Privacy Policy
The policy describes:

• How Navalo Financial Services Group Limited trading as “Navalo” (ABN 24 605 753 535) and its related bodies corporate will collect, hold and use your personal information
• How this personal information will be used and disclosed to third parties including, Navalo’s service providers, related entities and credit agencies
• How you can access or update personal information with Navalo, and
• If required, how you can make a complaint or enquiry relating to the use of your personal information, in connection with your application with Navalo.

The personal information we collect is treated in accordance with the Privacy Act 1988 and the Australian Privacy Principles. You can request access to the information held about you and obtain a copy of this Privacy Policy by calling Navalo on 1300 338 496.

What personal information does Navalo collect and hold?

We collect personal information from you in connection with your application with Navalo. This information may include:

• Your full name, residential address, contact phone numbers, date of birth, email or other identification or verification information (electronic or otherwise);
• Financial information such as credit or debit card and personal banking details, financial position, bank statement information and credit information
• Employment details such as employer name, address, contact number and employment status, and
• Additional information such as details from your Drivers’ Licence, Passport, Medicare Card, Pensioner Concession Card, or other government identifiers necessary to identify you and support your application.
• Your credit information including information relating to credit history, credit score and credit eligibility.
• Transactional information including information about how you use your account with us and how you manage your repayments.
• Information we collect when you visit or use our website – see ‘How does Navalo use Cookies?’
• Other information we collect during the course of our customer relationship including any inquiry or complaints made by you or on your behalf.

You may choose to make an inquiry with us on an anonymous basis or using a pseudonym however in order to make an application with us or to interact with us in relation to your application or your account with us we are required by law to be able to identify you.

Wherever possible, Navalo will collect information from you directly such as when you complete an application with us or when you contact us to discuss an application or your Navalo account, make an application to become a shareholder of Navalo Financial Services Group Limited or make any changes to your shareholder or customer records, or when you visit and use our website. Navalo may also collect information about you from our merchants who collect information on your behalf in connection with your application for a Navalo loan. Navalo may also collect information from publicly available sources (such as public registers) or from third parties, for example from third parties (such as credit reporting bodies) who provide us with additional data insights to allow us to more effectively manage your account with us and/or collect on an overdue debt if our standard debt collection activities are unsuccessful.

If we obtain information from third parties we will take all reasonable steps to:

• Keep you informed that we have collected the information
• Ensure that you understand the purposes for which the information is collected, and
• Ensure that you understand how that information may be disclosed to third parties by Navalo.

In addition to the above, we may collect information in accordance with the Anti Money Laundering and Counter Terrorism Financing Act 2006.

How does Navalo use your personal information?

Navalo collects and holds information for the purposes of:

• Assessing your application and creditworthiness for a Navalo loan
• Allowing us to contact you about your incomplete or partially completed application
• Managing your accounts with Navalo such as sending you notices, statements or processing transactions or any debt collection activities where necessary
• If required, selling your debt to third parties where our standard collection processes have been unsuccessful
• Assigning your debt to third parties for financing purposes in the ordinary course of business where we remain responsible for debt collection
• Enabling proper records to be held about you as a shareholder of Navalo Financial Services Group Limited and for reporting purposes
• Direct Marketing, including promoting Navalo products and services to you and promoting products and services of our merchants. You may opt out of receiving direct marketing at any time by contacting Navalo at 42 Cambridge Street, Collingwood 3066, care@payright.com.au or 1300 338 496
• Customer support including responding to any enquiries or complaints you make to us
• Complying with all applicable laws, including the Anti-Money Laundering and Counter Terrorist Financing Act 2006 (AML Act)

In addition, Navalo may combine the information it holds about you with information we collect from, or which is held by, external sources. We may use this combined information for the purpose of developing meaningful customer insights about you so that we can serve you better. This includes better understanding your preferences and what products or services, including products and services of our merchants, may be of interest to you. We may also combine your data with data held by third parties such as credit reporting bodies to gain insights about you in order to conduct more meaningful debt collection activities. For example, we may share your information with a credit reporting body, who may combine the data we have shared with them about you with additional information it holds about you, such as updated contact information, financial or bankruptcy information. These combined data sets will be used by Navalo to refine and inform our debt collection activities including whether we decide to sell your debt to a third party where standard collections practices have been unsuccessful. If we do decide to sell your debt to a third-party debt collector we will share this combined data set with them to assist them in their efforts to collect any unpaid debt from you. We may also aggregate and deidentify these combined data sets so that they do not contain any information that identifies you and may share this aggregated and deidentified data with third parties who will use this information for purpose of identifying these insights on our behalf.

You have a choice whether or not to supply us with the information we request (including information that we require under the AML Act), however if we do not receive all information that we require in connection with your application we may not be able to process your application or make available to you any Navalo products or services.

How does Navalo use Cookies?

Navalo uses cookies on its websites to provide you with a better and more user-friendly website experience.

Cookies are small files that are placed on your device by websites which collect information about your use of those websites. Different types of cookies are used for different purposes. There are cookies that are active for a single session, for example those which are used to help you to complete your Navalo application and persistent cookies which are stored on your device and help websites such as Navalo remember your information and settings when you visit them in the future.

Navalo uses cookies for various purposes which may include:

• to allocate an identification number to your Internet browser (you cannot be identified from this number);
• determining if your browser has previously visited our website and remembering your settings/preferences;
• tracking and reporting on website usage;
• identifying other pages or third parties’ websites your browser has accessed;
• personalising your experience, including your access to services that we provide on our websites. For example, providing customised content, support and advertising that may be relevant to your interests and needs;
• providing enhanced security and fraud detection.

You can choose to change your browser’s cookie settings via your browser privacy settings, including blocking the use of cookies. If you choose to delete or block cookies, your experience on Navalo’s website may be limited.

What credit information does Navalo collect and hold and how is it used?

When you apply for a product with us, we may collect credit information about you and disclose this credit information to credit reporting bodies. We may also collect credit information about you directly from credit reporting bodies. This exchange of information is used by Navalo in assessing your application for credit with us and is often called a ‘credit check’. When we perform a credit check we will obtain your consent. Performing a credit check will often create a record in your credit file and will be visible to other lenders who may consider this record should you apply to them for consumer credit. We will also exchange credit information about you to credit reporting bodies in connection with managing your account, including in circumstances where your repayments to us are overdue. This information will also create a record on your credit file and may be considered by other lenders. This credit information includes:

• Your identity information;
• Information about your application for credit;
• Default information where your repayments to us are overdue; and
• Serious credit infringement information if we reasonably believe a fraud has been committed relating to your credit or where your account is overdue and we cannot contact or locate you

The credit reporting bodies we may use are illion Pty Ltd and Equifax Pty Ltd, whose privacy policy and contact details are set out at www.illion.com.au and www.equifax.com.au.

We may also share your credit information with credit reporting bodies so that they can combine the data we hold about you with additional information they may hold about you, such as updated contact information, financial or bankruptcy information. These combined data sets may then be shared back with us by the credit reporting body for debt collection purposes including in assisting us decide whether to sell your debt to a third-party debt collector where our standard debt collection activities have been unsuccessful.

Credit reporting bodies s may use credit information they hold about you to respond to requests from us or other credit providers to pre-screen you for direct marketing. You are entitled to opt out of such pre screenings by contacting the credit reporting body directly.

How does Navalo protect your personal information?

Personal information is held in paper (hard copy) or electronic format on our systems and may be stored physically or electronically with third party data storage providers in Australia and elsewhere.

Your personal information is protected by physical, electronic, contractual and policy safeguards. Where we share your information with third parties we require that those third parties abide by privacy laws and security requirements.

All Navalo staff are required to complete procedural training on handling personal information.

Navalo will only retain your personal information for as long as it is necessary to satisfy any of the purposes for which it was obtained or to otherwise comply with law.

How does Navalo share your personal information?

We may share and disclose information about you to third parties as required to achieve the purpose for which it was collected by our business or as required or permitted by law. We may disclose your personal information to:

• merchants with whom we partner and from whom you purchase goods and services using a Navalo loan. The information we share will not include your financial or credit information but may include information about a complaint you have raised with us about your Navalo account or your purchase or service from the merchant;
• our advisors and corporate partners, contractors or developers (such as contact centres, software developers or mailing houses) who assist us in providing, managing or administering your Navalo product or service (including promotions) or who maintain and develop our business systems, procedures and technology infrastructure;
• Navalo’s share registry if you are a shareholder of Navalo Financial Services Group Limited and any third parties we engage to provide investor relations or corporate advisory services;
• credit reporting bodies (see section on credit information);
• our related entities and their officers and employees;
• debt collection agencies and third parties to whom we may sell your debt where our standard collections activity has been unsuccessful;
• fraud reporting agencies including organisations that assist with fraud investigation, prevention and detection;
• third party assignees or potential assignees for the purpose of securing debt finance so that we can lend to you;
• third parties for the purpose of verifying the information that you have provided (eg to confirm your employment details including salary or wages);
• other third parties, where such disclosure is required, authorized or compelled by law such as government and regulatory bodies like ASIC or AUSTRAC to the extent required by law; and
• other third parties where you have given your consent or at your request.

Due to the nature of cloud based service providers it is not always possible to know where the network storage systems are located. Some third parties with which we share your information as described in this privacy policy may not be located in Australia, for example email services where the data may reside in a third party data centre off shore. We may also store your information in the cloud or other types of network storage systems which can be accessed from countries outside Australia via the internet.

How you can access or update personal information with Navalo

In order to access your personal information please contact Navalo’s Privacy Officer on care@payright.com.au. We will make every effort to provide you with your personal information unless otherwise required by law.

Requests for personal information can only be made by the individual for whom the information relates to. We will make every effort to identify that you are the correct individual.

Please note that we are entitled to refuse you access to your information under Australian law in circumstances including where:

• Access would be unlawful;
• Denying access is required or authorised by or under an Australian law or a court/tribunal order; or
• Access would prejudice enforcement activities or the taking of appropriate action in relation to unlawful activity or serious misconduct.

If correction of your personal information is required please contact the Navalo Privacy Officer at care@payright.com.au.

We will make every practicable effort to ensure the personal information we hold is accurate and up to date.

How you can make a complaint or enquiry relating to the use of your personal information

We are committed to adhering to the Australian Privacy Principles. Should you have an enquiry or wish to make a complaint about how we have accessed, used or disclosed your personal information, you are welcome to contact our Privacy Officer:

Navalo Privacy Officer
Navalo Financial Services Group Limited
Mail: 42 Cambridge Street, Collingwood, 3066
Email: care@payright.com.au
Phone: 1300 338 496

We will make every practicable effort to respond to your enquiry within 7 days of receiving the enquiry or complaint. Further to this, we will endeavor to provide a successful resolution to all privacy related complaints within 21 days of our initial response. Should this not be possible, or unlawful to do so, we will contact you to advise you of the required resolution time. If you are not happy with the resolution of your complaint, you may take your complaint to:

Australian Financial Complaints Authority
Phone: 1800 931 678
Email: info@afca.org.au
Website: www.afca.org.au
Ordinary Mail:
Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001

Office of the Australian Information Commissioner
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au/privacy

Changes to this Privacy Policy

This policy may change from time to time. Please visit our website regularly as we will post a notification on our website if we make any changes to this policy. We may also communicate with you during our customer relationship to tell you more about how we handle your information, such as if you make a new application for credit or access our product in a different way or channel. Please review these communications carefully.

Version 3.6 (Updated October 2023)