This policy provides information as to the kinds of personal information that the Wingate Group collects and the ways it may be stored, used and disclosed. The Wingate Group includes Wingate Group Holdings Pty Ltd ACN 128 511 035 and its subsidiaries, related bodies corporate and associates (each as defined in the Corporations Act 2001 (Cth) (“Corporations Act”)).
We are committed to respecting your privacy and protecting your personal information. We are also committed to complying with our obligations under the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles as they apply to private sector organisations, and other applicable laws which govern the handling of personal information.
We sometimes handle personal information relying on exemptions under these laws, for example in relation to employee records. Any permitted handling of personal information under such exemptions will take priority over this policy to the extent of any inconsistency.
We may collect various types of information from you. Some of this information is personal information, some is non-personal. When we refer to personal information, we mean information or an opinion about an identified individual, or an individual who is reasonably identifiable.
The types of personal information we collect may include your name, date of birth, addresses, postal or email details, financial details, financial position statements, tax file number, tax returns, personal identification documents (e.g. drivers licence and passport details) credit-related personal information (see section 9 below) and other information that we may consider necessary.
If you are a job candidate, we may also collect information about your experience, qualifications, skills and character and/or conduct screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
We may not be able to do these things without your personal information. For example, we may not be able to provide you with our services or respond to your queries.
Where reasonable and practicable to do so, we will generally collect your personal information directly from you. Collection can occur in a number of ways, including:
We may record your interactions with us, including through telephone conversations, and emails, file notes and other records.
We may also collect personal information about you from other sources including public sources, information brokers and third parties such as agents, service providers, referrers (including originators or brokers), banks and other credit providers, credit reporting bodies and other third parties referred to in this policy.
Depending on the circumstances, we may disclose your personal information to:
We may also disclose personal information to other entities within the Wingate Group, for any of the purposes for which we may collect, use or disclose information that is set out in this policy.
We may also disclose such information as required or permitted by any law, for example in response to a subpoena or to the Australian Taxation Office, or following a direction issued under taxation laws.
Some of the third parties to whom we may disclose personal information may be located in other countries, including New Zealand. We will comply with our obligations under the Privacy Act in relation to these disclosures.
We take care to protect your personal information to protect such information from unauthorised access, modification or disclosure and from misuse, interference and loss. The safeguard measures we take include:
We may keep personal information in physical and electronic records, both at our own premises and, with the assistance of our service providers, in offsite backups or storage centres. Where we use other service providers, we will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We will only permit our service providers to process your personal data for specified purposes and in accordance with our contractual agreement.
If you are considering sending us any personal information through electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP).
We aim to keep your personal information only for as long as required to meet our legal and regulatory requirements or internal needs. Once your personal information is no longer required to be retained by us or at law, we will take steps for it to be securely destroyed or permanently de-identified.
You may make a request to access or correct any personal information we hold about you. To make such a request, please contact us using the details set out below in section 13. We may need to verify your identity before meeting your request. Please provide as much detail as you can about the particular information you seek or require correction of, in order to help us locate it.
We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information, and you disagree, you may ask us to make a note of your requested correction with the information.
This section applies in addition to the other sections of this policy where you apply for or obtain credit from us or apply to or guarantee or provide security in relation to credit provided to any other person or entity.
We may collect, hold, use and disclose certain credit-related personal information about you, including:
This information may include information about your arrangements with other credit providers as well as with us. We may disclose some of these types of information to CRBs. CRBs may use credit-related personal information to maintain records on individuals which they may share with other credit providers for those providers’ own credit assessments.
If you fail to meet your payment obligations in relation to consumer credit or commit a serious credit infringement we may be entitled to disclose this to a CRB.
The CRBs we may use from time to time include CreditorWatch.
You may contact those CRBs or visit their websites to see their policies on the management of credit-related personal information, including details of how to access your credit-related personal information they hold.
In the event that any part of our business or its assets is ever sold, acquired, merged, liquidated, reorganised or otherwise transferred, we reserve the right to transfer to the extent permissible at law our databases, together with any personal information and non-personal information contained therein to a third party acquiring the assets. While any transaction of this sort is being considered, we may also make limited relevant personal information available to prospective purchasers and legal and financial advisors and other relevant parties on a confidential basis.
By communicating, investing or dealing with Wingate, including by submitting information to us via email, through our website, registry or portal, you consent to the information you provide being collected, stored, used and disclosed by us in accordance with this policy. You can withdraw your consent at any time however we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
From time to time we may make changes to this policy. Such changes will be posted on this website and we will publish the effective date when the policy is updated.
Last update: October 2022
If you have any questions, concerns or feedback about privacy, or to make a request to access or correct your personal information or to opt-out of direct marketing, please contact our Privacy Officer as set out below:
Attention: Wingate Privacy Officer
Address: Level 48, 101 Collins Street, Melbourne VIC 3000
Phone: +61 3 9913 0700
We take your privacy concerns seriously. Where you express any concerns that we may have interfered with your privacy or conducted ourselves inconsistently with this policy, we will respond to let you know who will be handling your matter and when you can expect a further response. We aim to resolve your concerns in a fair and efficient manner within 30 days.
If your concerns are not resolved to your satisfaction, you may complain to the Office of the Australian Information Commissioner in writing as set out below:
Address: GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992
Fax: +61 2 9284 9666