same notice as is described in our General Privacy Policy.

HARDSHIP PRIVACY POLICY

1. Introduction

Sunshine Loans ("we"/"us"/"our") endeavour at all times to comply with the Privacy Act 1988, Australian Privacy Principles and the Credit Reporting Privacy Code which together will be referred to in this policy as "Australian Privacy Law."

This Hardship Privacy Policy applies if you:

• have received credit from us;
• are experiencing difficulty in meeting your repayment obligations under your (consumer) credit contract with us; and
• have applied for or approached us for a variation in those obligations on the grounds of hardship whether as result of receiving a Notice of Default or other notice from us or otherwise.

It is subject and in addition to our General Privacy Policy and our Credit Information Privacy Policy.

2. Hardship

"Hardship" as defined in the National Consumer Credit Protection Act ('NCCP') may include "illness, unemployment, family violence or other reasonable causes." In the course of you applying for a variation in repayment terms on the grounds of hardship, we may collect from you information to verify the illness, unemployment or other reasonable causes of hardship. This will, most likely, be "sensitive information" under Australian Privacy Law.

3. Sensitive Information

We will only collect sensitive information that is relevant to your application for a variation in your repayment terms on the grounds of hardship. Such information may include:

• health information about you or another member of your family;
• confirmation of your current employment status;
• changes to your domestic situation;
• other information relevant to your hardship application which are not otherwise usually collected by us.

4. The purposes for which we collect and use your sensitive information

We will only collect, use, hold and disclose your sensitive information for the following purposes and in the following ways to:

• assess your application for a variation to the terms of repayment under your (consumer) credit contract on the grounds of hardship ('hardship variation').
• explain our decision whether or not to agree to a hardship variation.
• administer, monitor and record any agreed hardship variation.
• consider any complaint about our decision to refuse a hardship variation in our Internal Disputes Resolution process.
• respond to any complaint about our decision to refuse a hardship variation made to our External Dispute Resolution scheme.
• manage our business including our responsible lending obligations and our systems for considering applications for hardship variations as required by the NCCP and other relevant laws.
• account to relevant authorities under the NCCP and Australian Privacy Law.

5. How we disclose your sensitive information

We shall not disclose your sensitive information to any party except for the purposes described above and as permitted by Australian Privacy Law.

In particular, we shall not disclose your sensitive information to any credit reporting body or any other credit or financial services provider though we may disclose that you have entered into a hardship variation to such parties.

6. Whether we supply your sensitive information to overseas recipients.

We shall not provide your sensitive information to overseas entities.

7. How you may access your sensitive information held by us

You may access your sensitive information held by us in the same way and subject to the same restrictions as you may access any of your personal information held by us as described in our General Privacy Policy.

There is no charge to make a request for access to your sensitive information but we may apply an administration fee for providing such access.

8. How you may seek correction of the sensitive information we hold about you

You may apply to correct the sensitive information we hold about you in the same way and subject to the same restrictions as you may do so for any of your personal information held by us and as describe in our General Privacy Policy.

9. How you may complain about how we deal with your sensitive information

If you are not satisfied with how we have dealt with your sensitive information, please contact our Privacy Officer in the same way as is described in our General Privacy Policy.

Again, if you are not satisfied with our Internal Dispute Resolution Process in relation to your sensitive information, you may refer your complaint to our External Dispute Resolution scheme as described in our General Privacy Policy or to the Office of the Australian Information Commissioner.

10. Changes to this policy

We may change this policy for the same reasons and in the same manner and with the same notice as is described in our General Privacy Policy.