Privacy Policy

This Privacy Policy was last updated on 30 June 2022

This Privacy Policy describes how Circular Now (Australia) Pty Ltd (ACN 657 630 094) and its subsidiaries and related group entities (together “us”, “our” or “we”) collects, holds, uses and discloses the personal and credit-related personal information of our customers (“user”, “users”, “you” or “your”) in connection with our services (“Services”), in accordance with the Australian Privacy Act 1988 (Cth) (the “PrivacyAct”)) and the Australian Privacy Principles (the “APPs”).

It is your responsibility to ensure that you understand this Privacy Policy. By using our Services, you agree to the terms of this Privacy Policy. If, at any time, you do not agree with any of this Privacy Policy, you must stop using our Services. By using our Services, you will be deemed to have understood and accepted this Privacy Policy.

The latest version of our Privacy Policy will be published on our Website. We recommend that you check the Website from time to time to access our most up to date Privacy Policy. If we decide to make a significant change to our Privacy Policy, we will notify you by email.

A reference to our Website in this Privacy Policy means our website at https://nowcircular.com.au and any of our other websites or social media profiles.

WHAT KIND OF INFORMATION DO WE COLLECT?

Personal information

1. Personal information is defined in the Privacy Act as information about an identified individual or an individual who is reasonably identifiable.

2. The types of personal information that we collect will depend on your dealings with us. Personal information that we may collect when you use our Services include:

  • your contact details, including your first and last name, email address, mobile number, mailing or street address;

  • information about your nationality, gender, date of birth, marital status and employment;

  • your billing information, including your bank account and credit card details;

  • photographs and other audio-visual information; and

  • any additional information relating to you where you are identifiable that you provide to us directly in communications with us, including through feedback or surveys.

3. We do not intentionally collect any sensitive information, such as your tax file number, health information, criminal records and/or information about your sexuality, religious beliefs and/or political opinions. To the extent that we do actively collect any sensitive information, we will seek your prior express consent. 

Credit information

4. We may also collect credit information, including credit eligibility information, including:

  • identification information;

  • credit history;

  • credit liability information;

  • repayment history; and

  • default information.

Analytics information

5. When you use your device to visit our Website, we may collect information about your device, including the Internet Protocol (“IP”) address of the device that you use to access our Website.

6. We may use web analytics tools to record how you access and use our Website with your device by collecting information about the advertising ID or IP Address of your device, the date and time that your device accessed the Website, the pages that your device accessed, if your device accessed our Website from a link on another webpage, details of that referring web page, and “cookies” (as explained in section 8 (“Cookies”) below).

7. We collect and analyse this information so that we can tailor advertising to users that is relevant to their interests, understand how users interact with our website and so that we can improve users’ experience of our Website and the functionality of our Website.

Cookies

8. A cookie is a data file that our Website stores on your device. We use cookies to help remember information about your preferences and record information about how you interact with our Website so that we can improve your experience of using the Website, for example, by providing you with information relevant to your interests and remembering your preferences and settings.

9. You can adjust your browser settings so that your browser will not accept cookies, however, doing so may cause some or all the functionality of our Website to not operate as intended.

HOW DO WE COLLECT YOUR INFORMATION?

Directly from you

10. We may collect personal and credit information from you when you:

  • establish a user account;

  • use our Services;

  • undertake any monetary transactions with us in relation to our Services;

  • complete forms, interviews, surveys and/or questionnaires in connection with our provision of the Services;

  • correspond or communicate with us, for example, via telephone, email, and written enquiries directed to us;

  • interact with us on our social media, for example, Facebook, Twitter or Instagram;

  • use the Website to sign up to receive our newsletter and/or subscribe to our mailing list (if applicable); and/or

  • provide the information to us as part of your dealings with us.

Indirectly from our third-party service providers

11. We may collect your personal and credit information from our third-party service providers, including credit reporting bodies, and marketing service providers. These service providers may share information, including your personal and credit information with us in connection with our delivery of the Services and/or for marketing and promotional purposes.

12. We will generally require that these service providers have informed you that your personal and credit information may be provided to us and that any personal and credit information they provide to us has been processed in accordance with applicable law. For information on how our service providers handle your personal and credit information please check their privacy policies.

WHY DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR INFORMATION?

Personal information

13. We collect, hold, use and disclose your personal information for various purposes associated with providing the Services to you and also in connection with our business, including so that we can:

  • perform our obligations in the course of, or in connection with, providing the Services to you;

  • process and respond to queries, requests, complaints and feedback from you;

  • manage our relationship with you;

  • process payment transactions;

  • verify your identity;

  • inform you about our business and Services;

  • send you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions; manage your subscription to our mailing lists;

  • for security purposes;

  • communicate with you and with the relevant authorities in the event that your personal information has been subject to a data breach;

  • comply with other obligations including our legal, tax and accounting obligations; and

  • transmit your personal information to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, for the aforementioned purposes.

Credit information

14. We collect, hold, use and disclose your credit information for the purpose of undertaking a credit check in relation to a Rental Request (as defined in the Terms of Use) made by you.

WILL YOUR INFORMATION BE DISCLOSED TO A THIRD PARTY?

General

15. Generally, we will only disclose your personal and credit information in connection with providing our Services.

16. We may provide your personal information to third-party service providers including, information technology (IT) service providers and marketing service providers, who we have engaged to facilitate the provision of the Services or to perform any of the matters referred to in section 13 above (“Why we collect, hold, use and disclose your information”). We will only disclose your information where such disclosure is required for the delivery of the services by the third-party service provider.

17. If we are legally permitted or required to, we may also disclose your personal information in order to comply with our legal obligations or to protect or enforce our rights.

18. We do not control and are not responsible for any other websites or services, including the information or content contained within them, that are accessible via hyperlinks from our Website. Our Privacy Policy does not apply to third-party websites or services and your use of any third-party website or service is governed by the privacy policy and terms of use for that website or service. If you communicate with us via a social media platform, for example, Facebook, then the terms and privacy policy for the social media platform will also apply.

19. We may also disclose non-personal, de-identified and aggregated information (i.e. information that is not personal information) to third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

Credit Reporting Bodies

20. We may provide your credit information to credit reporting bodies listed below whom we have engaged to perform any of the matters referred to in section 14 above (“Why we collect, hold, use and disclose your information”):

Experian Australia Pty Ltd.
Phone: 1300 783 684
Postal: 101 Miller Street, North Sydney, NSW, 2060
Website: www.experian.com.au

21. The credit reporting body listed in section 20 may include any of your personal or credit information, disclosed to it by us, in reports provided to other credit providers to assist them in assessing your creditworthiness.

22. You have the right to make a request to the above credit reporting body not to use or disclose your credit reporting information:

  • for the purposes of pre-screening of direct marketing by a credit provider; or

  • if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.

23. If you would like more information about how the above credit reporting body manages credit related information, you can contact them directly and request a copy of their privacy policy.

HOW LONG DO WE HOLD ON TO YOUR PERSONAL INFORMATION?

24. We will hold copies of your personal information, for as long as we need your personal information in order to provide the Services to you and to undertake any other activities described in sections 13 and 14 above (“Why we collect, hold, use and disclose your information”) of this Privacy Policy. We will also retain a copy of your personal information in connection with administering our business and in order to fulfil our legal obligations.

OVERSEAS DISCLOSURES

25. We may disclose your personal information to entities outside of Australia when we provide the Services to you, including to business partners, IT service providers and data storage providers. We take reasonable steps to ensure that overseas entities that receive your personal and credit information handle your information in accordance with the Privacy Act including the APPs and other relevant privacy laws.

MARKETING COMMUNICATIONS

26. From time to time, we may contact you by email or other means (“marketing communications”) with information and news about our business that we believe may be of interest to you. If you do not wish to receive these marketing communications, you can follow the instructions in these marketing communications to opt out of receiving these marketing communications from us. You can also contact us using the details in section 44 below (“Contact us") to let us know that you wish to opt out of these marketing communications.

27. If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, in error, or in breach of any law, or if you suspect that your personal information that we hold has been subject to a data breach, then please contact us immediately using the details in section 44 below (“Contact us").

CAN I WITHDRAW MY CONSENT?

28. You may withdraw consent to our use and disclosure of your information for any or all of the purposes listed in this Privacy Policy by submitting a request in writing to the email set out in section 44 below (“Contact us").

29. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us agreeing to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

30. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing the Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in section 28 above.

31. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose information where such collection, use and disclose without consent is permitted or required under applicable laws.

HOW DO WE PROTECT YOUR INFORMATION?

32. To safeguard your information from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal and credit information by us, and disclosing personal and credit information both internally and to our authorised third-party service providers and agents only on a need-to-know basis.

33. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

HOW CAN YOU ACCESS AND UPDATE YOUR INFORMATION?

34. Without limiting any other rights you may have at law and/or under this Privacy Policy, you can contact us using the details in section 44 (“Contact us") to request:

  • access to the personal or credit information that we hold about you; and

  • if the personal or credit information that we hold about you is incorrect or incomplete, that we update the personal or credit information that we hold about you.

35. We will endeavour to respond to your request as soon as possible and within thirty (30) days of receipt of your request.

36. If we need more time to respond to your request, we will notify you of the time by which we will be able to respond to your request within thirty (30) days of receipt of your request.

37. We will, on request, provide you with access to your personal or credit information or update or correct your personal or credit information, unless we are lawfully excluded from granting your request, including if:

  • giving access would be unlawful;

  • we are required or authorised by law or a court/tribunal order to deny access; or

  • giving access is likely to prejudice one or more enforcement-related activities conducted by an enforcement body.

38. If we refuse to give you access to, or correct, the personal or credit information, we will inform you of the reasons why we are unable to do so within thirty (30) days of receipt of your request.

39. Please note that we may charge a reasonable fee for responding to request for access or correction, in which case we will inform you of the fee before processing your request.

HOW TO MAKE A COMPLAINT

40. If you wish to complain about how we have handled your personal and/or credit information, please submit your complaint in writing using the contact information in section 44 below (“Contact us”).

41. We will respond to your complaint as soon as reasonably possible and will endeavour to respond to you within thirty (30) days of receipt of your written complaint.

42. You must provide all reasonable assistance to us to allow us to address your enquiry or complaint, including providing us with all appropriate and relevant information and feedback on our written request.

43. If you are not satisfied with how we have handled your complaint, you may lodge a complaint with the Office of the Australian Information Commissioner using the details below:

Office of the Australian Information Commissioner
Phone: 1300 363 992
Postal: GPO Box 5218, Sydney, NSW 2001
Website: https://www.oaic.gov.au/about-us/contact-us/

CONTACT US

Requests and complaints

44. If you wish to opt-out of our marketing communications, withdraw your consent, access or update the information we hold about you, make a request relating to your personal information, or make a complaint about how we have handled your personal and/or credit information please contact us by phone or email using the following details:

Phone: (02) 5632 9299
Email: escalations@nowcircular.com

General enquiries and feedback

45. If you have any questions or feedback about this Privacy Policy or any of the practices described therein, please contact us by email at help_au@nowcircular.com.