Your Data’s Data Statement

This document declares the undertakings by concerning its
handling of Your Data.


Collection undertakes to collect Your Data by means that are:

  • fair;
  • legal; and
  • transparent.

If you visit’s website, your web browser automatically discloses, and’s web server automatically logs the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.

Any additional data you provide, e.g., in a web form, may also be logged. This data may or may not be sufficient to identify you.

Any additional data that your web browser automatically
may also be logged. For example, this will be the case if your browser has previously been requested to store data on your computer in
‘cookies’ and submits them each time you request a web page within a particular domain (such as This data may or may not be sufficient to identify you.

If you disclose personal data to with an identifier such as your name or credit card details, will collect Your Data. Moreover, any data that becomes available to through any of the means described in the preceding paragraphs may be able to be associated with that identifier and hence become Your Data.

Subject to the qualifications immediately below, undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:

  • where reasonably considers that the protection of its
    financial interests require that it gather YourData from other sources, or
    From additional sources. This applies in particular where has a lending exposure to you and seeks information about your creditworthiness;
  • reasonably considers its capability to deliver Quality services to you will be materially enhanced by gathering YourData from other sources. This applies, in particular, to consumer profile data.

Where collects Your Data from sources other than
, it undertakes:

  • to do so only by legal means;
  • to do so only with your Consent; and
  • to declare to you what sources it uses and under what circumstances. undertakes to declare the purpose of the collection in a manner that is clear and meaningful and to avoid vague, highly inclusive
statements such as ‘to support our operations.’

Data Security undertakes to store Your Data in a manner that ensures security against unauthorized access, alteration, or deletion at a level commensurate with its sensitivity. undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines. undertakes to transmit Your Data in a manner that
ensures security against unauthorized access, alteration, or deletion at a
level commensurate with its sensitivity. undertakes to implement appropriate measures to ensure
security of Your Data against inappropriate behavior by’s staff members and contractors
. These include:

  • training for staff concerning privacy;
  • access control, to limit access to Your Data to those staff and
    contractors who have legitimate reasons to access it;
  • particularly in the case of sensitive data, audit trails of accesses,
    including the identities of staff and contractors accessing the data;
  • reminders to staff and contractors from time to time about the importance
    of data privacy and the consequences of inappropriate behavior;
  • declaration of appropriately strong sanctions that are to be applied in
    the event of inappropriate behavior
  • clear communication of policies and sanctions; and
  • processes to audit, investigate and impose sanctions.

Data Use

Use refers to the application of Your Data by any part of, or
any staff member or contractor of in the course of their work. undertakes to use Your Data only for the following:

  • the purposes for which it was collected;
  • such other purposes as are subsequently agreed between and You;
  • such additional purposes as may be required by law. In
    these circumstances, will take any reasonable steps available to it to communicate to You that the use has occurred unless it is precluded from doing so by law; and
  • such additional purposes as are authorized by law (in particular to protect’s interests, e.g., if it believes on reasonable grounds that You have failed to fulfill your undertakings to or have committed a breach of the criminal law). undertakes to use YourData only if it has demonstrable
to the particular use to which it is being put. undertakes to use YourData in such a manner as to consider the possibility that it is not of sufficient quality for the purpose, e.g., because it is inaccurate, out-of-date, incomplete, or

Data Disclosure

Disclosure refers to making YourData available to any party other than and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing, and giving. undertakes to disclose Your Data only under the following circumstances:

  • In the course of business being conducted between You and
    , where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, undertakes to exercise control over’s contractors to ensure that their actions are compliant with these Terms;
  • in other circumstances directly implied by the purpose agreed between You and at the time of data collection or
    subsequently. Where Your Data is disclosed in this way, undertakes to exercise control over’s contractors to ensure that their actions are compliant with these Terms;
  • with your consent or at your request;
  • where required by law, such as a provision of a statute or a court order such as a search warrant or subpoena. In these circumstances, will take any reasonable steps available to it to communicate to You that the disclosure has occurred unless it is precluded from doing so by law;
  • where permitted by law (e.g., the reporting of a suspected breach of the criminal law to a law enforcement agency; and in an emergency, where believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life of health of some person), will apply due diligence to ensure the permission exercise is justifiable.

In all cases, undertakes to disclose only such of Your Data as is necessary for particular circumstances.

Data Retention and Destruction

Subject to the qualifications immediately below, undertakes the following:

  • to retain Your Data only as long as it is consistent with
    its purpose; and
  • to destroy Your Data when its purpose has expired and to
    do so in such a manner that Your Data is not subsequently capable of being recovered.

This undertaking is qualified as follows:

  • Your Data may be retained in’s logs, backups, and audit trails within short-term retention cycles that are devised to protect
    the company’s operations. In such cases, Your Data will be destroyed in
    accordance with those cycles;
  • Your Data may be retained beyond the expiry of its purpose if that is
    Required by law, such as a provision of a statute, a court order such as a search warrant or subpoena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances,


    • will take any reasonable steps available to it to communicate to You that
      Your Data is being retained unless it is precluded from doing so by law; and
    • will only retain Your Data while that provision is current and will then
      destroy Your Data;
  • Your Data may be retained beyond the expiry of its purpose if it is
    authorized by law (in particular to protect’s interests, e.g., if it believes on reasonable grounds that You have failed to
    fulfill your undertakings to or have committed a breach of criminal law). In these circumstances, will only retain Your Data while that situation is current and destroy Your Data.

Access by You to Your Data undertakes to provide you with access to Your
Data, subject to only such conditions and processes as are reasonable in the
circumstances. In particular, undertakes to enable access:

  • conveniently;
  • without unreasonable delay; and
  • without cost. undertakes to establish and operate identity
authentication protections for access to Your Data
that are
appropriate to its sensitivity, but practical. This may involve some
inconvenience; for example, relatively straightforward procedures may be
involved to provide you with access through a channel that you have
previously registered with (such as a particular email address), but may impose more onerous procedures if you wish to use another channel.

If you dispute some aspect of Your Data, undertakes
to take reasonable steps concerning the amendment, supplementation
or deletion
of Your Data.

You undertake:

  • not to seek access for frivolous purposes or unreasonably frequently;
  • to accept that deletion of some data may not be consistent with the
    provision of particular services by to you.

about Data-Handling Practices undertakes to make information available to you about the manner
in which handles your data:

  • in general terms, in a readily accessible manner; and
  • in more specific terms, on request.

Where Your Data is disclosed to a contractor, undertakes to make information available to you on request about how’s
contractors handle your data. undertakes to ensure that the information provided is meaningful,
and addresses your concerns.

You undertake:

  • not to seek such information for frivolous purposes or unreasonably
    frequently; and
  • to accept that the disclosure of excessive detail may harm the security of
    Your Data and’s business processes may harm’s
    commercial interests.

of Enquiries, General Concerns, and Complaints

If you have inquiries, general concerns, or complaints about these Terms, or
about’s behavior concerning these Terms, you undertake:

  • To communicate them in the first instance:
    • to only;
    • in sufficient detail;
    • through a channel made available by for that purpose; undertakes:

  • to provide one or more channels for communication to, which is convenient for users;
  • to promptly provide acknowledgment of the receipt of
    communications, including the provision of a copy of the communication, the
    date and time it was registered, and’s reference code for the
  • to promptly respond to the communication, in
    an appropriate and meaningful manner.

You further undertake not to pursue through any
Regulator or the media:

  • until and unless has had a reasonable opportunity to respond
    to the initial communication; and
  • while and you remain to conduct a meaningful dialogue
    about the matter.

Enforcement declares that its undertakings in these Terms are intended to
create legal obligations, and that those obligations are
intended to be enforceable under appropriate laws in
appropriate jurisdictions. These include laws relating to data protection,
privacy, fair trading, corporations, and criminal laws.

You undertake to seek enforcement only in a jurisdiction that
is relevant to the transactions that have taken place between You and, in particular, the jurisdiction in which you live or in which you
performed the relevant acts, and the jurisdiction in which is
domiciled or performed the relevant acts.

If you wish to discover the relevant laws in any particular jurisdiction, draws your attention to the following resources:

Changes to These Privacy Undertakings undertakes:

  • not to materially change these Terms in a manner that reduces the
    protections for Your Data;
  • to take all possible steps to prevent any company from acquiring this
    company or any of its relevant assets from materially changing the Terms
    applicable to Your Data in a manner that reduces the protections for Your Data;
  • where it is considering making changes to these Terms or creating more
    specific Terms relating to specific services, to consult with appropriate
    representative and advocacy organizations;
  • where it makes changes to these Terms to ensure that the differences
    between successive versions are readily accessible;
  • to maintain all prior versions of these Terms in such a manner that they
    are dated and readily accessible.

Definitions means <The website>.

Your Data means data capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that can correlate with you using server logs and cookie contents.

Your Data does not refer to data that can no longer be associated with
you. This includes aggregated data that does not and cannot identify the
individuals whose data are included in the aggregation.

Consent means your concurrence with an action to be taken by Consent may be expressed or implicit, but it must be informed and freely given in either case.