By visiting our web site ("www.nlc.com.au" or other related web sites), you are accepting the practices described in this privacy policy.

This is the web usage privacy policy for the nlc Group ('nlc') being NLC Pty Ltd (ACN 052 442 645) and its subsidiaries.

Your privacy is important to nlc. nlc respects the right of individuals to have the privacy of their personal information maintained. We recognise the importance of personal information privacy and the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)and the (Credit Reporting) Code 2014 with respect to the collection, storage and handling of personal information. We also have obligations in relation to your personal information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Electronic Transactions Act 1999 (Cth) and the Electronic Transaction Amendment Act 2011 (Cth) and the National Consumer Credit Protection Act 2009 (Cth). We are also authorised to collect personal information under the Personal Property Securities Act 2009 (Cth).

This privacy policy provides information about the personal information that nlc collects and the ways in which nlc uses that information.

It is important for you to understand that we need different types of personal information at different stages of your relationship with us and therefore the policy is divided into four areas:

1. Overview of Information Collection & Usage Practices
2. Website Information Collection & Usage Practices
3. Further Information on Collection & Usage Practices 
4. Information on Storage & Access Practices

The first area provides an overview of our information collection and usage practices. The second area addresses information we may collect when you use our website and how we may use this information. The third area addresses information that we may collect if you request a salary packaging report, a quotation or if you complete an application for finance and/or insurance or request motor vehicle advisory and referral services. The final area provides you with detail on how we store your information and how you are able to access it and request changes to it.

Agreement to Terms of Privacy Policy

By using this web site and/or providing information to us, you accept and agree to the collection and use of your personal data for the purposes described. We will review our policies regularly and occasionally may need to change or update them. This privacy policy was last reviewed and updated 5^th March 2014 

1. Overview of Information Collection & Usage Practices

nlc collects personal information that you provide directly to nlc as well as information from publicly available sources and third parties.

nlc only collects personal information that is necessary to carry out our primary business activities, including providing you with information and general marketing activity about our financial products and services, insurance products and services and motor vehicle advisory and referral services.

If at any time you provide us with the personal details of someone else (e.g. a spouse), you must ensure that the person has read and understood this privacy policy and separately consented to his or her personal information being used and disclosed to us by you for the purposes detailed in this policy.

nlc will not use an identifier assigned by a Federal government agency to identify an individual.

Where nlc provides you with marketing material, nlc will also provide you with the option to opt out of receiving future marketing material.

Where applicable, we may be authorised to collect your tax file number for the purposes of managing your superannuation contributions under a salary packaging which has been agreed between you and your employer. Access to tax file number information for such purposes is required under taxation and superannuation laws such as the Income Tax Assessment Act 1936 and the Superannuation Industry (Supervision) Act 1993. In order to send contributions using SuperStream*, we are also required to collect the unique superannuation identifier (for APRA-regulated funds), electronic service addresses (ESA) for Self-Managed Super Funds and bank account details of your nominated super fund.

*All superannuation contributions made under a salary sacrifice arrangement must be sent using the SuperStream data and payment standard. For more information on SuperStream, please refer to www.ato.gov.au/superstream.

Sensitive Information

We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to, race, political or religious beliefs, sexual preferences, criminal convictions and, health information.

We may also collect information about your health (particularly if you purchase involuntary unemployment insuranceor make a disclosure or claim relating tothisinsurance) or criminal convictions which are defined as sensitive information in the Privacy Act, with your consent. We may collect, hold, use and disclose personal information about you under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Electronic Transactions Act 1999 (Cth) and Electronic Transactions Amendment Act 2011 (Cth) and the National Consumer Credit Protection Act 2009 and we are authorised to collect personal information under the Personal Property Securities Act 2009 (Cth)

We can only fully advise you if we have all relevant information. Where applying to us for an insurance product, the insurance laws also require you to provide your insurers with all information they need in order to be able to decide whether to insure you and on what terms. 

If you do not supply us with your personal information we may be unable to process your application for finance and/or insurance.

2. Website Information Collection & Usage Practices

You can access our home page and browse our website without disclosing your personal information.  When you access the site or services, we may collect the following information:

Personal Information - We collect Personal Information when you knowingly provide it, including when you provide feedback or request information

Non-Personally Identifiable Information - nlc automatically receives and records certain "traffic data" on its server logs including your IP address, browser type, browser language, the page you requested, the date and time of this request, your communications and interactions with other site registrants and the page you visited immediately prior to visiting this site. You understand that nlc uses this data to help diagnose problems, analyse trends and develop marketing material communications. nlc may from time to time use information and data collected to send site or operational announcements to Customers by email or other electronic forms.

Cookies - We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them).

 The following types of cookies could be placed on your computer:

Social Media Cookies: These cookies are used to integrate our site with popular social media sites (Facebook, Twitter, YouTube, Google+, Add This, etc.).  Social Media cookies allows visitors to share content quickly and easily with their social networks. Log data may include information such as IP address, browser type, the referring web page, pages visited, cookies, and other interactions with the social sharing buttons or widgets.

Google Analytics Cookies: These cookies (__unam, __utma, __utmb, __utmc, __utmz) are used to measure website traffic and activity, and improve the user experience by providing us with anonymous, unique and repeat visitor performance data in aggregate format.

Marketing Automation Cookies: We use a 3rd party marketing automation provider, Marketo.com. Marketo tracking cookies (_mkto_trk) allow us to collect information about how you use our site after you have received an email from us. The cookies track data linked to your email address and include data such as how you arrived at the site, how often you've visited, and which pages you looked at. To opt out of this, you can disable cookies or unsubscribe from our emails using the link on the bottom of any marketing email. You understand you can prevent this collection of information by setting your browser to not accept cookies. This will not prevent you from accessing the site; however, it may prevent you from utilising all features of the site.

Direct Marketing

We may use your personal information for marketing and promotional purposes and may send you information about other services and products that may be of interest to you. Our communication to you may be sent in various forms such as mail, SMS, fax and email. You consent to us sending you marketing communications. If you indicate a preference for a method of communication, we will endeavour to use that method wherever practical to do so. If you do not wish to receive information about our products and services or those of other members of the Group, you may notify us using the contact details provided below or by using any opt-out facilities provided in the marketing communications.

Internet Service Provider

The nlc web site and electronic mail is not managed by a third party Internet Service Provider (ISP).

3. Further Information on Collection & Usage Practices

If you request a salary packaging report, a quotation or if you complete an application for finance and/or insurance or request motor vehicle advisory and referral services you will be required to supply us with personal information as part of the request or application.

Use of Personal Information

nlc may collect, use and disclose your personal information to:

• Provide you with products and services;
• Respond to your queries,
• Obtain and provide you with quotes for finance and / or insurance products;
• Assess your application for finance and /or insurance;
• Advise you on insurance and risk management needs;,
• Provide you finance and/or insurance and related financial and insurance services;
• Communicate with you in relation to your finance and/or insurance contract and related services;
• Carry out day to day operational activities related to the management of your finance and/or insurance contractand or fleet management account;
• Assist you with insurance claims;
• Assist you with motor vehicle acquisition and disposal;
• Operate our business;
• Where applicable, so that we may comply with relevant taxation and superannuation laws, we will forward all necessary data (including tax file number) associated with superannuation contributions, to a third party solution partner who meets the SuperStream*standard; and
• Related companies in Australia and overseas

* All superannuation contributions made under a salary sacrifice arrangement must be sent using the SuperStream data and payment standard. For more information on SuperStream, please refer to www.ato.gov.au/superstream.

We will endeavour to only collect your personal information directly from you. However, there are circumstances where we will be required to collect your information from, and disclose information to, third parties. We may collect and disclose personal information about you from/to other parties including:

• To and from your employer to confirm details of your employment including your salary, your position, your length of employment and that you are entitled to a lease under the company's policy, and to administer your lease,
• To and from a credit reporting agency to obtain a credit reference on you in the course of assessing your application for finance and/or insurance, and
• To and from insurers or underwriters to assess whether to insure risks, and to administer any insurance contract (including claims).

The types of organisations we may disclose your information to are: 

• Your employer;
• Our principal credit underwriters in order to provide you with finance, including assessing your application;
• Third parties contracted to provide fuel or maintenance services for your leased vehicle;
• Vehicle dealers if we order a vehicle on your behalf;
• Organisations contracted to provide administrative services such as mail service providers;
• Insurance companies and insurance underwriters;
• Credit reporting bodies for the purpose of obtaining credit reports to assess credit applications, collect overdue commercial credit and to assess any guarantors of credit applications;
• Other credit providers in relation to your credit related information;
• Guarantors regarding your personal information and credit related information
• Financiers and rating agencies for the purpose of funding, refinancing, sale or securitization associated with due diligence and review of the products and related services provided to you;
• Third parties including government agencies or toll road operators where required or allowed by law or court or tribunal order in order to register or protect our interest or to deal with infringements;
• Any party acting on your behalf such as financial advisors, accountants or lawyers;
• Organisations to whom we outsource functions including professional advisors and collection and mercantile agents;
• Third party service providers in respect of our products and related services including service providers assisting you with repairs and claims and any person who introduces you to us;
• Third party service providers who provide electronic signatures for electronic records; and
• Where applicable, so that we comply with relevant taxation and superannuation laws, we will forward all necessary data (including tax file number) associated with superannuation contributions, to a third party solution provider who meets the SuperStream* standard.

If we appoint any third party service provider to carry out administrative services on our behalf, and such services involve your personal information, we will use reasonable endeavours to ensure that our third party service providers handle your personal information in accordance with this privacy policy. Separately, in providing and managing our products and services, we may need to disclose personal information to enable them to provide and perform services for nlc. APPs allow companies to share personal information with related bodies corporate

Cross Border Transfers

We disclose personal information outside Australia and we take reasonable steps to ensure that any overseas recipient handles your personal information in accordance with the Privacy Act. We may disclose your personal information to entities located in the following countries:

• Our related bodies corporate in the United Kingdom and New Zealand; and
• Our funders and their related companies and service providers in Austria, Bermuda, Brazil, Canada, China, Denmark, Fiji, France, Germany, Hong Kong, India, Indonesia, Ireland, Japan, Luxemburg, Malaysia, Mexico, Netherlands, New Zealand, Philippines, Russia, Singapore, South Africa, South Korea, Spain, Switzerland, Taiwan, Thailand, Unite Arab Emirates, United Kingdom, and United States of America.
• Our service providers (other than funders) in Belgium, Canada, Germany, India, Netherlands, New Zealand, Philippines, Singapore, United Kingdom and United States of America.

Credit Reporting

We comply with all Privacy Law that applies to the collection, use and disclosure of credit information, including the Privacy (Credit Reporting) Code 2014 and a copy of the NLCCreditReporting Policyis available on the nlc web site at: www.nlc.com.au or a copy may be obtained upon request.

4. Information Storage & Access Practices

Securing Your Data

We take reasonable steps to protect all information which we hold (including your personal information) from misuse, loss, unauthorised access modification or disclosure. However, security of communications over the Internet cannot be guaranteed, and therefore nlc cannot provide absolute assurance that information will be secure at all times.

nlc have implemented security measures to protect the personal information we hold from unauthorised access.

Privacy Statement and Requests for Access

If we collect your personal information, you have the right to request access to your personal information.  However, we will need to establish and verify your identity before we can disclose information to you. The process of verification will vary depending on our assessment of the appropriate level of security required for the information which is being disclosed.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request an amendment of it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it and provide upon request, nlc's reasons for denial of access or a refusal to correct personal information.

If you have any questions in relation to our information handling procedures, or you would like to request a copy of our Privacy Statement, or you wish to lodge a request for access or amendment to the personal information we hold, please contact the Privacy Officer at the address set out below;

How can I contact nlc?

Please address all correspondence to:

The Privacy Officer

NLC Pty Ltd

Level 3, 102 Albert Road

South Melbourne, Victoria 3205

T 03 8699 7000

F 03 8699 7199

E privacyofficer@nlc.com.au

Privacy Complaint Form

If you believe we have not complied with our obligations concerning your personal information we invite you to contact us and lodge a complaint. Complaints can be lodged on the Feedback Form. This form also provides a link to our Complaints Policy which details the process nlc will use to manage your complaint.

This form is to assist you in making a complaint if nlc holds your personal information and you feel your privacy has been infringed by nlc; and

If your complaint is not resolved to your satisfaction you can contact the Office of the Privacy Commissioner on 1300 363 992.

Miscellaneous

• This policy represents our policy at June 2016
• We may change this privacy policy from time to time.
• Although we intend to observe this privacy policy at all times, it is not legally binding on nlc in any way. From time to time we may regard it as necessary or desirable to act outside the policy. nlc may do so, subject only to any statutory rights you may have under the Privacy Act 1988 or other applicable legislation.