Website and Credit Reporting Policy
Version 2 Effective 16 May 2025
GAP Business Loans provides a simple process to access Business Loans for SME’s. Whatever your business needs are, GAP Business Loans is here to assist you to make sure that the loan process is quick and simple.
Who are we?
‘We’, ’us’ and ‘our’ refer to GAP Business Loans Custodians Pty Limited ACN 643 966 349, GAP Loans Australia Custodians Pty Ltd ACN 616 474 705, and GAP Business Management Pty Ltd ACN 683 003 205.
Our commitment to protect your privacy
We are committed to protecting your privacy and understand how important it is to protect your personal information. This document sets out how we may collect, use and manage your personal information (including credit-related information) and our commitment in respect of such information, in line with our obligations under the Privacy Act 1988 (Cth) (‘Privacy Act’), the Australian Privacy Principles (‘APPs’) and the Privacy (Credit Reporting) Code 2014 (‘Credit Reporting Code’). Any personal information we collect about you will only be used for the purposes we have collected it for, as reasonably necessary for one or more of our functions, operations or activities or otherwise as required or allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Personal information
When we refer to personal information, we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you.
Why we collect your personal information
We collect personal information for the purposes of assessing your application for finance, managing that finance, establishing your identity, contacting
you, managing our risk and to comply with our legal obligations. We may also collect your personal information for the purposes of direct marketing
and managing our relationship with you.
How do we collect your personal information?
General
We may collect your personal information directly from you or via your use of our services, including our website. We may also collect information about you that is publicly available, for example from public registers or social media, or made available by third parties, including personal information from credit reporting bodies, mortgage and finance brokers, employers and other people such as accountants and lawyers.
We will only collect personal information which is reasonably necessary for, or directly related to, our functions or activities. The types of information we might collect from you and use in accordance with this policy include:
(a) contact information, such as your name, address, telephone number(s) and email address(es);
(b) financial information, including bank account details;
(c) business details, including your tax file number and Australian Business Number;
(d) identification information, such as your date of birth, current or previous addresses and driver’s licence or passport number; and
(e) your IP address, being the identifier for your computer when you are using the internet, to formulate your interaction with various parts of our website.
We will not ask you to supply personal information publicly over Facebook, Twitter, or any other social media platform that we use.
Cookies
We may also collect personal information through ‘cookies’ on our website. We use cookies to provide you with better and more customised services and with a more effective website. A cookie is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our web page server. Cookies are frequently used on websites, and you can choose if, and how, a cookie will be accepted by configuring your preferences and options in your internet browser.
We use cookies for different purposes, such as:
(a) to allocate a unique number to your internet browser(s);
(b) to customise our website for you;
(c) for statistical purposes;
(d) to identify if you have accessed a Third Party website; and
(e) for security purposes.
Online applications
We use the information within your completed online application to us to provide any financial services that you may require.
You can suspend and save online applications, so you can complete and send the applications at a later time. If you suspend or save your application, the information that you have entered will be retained in our systems so that you may recover the information when you resume your application. Online applications that have been suspended or saved may be viewed by us.
Do we disclose your personal information?
We may disclose your personal information to third parties to assist us with the primary purpose for which your information was collected:
» to prospective funders or other intermediaries in relation to your finance requirements;
» to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres, lenders, mortgage insurers, trade insurers and credit reporting bodies;
» to related bodies corporate or associated businesses that may want to market products to you;
» to companies that provide information and infrastructure systems to us;
» to our agents, contractors, external service providers to outsource certain functions, for example, statement production, debt recovery and information technology support;
» to anybody who represents you, such as finance brokers, lawyers, mortgage brokers, guardians, » persons holding power of attorney and accountants;
» to anyone, where you have provided us consent;
» to other guarantors or borrowers (if more than one);
» to borrowers or prospective borrowers including in relation to any credit you guarantee or propose to guarantee
» to our auditors, insurers, re-insurers and health care providers;
» to claims related providers, such as assessors and investigators who help us with claims;
» where we are authorised or required to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), government and law enforcement agencies or regulators;
» to investors, agents or advisers, trustees, rating agencies or any entity that has an interest in your finance or our business;
» to other financial institutions, for example to process a claim for mistaken payment;
» organisations that provide products or services used or marketed by us;
or
» to your employer, former employer, referees or identity verification services.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
(b) you have consented to us making the disclosure.
Disclosure to overseas entities
We do not generally disclose personal information obtained from cookies to overseas entities in the course of our activities.
Third Party Websites
Our website may contain links to the websites of third party providers of goods and services (Third Party websites). If you have accessed Third Party websites through our website, and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.
Where you access a Third Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
When you view our advertisements on a Third Party website, the advertising company may use ‘cookies’ and in some cases ‘web beacons’ to collect information such as:
(a) The server your computer is logged onto;
(b) Your browser type;
(c) The date and time of your visit; and
(d) The performance of their marketing efforts.
When you access our website after viewing one of our advertisements on a Third Party website, the advertising company collects information on how you utilise our website (e.g. which pages you view) and whether you complete an online application.
This policy does not govern Third Party websites. For information on how such websites collect, use and store your personal information, refer to the privacy policy of each Third Party website.
Direct Marketing
From time to time, we may use your information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated. We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.
If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on 1800 99 22 75 or by writing to us at [email protected]. If the direct marketing is by email, you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Sensitive information
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health information.
We will not ask you to disclose sensitive information, but if you elect to provide sensitive information, it will also be captured and stored.
Retention and security of your personal information
The security of your information is very important to us. We will take a range of measures and reasonable steps to protect your personal information. We may retain your personal information for as long as is needed for the purposes outlined in this policy, or as required by law. We will take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
We may store your personal information in paper and electronic form. Your information may be stored on our electronic data base system and on computers with appropriate back up and security systems. All our servers are located in Australia.
Any personal or credit information which is collected via our website, or which is held on our computer systems, is protected by safeguards including physical, technical (including firewalls and SSL encryption) and procedural methods.
We take reasonable steps to hold information securely in electronic form. We are committed to keeping secure the data you provide to us and we will take all reasonable precautions to protect your personally identifiable information from loss, misuse, interference, unauthorized access, alteration or disclosure.
If we no longer require your information, and we are legally permitted to, we will take all reasonable steps to destroy or de-identify the information.
We take reasonable steps to preserve the security of cookie and personal information in accordance with this policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).
In the event of a data breach, we are committed to complying with our obligations at law, including our notification obligations (see below).
Online Applications
When you send a completed online application to us, we retain the information contained in that application.
Credit-related information
The information we hold about you may also include credit-related information.
Credit-related information means both:
» Credit information, which is information which includes your identity, the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information, default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information.
We exchange credit-related information for the purposes of assessing your application for finance and managing that finance. If you propose to be a guarantor, one of our checks may involve obtaining a credit report about you.
This credit-related information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit-related information we hold about you.; and
» Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body and any information that we derive from it. We use you credit-related information to assess your eligibility to be provided with finance. Usually, credit-related information is exchanged between credit and finance providers and credit reporting bodies.
The kinds of personal information we may collect about you includes your name, date of birth, address, account details, occupation, and any other information we may need to identify you. When we obtain credit eligibility information from a credit reporting body about you, we may also seek publicly available information about any serious credit infringement you may have committed.
When you use our website or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you have accessed third party sites, the date and the time of visits, the pages that are viewed, information about the device used and other user location information. We collect some of this information using cookies.
If you are applying for finance or provide a guarantee we may also collect the ages and number of your dependents and cohabitants, the length of time you have resided at your current address, your employment details and proof of earnings and expenses.
Business without identifying you
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
Notifiable matters
The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit-related information. You may request to have these notifiable matters (and this policy) provided to you in an alternative form.
We exchange your credit-related information with credit reporting bodies. We use the credit-related information that we exchange with the credit reporting body to confirm your identity, assess your creditworthiness, assess your application for finance or your capacity to be a guarantor and manage your finance.
The information we can exchange includes your identification details, what type of loans you have, how much you have borrowed, whether or not you have met your loan payment obligations and if you have committed a serious credit infringement (such as fraud).
If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement then we may disclose this information to a credit reporting body.
You have the right to request access to the credit-related information that we hold about you and make a request for us to correct that credit-related information if needed. Please see the heading ‘Access and correction to your personal and credit-related information’, below.
Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting body at any time to request that your credit information is not used in this way.
You may contact the credit reporting body to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the credit reporting body receives your notification the credit reporting body must not use or disclose that credit information. You can contact any of the following credit reporting bodies for more information:
» Equifax Pty Ltd
www.equifax.com.au,
» Dun & Bradstreet (Australia) Pty Ltd
www.dnb.com.au, or
» Experian Australia Credit Services Pty Ltd
www.experian.com.au.
Access and correction to your personal and credit information
We will provide you with access to the person and credit-related information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we will respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal or credit-related information. For example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious or if the information is commercially sensitive.
An explanation will be provided to you, if we deny you access to the personal or credit-related information we hold about you.
If any of the personal or credit-related information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information by telephoning us on 1800 99 22 75 or by writing to us at [email protected].
If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit-related information within thirty days.
We may need to consult with other finance providers or credit reporting bodies or entities as part of our investigation.
If we refuse to correct personal or credit-related information we will provide you with our reasons for not correcting the information.
Complaints
If you are dissatisfied with how we have dealt with your information, or you have a complaint about our compliance with the Privacy Act and the Credit Reporting Code, you may contact our complaints officer on 1800 99 22 75 or submit a written complaint which can be emailed or posted to use using the contact details set out below. You must include contact details for us to contact you regarding your complaint.
We will acknowledge your complaint within thirty days and aim to resolve the complaint as quickly as possible. We will provide you with a response to your complaint as soon as reasonably possible, but no later than thirty days from receiving the complaint.
If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992. If you are an individual residing in the EU, you may submit your complaint to your local data protection authority.
Change in our privacy and credit reporting policy
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and marketplace practices.
We may change this policy from time to time and publish changes to it on our website ‘https://gapbusinessloans.com.au/website-credit-policy’. We encourage you to check our website periodically to ensure that you are aware of our current website policy. You may also request a copy of our most up-to-date policy by contacting our complaints officer (see details below).
Further information
If you wish to:
• gain access to your personal information;
• exercise any of the rights described in this website policy;
• make a complaint about a breach of this website policy or our obligations at law;
• contact us with a query about how your information is collected or used;
• contact us regarding any other matter concerning this website policy.
Contact our Complaints Officer:
• Email: [email protected]
• Postal address: PO Box R599 Royal Exchange NSW 1225
• Phone: 1800 99 22 75