SocietyOne Privacy and Credit Reporting Policy
When you trust SocietyOne with your personal and credit related information, we know you expect us to protect it and keep it safe.
We are committed to protecting your privacy and will comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Privacy (Credit Reporting) Code 2014. They govern how we collect, use, hold and disclose your personal information and how we ensure it is accurate and secure.
This policy applies to all SocietyOne companies.
What is personal and credit related information?
Any information or opinions about you are personal information.
Credit related information includes identification information as well as information about your financial and credit situation and history, e.g. the types and amounts of loans and loan applications, repayment history, requests for information about you from credit providers and mortgage insurers, credit defaults, court proceedings and personal insolvency as well as information that has been derived about you by credit reporting bodies such as a credit report.
What kinds of personal information do we collect and hold?
The information we seek to collect about you depends on whether you are an investor or borrower with us. We will always collect your name, address, contact details, date of birth nominated bank accounts and your tax file number. We also collect credit related information about our borrowers.
If you do not provide us with the information we ask for, we may not be able to deliver our services effectively or at all.
How do we use your information?
We use your personal information to provide our products and services to you including the following:
Establish your identity and assess your applications for our products and services
Price and design our products and services
Tell you about products and services offered by SocietyOne or our preferred suppliers that we believe may interest you - unless you ask us not to
Administer our products and services and manage our relationship with you
Manage our risks and help identify and investigate illegal activity, such as fraud
Conduct and improve our businesses and improve our customers' experience
Comply with our legal obligations and assist government and law enforcement agencies or regulators.
What laws require or authorise us to collect personal information?
We are required by law to collect the following information:
Certain identification information about you - by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
Your Tax File Number, if you choose to provide it - by the Income Tax Assessment Act 1936 (Cth);
If you have applied for credit or provide a guarantee, certain information about your financial position under the National Consumer Credit Protection Act 2009 (Cth), and if you give us a mortgage security, certain identification information under property laws in some states and territories.
How do we collect personal information?
We collect most personal information directly from you. For example, when you apply for or use a product or service or talk to us in person or on the phone. We ask borrowers to allow us to collect information from their service providers such as banks and we collect information about borrowers from credit reporting bodies.
We collect information about you from others, such as your service providers and agents, advisers, brokers, employers or family members. We will generally only do this with your consent. For example, borrowers may instruct GetCreditScore to provide us with your credit grade.
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.
If we need to obtain sensitive information about you, we will ask for your consent where required by law.
We also collect information from you electronically. If you log into the SocietyOne website we may collect information from you to confirm your identity. So that we can better tailor information and products to your needs, when we send you email messages, we may use technology to identify you so that we can know when you have opened the email or clicked on a particular link in the email.
When you use our website, tablet or mobile applications, we may collect information about your location or activity including the date of and time of visits, which pages are viewed, how you as the user navigate through the website and interact with the webpages (including fields completed in form and applications), IP address, telephone number, information about the device used to visit our website and whether you"ve accessed third party sites. Some of this information is collected using cookies.
How do we hold and manage personal information??
Much of the information we hold about you will be stored electronically in secure data centres located in Australia owned by either SocietyOne or our external service providers. Some of your information will be stored in paper files.
We use a range of physical and electronic security measures to protect the security of the personal information we hold. For example:
Access to information systems is controlled through identity and access management.
Employees are bound by internal information security policies and are required to keep information secure.
All employees are required to complete training about information security.
Disclosure of personal information?
We may disclose your personal information to other SocietyOne companies.
We may also disclose your personal information to organisations external to SocietyOne. This includes:
Your advisers, agents and service providers and anyone to whom you have agreed we may provide your information
Other organisations who provide products or services to you jointly with us, or who we believe can offer services that will be of use to you
Our collection agencies, legal advisers, accountants, auditors and external dispute resolution scheme and any other agents, contractors or external service provider
Our investors, but all information provided to investors is de-identified
Where we are required or permitted to do so by law.
We require all our service providers to comply with the privacy laws.
Do we disclose personal information overseas?
We may disclose your personal information to recipients located outside Australia
SocietyOne companies located in Singapore and New Zealand
SocietyOne service providers which are likely to be located in the United States, United Kingdom, and
For international transactions to the corresponding international party in order to process the transaction. The countries we disclose your information to will depend on the details of the transaction you ask us to carry out.
Credit related information
Credit reports- When you apply for credit or propose to be a guarantor, we need to know if you're able to meet payments under your agreement with us. We also want to avoid giving you further credit if this would put you in financial difficulty. One of our checks involves obtaining a credit report about you.
Credit reports contain information about your credit history which helps credit providers assess your credit applications, verify your identity and manage accounts you hold with them. Credit reporting bodies collect and exchange this information with credit providers like SocietyOne and other service providers such as phone companies.
The Privacy Act limits the information that credit providers can disclose about you to credit reporting bodies, as well as the ways in which credit providers can use credit reports.
What information can we exchange with credit reporting bodies? - The information we can exchange includes your identification details, what type of loans you have, how much you've borrowed, whether you've met your loan payments and if you have committed a serious credit infringement (such as fraud). We also ask the credit reporting body to give us an overall assessment of your creditworthiness.
We use the following credit reporting bodies:
Veda Advantage Information Services and Solutions Ltd - www.veda.com.au
Experian Australia Credit Services Pty Ltd -www.experian.com.au/credit-services
Dun & Bradstreet (Australia) Pty Ltd - www.checkyourcredit.com.au
What do we do with credit-related information?
We use this information to confirm your identity, assess your creditworthiness and application for credit under our criteria, manage our relationship with you and collect overdue payments.
Credit reporting bodies with whom we exchange information may include the information in reports they provide to other credit providers to assist them to assess your creditworthiness. You can obtain a copy of the credit reporting body"s policy about the management of credit-related information by contacting them or from their website.
Other credit providers may ask credit reporting bodies to use your credit-related information to pre-screen you for direct marketing. You can ask a credit reporting body not to do this. Also, if you've been, or have reason to believe that you're likely to become, a victim of fraud (including identity fraud), you can ask the credit reporting body not to use or disclose the credit-related information it holds about you.
Accessing, updating and correcting your information
You can ask for access to the personal and credit-related information we hold about you. You can also ask for corrections to be made.
We may charge you for any reasonable costs incurred by us to access your personal information which is not credit related. You will be charged our reasonable costs of accessing your credit-related information if you have already sought access to it in the past 12 months.
There is no fee for correcting your personal information. If we disagree that your information should be corrected, we will tell you why in writing.
We can deny or limit access to your personal information if we cannot identify you, the information relates to commercially sensitive of privileged material, or if your request is vexatious. Whatever the outcome, we'll write to you explaining our decision.
If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Privacy Act, the Code or the APPs, you can contact our Privacy Officer on:
Telephone: 1300 144 221
PO Box 5175, Sydney NSW 2001
If you are not satisfied with the way we handled your complaint, you may complain to the Office of the Australian Information Commissioner.
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
- Website Conditions
General terms and conditions for all users
To the extent possible we choose to carry out all transactions by means of electronic communication in accordance with the Electronic Transactions Act 1999 (Cth) and any regulations. You consent to using electronic means to form, or agree, or agree to, or bind you to, legal obligations. Therefore, where you indicate through electronic means your agreement to, or acceptance of, terms and conditions, offers and other documents, you will be taken to have agreed to, or signed them.
You agree that any where We are required, by law or otherwise, to provide you with any documentation you consent to the provision of that document electronically through the links on this website or any other means We choose to use. Paper documents may no longer be given to you and you must regularly check your email, Activity Feed, your Account, text messages and SocietyOne Website for the documents. You may withdraw your consent to the giving of documents by electronic communication at any time by emailing us at firstname.lastname@example.org.We suggest that you print a copy of the document, or file it electronically, for future reference.
To access SocietyOne"s services you will also need to agree to receive notices, information and other disclosures in electronic form. We carry out all transactions by means of electronic communication in accordance with the Electronic Transactions Act 1999 (Cth) and any regulations.
also consent to receive notices, information and other disclosures in electronic form We choose to use. through the links on this website or any other means.
The Site contains information and features that you can access and use, including borrowing and lending accounts and related services, monitoring your loans, participating in groups and any other features or content we may add in the future (the Services).
Eligibility to Use SocietyOne"s Services
To be eligible to use Our services via the Site you must hold an Australian bank account and be twentyone (21) years of age or older (Eligibility Criteria). We may vary the Eligibility Criteria from time to time. By using the Service or the Site, you represent and warrant that you are 21 or older and have an Australian bank account. We may terminate your membership (see below), delete your profile and any content or information that you have posted on the Site and/or prohibit you from using or accessing the Site without limitation if We believe that you do not comply with the Eligibility Criteria.
To access the full range of Our services and to view all the available details we require that you register a SocietyOne Account (Account) (thereby becoming an Account holder) using a valid email, a user name, a secure password and security question. Each registration is for a single user or joint users only where you are married or in a de facto relationship (Joint Registration). If you are eligible for Joint Registration and register an Account, you and your registering partner will be held to be jointly and severally liable at all times. You must not share your user name and password with any other person nor with multiple users on a network.
You are responsible for maintaining the confidentiality of your password and security question at all times. Please notify Us immediately of any unauthorised use or any other breach of security in relation to your Account. You may not use an Account held by any other individual or entity to access Our services at any time.
Collection of Information
You authorise Us to collect and access your information from time to time for the purpose of providing Our services to you. If you have any questions regarding the collection and access to your personal information, please contact us by emailing email@example.com. We may collect personal information from Social media networks such as LinkedIn when providing Our services. We may also collect personal information as required or authorised by or under The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the National Consumer Credit Protection Act 2009 (Cth), The National Credit Code, or any of their related regulations. In addition, if we are required or authorised by or under a court or tribunal order to collect personal information about you, we will take reasonable steps to notify you as soon as practicable after the order.
We generally use personal information to:
provide you with services you have requested;
communicate with you;
determine your SocietyOne Credit Score;
verify your identity and other information you provide to Us; and
help us manage and enhance Our services.
If some or all of the personal information is not collected, we may not be able to provide you with Our services, so that you may not be able to borrow from or invest with us. We may also disclose personal information to credit reporting and rating agencies, debt collection agencies, any related body corporate of SocietyOne and other third parties and contractors as part of providing Our service.
access your personal information held by Us and seek the correction of such information; and
complain about a breach of the Australian Privacy Principles or a registered Australian Privacy Principles Code (if any) that binds Us, and how We will deal with such a complaint.
For the purpose of providing you with Our services, it is likely that we may disclose your personal information to overseas recipients located in New Zealand.
Type Definition Example Marketing Information relating to investing or borrowing via the Online Platform, advertisements or promotion of SocietyOne services.
- Emails containing information on new credit lending services or promotions;
- Activity Feed notification to a customer of a special offer; or
- An email promoting a customer competition on societyone.com.au
Operational Information relating to your Account, Loan or Bid, servicing information including information regarding fees and charges and terms and conditions published by SocietyOne.
- Activity Feed notification reminding you to deposit funds into your account to avoid fees and charges;
- Text message notifying you of the progress of your Bid;
- An email notifying you of your successful Loan application.
Legal Legal documents, notices or communications
- Loan Offer
- Payment dishonours and Arrears notifications
- Notices of Default and Intent to Default; or
- Notices of demand
- Yodlee Terms
Yodlee, Inc. of 3600 Bridge Parkway, Redwood City, California 94065 (the "service provider") provides SOCIETYONE with the technology and other services required to deliver SOCIETYONE Online Bank Statements Retrieval. The service provider is a Banking beneficiary under these Terms with all the rights, benefits and protections as if it were a party to these Terms and a reference to SOCIETYONE in these Terms shall (for the purpose of the service provider receiving the full benefit of such rights, benefits and protections) also be deemed to be a reference to the service provider.
SOCIETYONE Online Bank Statements Retrieval is an information management service that allows you to retrieve your bank statements and forward them online to SOCIETYONE.
When you use SOCIETYONE Online Bank Statements Retrieval to access your Banking Website you:
authorise SOCIETYONE to use information provided by you to access a Banking Website; retrieve statement information requested by you; to copy or transfer such statement information; and to otherwise use, display, andd create derivative works from such information to provide SOCIETYONE Online Bank Statements Retrieval to you. For these purposes you appoint SOCIETYONE and its service provider as your agent with the full power to do and perform each act or thing requisite and necessary to be done and as fully as you might or could do in person;
represent that you are the legal owner of the account at the Banking Website and that you have the authority to designate SOCIETYONE and its service provider as your agent and to give us the information you provide to use SOCIETYONE Online Bank Statements Retrieval;
acknowledge that when SOCIETYONE and its service provider accesses and retrieves information from a Banking Website they do so as your agent and they are not the agent of the entity providing the Banking Website; and
acknowledge that balances shown on SOCIETYONE Online Bank Statements Retrieval obtained from a Banking Website reflect the most recent refresh by the entity providing the Banking Website and the most recent refresh by SOCIETYONE Online Bank Statements Retrieval and may not be as accurate as if the Banking Website was accessed directly.
SOCIETYONE has no responsibility for any transactions, inquiries or other activities you initiate at a Banking Website, the products and services at a Banking Website and any fees charged by the entity providing the Banking Website.
You represent that:
all information you provide to SOCIETYONE and its service provider in connection with SOCIETYONE Online Bank Statements Retrieval is accurate, current and complete, and that you have the right to provide such information to SOCIETYONE and its service provider for the purpose of operating SOCIETYONE Online Bank Statements Retrieval.
You agree to not:
misrepresent your identity or your account information. You agree to keep your registration and account information up to date and accurate.
You are responsible for maintaining the confidentiality of your personal identification number ("PIN") and all other log-in information in relation to SOCIETYONE Online Bank Statements Retrieval and any Banking Website. You must not:
disclose your PIN and/or password any other log-in information to any other person, except to the extent necessary for SOCIETYONE to provide SOCIETYONE Online Bank Statements Retrieval to you;
keep a record of your PIN and/or password and other log-in information;
write your PIN and/or password down and other log-in information;
negligently or recklessly disclose your PIN and/or password and other log-in information by, for example, failing to take reasonable care when typing it or keying it in PIN and/or password and other log-in information that you select must not be easily identifiable
- Returns Methodology
Investments in personal loans may be made through the SocietyOne P2P Lending Trust operated by SocietyOne Australia Pty Limited ACN 151 627 977 as trustee. Investments in agricultural loans may be made through the SocietyOne Livestock Lending Trust operated by SocietyOne Livestock Lending Pty Limited ACN 161 968 869 as trustee. Investment in these unregistered managed investment schemes is only available to wholesale investors. SocietyOne Australia Pty Limited and SocietyOne Livestock Lending Pty Limited are authorised representatives of Ironbark Asset Management Pty Ltd ACN 136 679 420 AFSL 341020.
The returns shown are calculated net of all fees, with no allowance for taxation. They represent past returns and are not indicative of future returns, which may vary. All investments involve risk and investors may lose some or all of their capital.
To the extent that any information in this document constitutes advice, it is general. You should consider whether it is appropriate in the light of your objectives, financial situation or needs before deciding to invest. Prospective investors should obtain a copy of and consider the investment memorandum for the investments before making any decision. SocietyOne cannot provide advice to you; if you need advice, contact a professional adviser.
Details of Calculations and Assumptions
*EAR reflects the actual historical return up to the date of calculation, and does not include cash interest or cash balances (i.e. it is a measure of return only on funds invested).
EAR is calculated as:
- N = Number of Loans in the portfolio
- Interest = All Interest received on a loan
- WriteOffs = Outstanding loan amount at time of Write Off
- Recoveries = Actual recoveries received on loans that have been written off
- Principal = A daily weighted balance of the outstanding loan amount, calculated as
for each day
#Loss Rate uses a standard definition of WriteOff amount subtract Recoveries, divided by the dollar weighted principal amount as specified above. Loans are written off if they have been in arrears for more than 180 days. If loans are considered to be fully written off at 90 days in arrears, then the loss rate for the SocietyOne portfolio grows to 1.74%. This revised loss rate gives an indication of where future loss rates may reside.
Notes: Loans must have originated on or after 1 Jan 2013, and has been calculated as at 30th November 2015. Loans must also be originated more than three months prior to the calculation date, which removes return and loss anomalies in a dynamically growing book
The SocietyOne portfolio dollar weighted average age of 4.3 months, calculated as
for all loans