Use and Disclosure of Information

Personal Information

How we collect and hold personal information

We aim to collect personal information only directly from you, unless it is unreasonable or impracticable for us to do so.  For example, we collect personal information from you or about you from correspondence that you submit to us, meetings and interviews with us, telephone calls with us, the investment and / or borrowing instructions you provide to us, the completed application forms, identification check forms and other contractual documentation you submit to us, and from your activity on our website.

However, in some instances we may receive personal information about you from third parties, such as credit reporting bodies, your credit referees, Government agencies, associated businesses and referrers (such as law firms, accountants, financial planners and your business advisory consultants etc).  We may also receive personal information about you from your family members, authorised third parties and publicly available sources.

You can be anonymous or use a pseudonym when dealing with us, unless:

  • the use of your true identity is a legal requirement; or
  • it is impracticable for us to deal with you on such basis.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities, which are detailed generally in the RMBL Product Disclosure Statement and Supplementary Product Disclosure Statement, and more specifically in the application forms completed by you. For example, we collect, hold, use and disclose personal information as necessary to consider and process your application to invest in, or borrow under, our product and service offerings.

We will disclose personal information about you to credit reporting bodies for purposes related to assessing your credit worthiness, and reporting on payment defaults.

In relation to Borrowers, we may also disclose your personal information to third parties such as the Australian Securities and Investment Commission, and to Members in our investment schemes, for the purposes of assisting the potential Member to make a decision as to whether to invest their funds into a sub-scheme. Such information that would be disclosed would include your name, property information, the reason / purpose for borrowing funds, certain financial information relevant to your ability to service the loan and funding requirements for development projects (if applicable), source of income, credit worthiness, documents required to be entered into as security for the loan, and ability to complete a construction project if applicable and previous experience or projects undertaken.

We may collect sensitive information from you or about you where there is a legal requirement to do so, or where we are otherwise permitted by law.  In all other situations, we will specifically seek your consent.  

We also collect, hold, use and disclose your personal information for purposes related to our investment and borrowing facilities that you would reasonably expect, such as internal and regulatory audit investigations, performance reporting, investment planning, our own internal administrative and accounting functions, our obligations under professional and compliance schemes, data backups, marketing and promotions, ongoing newsletter communications, providing you with details about investment changes, educational briefings and other service offering updates, conducting client satisfaction surveys and feedback requests, statistical collation and website traffic analysis.

Where we use your personal information for marketing and newsletter communications, you can opt out at any time by notifying us.  Opt out procedures are also included in our communications.

We may also disclose your personal information to third parties (including Government departments such as the Australian Taxation Office and enforcement bodies) where required or permitted by law.

Where we wish to use or disclose your personal information for other purposes, we will obtain your consent.

If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to answer your enquiry, process your application to invest or borrow funds, or provide the services that you or your organisation have contracted us to provide.

Credit Information

How we collect and hold credit information and credit eligibility information

We will collect credit information directly from you from your correspondence with us, and from completed application forms, identification check forms and contracts that you submit to us. 

We will also collect credit information about you from specific requests that we make to credit reporting bodies.  In some instances, we may receive credit information about you from other credit providers with whom you deal and from the credit referees you have nominated.

Credit eligibility information will be disclosed to us by credit reporting bodies in response to our request. 

Why we collect, hold, use and disclose credit information and credit eligibility information

If you are a borrower or potential borrower of RMBL funds, we collect, hold, use and disclose credit information and credit eligibility information about you for the purposes of assessing your loan application, and for collecting overdue payments. 

We may also disclose the credit information and credit eligibility information of borrowers to third parties such as the Australian Securities and Investment Commission, and to members in our investment schemes, for the purposes of assisting the potential member to make a decision as to whether to invest their funds into a sub-scheme. Such information that would be disclosed would include your name, property information, your reason / purpose for borrowing funds, certain financial information relevant to your ability to service the loan and funding requirements for development projects (if applicable), source of income, credit worthiness, documents required to be entered into as security for the loan, and ability to complete a construction project if applicable and previous experience or projects undertaken.

If you are a guarantor or proposed guarantor for someone else’s borrowings, we collect, hold, use and disclose credit information and credit eligibility information about you for the purpose of assessing your suitability as a guarantor, and (if necessary) for enforcing the guarantee and collecting payments owed to us. 

We will disclose credit information about you to credit reporting bodies for purposes related to assessing your credit worthiness, and reporting on payment defaults. 

For borrowers and guarantors, we may disclose credit eligibility information to other credit providers and to guarantors, where we have obtained your consent.                                                           

We may also disclose credit eligibility information to third parties (including debt collectors, Government departments and enforcement bodies) where required or permitted by law.

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