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This Privacy Statement applies to Global Path Holdings ACN 642 219 047 Pty Ltd, trading as ‘Global Path’, and all its related entities, of Level 33, 264 George Street, Sydney 2000 NSW, Australia (“Global Path” or “we” or “our”, as relevant).
Who we are and what this statement is about?
Global Path is a specialist commercial financial services provider and global commodities wholesaler. This statement describes how we will handle your personal information.
In the process of providing services, Global Path may collect, receive, deal with and store personal information. Global Path is committed to collecting, using, disclosing and storing personal information only in a manner which is compliant with the Privacy Act 1988 (Cth) (“Privacy Act”).
What information does this statement apply to?
This statement only applies to “Personal information” and “Credit Information”.
Personal Information
“Personal Information” is any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in material form or not.
Whether an individual is ‘reasonably identifiable’ will depend on what other information is held or collected by Global Path or whether it is possible to identify the individual using available resources (including other information available to Global Path). This means that if Global Path collects information that by itself is not personal information (e.g. credit data associated with a customer number) but then also hold personal information that could be connected to that information (e.g. when Global Path has records of the customer names associated with each customer number), all of the information collected is personal information, as the customer number provides a reasonable link between the name of the individual and the credit data. Personal Information generally does not include information (or an opinion) that is about a business, company or trust.
Credit Information
“Credit Information” is Personal Information about an individual (other than sensitive information) that includes identification information, consumer credit liability information, repayment history information, a credit or commercial credit applied for, and the amount of credit, default information, payment information, new arrangement information, court proceedings information, personal insolvency information, publicly available information about individual’s credit worthiness or the opinion of a credit provider that the individual has committed a serious credit infringement in relation to consumer credit provided by the credit provider to the individual.
Credit Information includes:
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information that we obtain from credit reporting bodies;
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information that we derive from such information, for example, a credit score; and
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information that we may disclose to a credit reporting body in relation to an application made to us for credit by a customer, or prospective customer, who has nominated you as a guarantor. It can also cover information about you as a guarantor of a loan or as an insured party under a credit related insurance policy.
Our obligation in relation to information we collect as part of a commercial arrangement is governed by the confidential information undertaking in the commercial financial services arrangement.
We are also required to collect your Personal Information to comply with our obligations under Australian law, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
You do not have to disclose Personal Information or Credit Information to us. If you do not agree or do not provide some or all of the information requested, we may not be able to process or accept your application for credit, consider your application for employment, or otherwise provide you with goods and services.
Our collection of Personal Information
Global Path collects Personal Information as necessary for its business purposes, for example to process your application and give effect to your instructions.
We may collect your Personal Information directly from you or from a third party, such as a retailer who referred you to us.
The information we may collect includes, when permitted by law:
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identification information (such as your name and address);
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contact information (such as your telephone number and email address);
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age or date of birth;
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details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
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information to substantiate your financial capability, such as pay slips and information on assets you hold; and
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any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information.
In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history, qualifications and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.
Any information you provide to us when applying for a job or position may be shared within Global Path and its related entities, including but not limited to Garrison Lending Operations Pty Limited and Angle Auto Finance Pty Ltd, for recruitment purposes.
The Privacy Act contains certain exemptions in relation to certain acts undertaken in relation to employee records and related bodies corporate. Where appropriate we make use of relevant exemptions in the Act.
We endeavour to collect your information directly from you. However, in some circumstances we may collect your information from third parties, such as your employer or contracting organisations, a service provider or from a publicly available record.
Information we collect when you use our online services
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When visiting our website
We may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information may be used in an aggregated manner to analyse how people use our site, such that we can improve our service.
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Cookies
We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website.
Our website may from time to time use cookies to analyse website traffic and help us provide a better website visit or experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.
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Third party sites
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Global Path is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects Personal Information.
Our use and disclosure of Personal Information
Global Path uses and discloses Personal Information for the following purposes:
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the purpose for which the information was provided;
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to enable you to access and use our services;
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a purpose set out in this Privacy Statement or otherwise disclosed to you;
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a purpose required or permitted by law; and
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a purpose you authorised, including to give effect to your instructions.
Subject to the Privacy Act, in the process of providing you with the services, we may share Personal Information with our employees, related bodies corporate and with our third-party services providers. These third-party service providers may include agents, portfolio managers, mail house operators, collection agencies, research providers, dispute resolution schemes, accounting and legal advisers.
Global Path may also disclose information about you to third parties for the following purposes:
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to comply with the law;
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to obtain a credit report about you;
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to allow the credit reporting agency to create or maintain a credit information file containing information about you;
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to provide you with promotional information about financial services and products we may provide;
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to manage and administer the agreement with you;
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to protect our lawful interests;
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to give effect to your instructions; and
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if we negotiate with a third party regarding the possibility of an acquisition of part or the whole of our business.
Security of your Personal Information
Global Path maintains strict procedures and standards and takes all reasonable care to prevent unauthorised access to, and modification and disclosure of, your Personal Information. Global Path also takes all reasonable care to protect any Personal Information it holds against misuse or loss.
If we no longer need your Personal Information, we will take steps to either destroy the information or de-identify it.
Credit reporting
In addition to complying with its general obligations under the Privacy Act, Global Path is committed to collecting, using, storing and disclosing credit information in accordance with the CR Code and Part III A of the Privacy Act.
What kinds of credit information does Global Path collect or hold?
The information we may collect includes, when permitted by law:
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your name, date of birth, gender, residential address (and up to two previous addresses), the name of your current or last known employer, your driver’s licence, passport and Medicare numbers;
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credit reports;
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the fact that you have applied for credit, the type of credit and the amount;
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whether repayments on a loan we have granted you are more than 60 days overdue;
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the fact that any overdue payments are no longer overdue or a default is remedied;
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whether you have committed a serious credit infringement (that is, acted fraudulently or shown an intention not to comply with your credit obligations);
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information about dishonoured cheques;
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repayment history;
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information about court judgments against you;
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any information which is publicly available and relevant to your credit worthiness; and
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certain insolvency information from the National Personal Insolvency Index.
We may use credit reports obtained from credit reporting bodies to produce our own assessments and ratings in respect of your credit worthiness, which may also take into account information we obtain from you and other sources. The reports will have information from your credit file. Your credit file contains information about your credit worthiness and any previous credit applications you have made. It also contains information about any judgements made against you.
How does Global Path collect credit information?
Global Path may obtain credit information in a number of ways, including:
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from Global Path’s customers (or prospective customers) during that customer’s (or prospective customer’s) application process;
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from any other company in the Global Path group
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from retailers, brokers or aggregators who referred you to us;
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from contractors to whom Global Path has outsourced the provision of services to its customers and any other entities operating under the Global Path brand name with authority from Global Path;
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from credit reporting bodies, other credit providers, law enforcement agencies and other government entities;
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from publicly available sources of information;
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during recordings of calls made when you contact Global Path.
Global Path may also collect credit information by other means and will take all reasonable steps to inform you if and when it does.
How does Global Path hold credit information?
The credit information we hold about you may be stored in an encrypted electronic database or in paper files. Global Path’s electronic records are protected by restricted password access, backed up daily and stored off site. Global Path’s paper records containing credit information are stored in secure cabinets or rooms which are locked after hours. Credit information may be stored in Australia and overseas. If credit information is stored overseas, Global Path imposes equivalent physical and logical security measures.
What kinds of information does Global Path derive from credit information?
From the credit information disclosed to Global Path by a credit reporting body, Global Path derives the following kinds of information:
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credit score calculated from information provided by a credit reporting body
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adverse credit history
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current and past directorship
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past and present residential addresses
Why does Global Path collect, hold, use or disclose credit information?
Global Path collects, holds, uses and discloses credit information to provide you, or a customer (or prospective customer) in respect of whom you are nominated as a guarantor, with products and services.
Such purposes include:
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assessing whether you are, or a relevant prospective customer is, eligible for the product or service (including whether the relevant prospective customer would be eligible if you act as guarantor);
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collecting overdue payments; and
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Global Path’s internal management purposes that are directly related to the relevant product or service.
To whom does Global Path disclose credit information?
Global Path may disclose credit information as permitted by law to entities both within and outside Australia, including credit reporting bodies as set out below. Global Path may disclose your credit information to its third-party service providers overseas as further detailed below.
Credit reporting bodies
In addition, we may disclose information to credit reporting bodies. If you are in default, we may report the default to the credit reporting agencies in compliance with the Privacy Act1988.
The credit reporting bodies we use may include:
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Equifax, https://www.equifax.com.au/, 138 332; and
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Illion, https://www.creditcheck.illion.com.au/, 1300734 806
Those credit reporting bodies may include the information disclosed by Global Path in reports provided to credit providers to assist them to assess your credit worthiness. If you fail to meet your payment obligations in relation to consumer credit, or commit a serious credit infringement, Global Path may be entitled to disclose this to those credit reporting bodies.
For contact details and information on how credit reporting bodies manage credit information, please see their privacy policies available at the websites noted above.
Can you request a credit reporting body not use or disclose credit information?
You may request a credit reporting body:
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not to use your credit information for the purposes of pre-screening of direct marketing by a credit provider; and
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not to use or disclose your credit information, if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
Access to and correction of your Personal Information
You may seek access to any information we hold about you by writing to our privacy officer at finance@globalpath.com.au
You may also ask us to correct any information we hold about you if the information is inaccurate or erroneous by writing to our privacy officer at enquiries@globalpath.com.au
Direct marketing
Global Path may use your Personal Information to provide you with information from time to time in relation to additional services and or products we provide. If you do not want to receive such information, you may unsubscribe by calling us on 1300 586 936, ticking the opt out box on our application form or on the service agreement, or following the unsubscribe instructions in the communication.
Overseas disclosure
To assess your finance enquiry and to administer our finance offerings we may disclose your Personal Information or Credit Information to overseas entities. Some of our products and services are supported by third party contractors and other external organisations, which are located in jurisdictions including Europe, Asia and North America. If you provide your Personal Information or Credit Information, then we may disclose this information to these third parties, to enable the effective operation and functionality of those products and services.
We will only disclose your Personal Information and Credit Information if:
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you have provided consent; or
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we believe on reasonable grounds that the overseas recipient is required to deal with your Personal Information and Credit Information by enforceable laws which are similar to the requirements under the Privacy Act and other applicable laws; or
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it is otherwise permitted by law.
If we disclose your Personal Information or Credit Information to overseas entities, we will take reasonable steps to ensure that those overseas recipients protect the privacy of your Personal Information and Credit Information as we have committed to under this Privacy Statement. Whilst we attempt to select and secure reputable offshore service providers, we are not liable for any breach or misuse of information sent offshore. An overseas entity may not be subject to privacy laws or principles similar to those which apply in Australia, and any information disclosed to an overseas entity may not have the same protection as under the Australian privacy law. You may not be able to seek redress for any breach of your privacy which occurs outside of Australia.
Complaints
If you believe that your Personal Information has been mishandled by us or that we have breached this statement in any way, we invite you to write to our privacy officer at enquiries@globalpath.com.au We will make every effort to resolve your complaint internally.
If you are dissatisfied with the resolution we offered you, you may file a complaint with the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner’s contact details are set out below.
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Online: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint
Changes to this privacy statement
Global Path reserves the right to vary this statement from time to time. If we change the statement, we will post the revised statement as soon as it is completed on our website. We do not have to provide you with notice of changes to the statement. We encourage you to periodically review our privacy statement for any changes.
Further information?
If you have any questions regarding this privacy statement or would like more information about the way we manage your Personal Information, please write to us on enquiries@globalpath.com.au
Effective Date 03 October 2023.