Privacy Policy

1. Introduction

Steadfast Recoveries ABN [XX XXX XXX XXX] ("we", "us", "our") is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) set out in Schedule 1 of that Act.

This Privacy Policy explains how we collect, use, disclose, and store your personal information and how you can contact us if you have a privacy concern.

2. What Personal Information We Collect

We may collect and hold the following types of personal information:

• Identity information — full name, date of birth, and government-issued identification details
• Contact details — postal address, email address, and telephone numbers
• Financial information — account balances, transaction history, bank account or card details used for payments
• Employment information — employer name and income details (where relevant to assessing hardship)
• Communication records — records of phone calls, emails, letters, and online messages with us
• Technical information — IP address, browser type, and usage data collected via cookies when you visit our website

We only collect sensitive information (such as health information in hardship applications) with your consent and where it is reasonably necessary for our functions.

3. How We Collect Personal Information

We collect personal information in the following ways:

• Directly from you — when you submit forms on our website, call us, or correspond with us by email or letter
• From our clients (creditors) — when an account is referred to us for collection, the creditor provides us with your personal details
• From third parties — where permitted by law, from credit reporting bodies, public registers, or skip-tracing providers to locate or verify your contact details
• Automatically — via cookies and web analytics when you browse our website

4. Why We Hold and Use Your Personal Information

We use personal information for the following primary purposes:

• To contact you about an outstanding account referred to us by a creditor
• To verify your identity before discussing account details
• To arrange and process payments or payment plans
• To assess and respond to hardship applications
• To investigate and respond to account disputes
• To comply with legal and regulatory obligations
• To improve our website, services, and internal processes

We will not use your personal information for direct marketing purposes unrelated to your account without your explicit consent.

5. Disclosure of Personal Information

We may disclose your personal information to:

• The creditor who referred your account to us, including updates on payments and dispute outcomes
• Payment processors and banking institutions to facilitate transactions
• Cloud service providers and IT vendors who assist us in storing and managing data securely
• Legal and compliance advisers where required
• Government and regulatory bodies (e.g., ASIC, ACCC) where required by law
• Credit reporting bodies in accordance with the Privacy Act 1988 and the CR Code, where we have a legal basis to do so

We do not sell your personal information to third parties.

6. Overseas Disclosure

Where we use cloud infrastructure or service providers that may store data outside Australia, we take reasonable steps to ensure those third parties comply with the APPs or a comparable privacy regime. By using our services, you acknowledge that your information may be processed outside Australia in such circumstances.

7. Information Security

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our security measures include:

• TLS/SSL encryption for all data transmitted to and from our website
• Role-based access controls and staff training
• Regular security reviews and vulnerability assessments
• Secure destruction of personal information when it is no longer required

If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.

8. Retention of Information

We retain personal information for as long as it is needed to fulfil the purpose for which it was collected, or as required by law. Account records are typically retained for 7 years after account closure in accordance with general financial records obligations. After this period, records are securely destroyed.

9. Your Rights

Under the Australian Privacy Principles, you have the right to:

• Access — request a copy of the personal information we hold about you
• Correction — request that we correct any information that is inaccurate, out-of-date, incomplete, or misleading
• Opt out of direct marketing — request that we stop contacting you for marketing purposes (note: we may still contact you about your account)
• Complaint — lodge a complaint with us about how we have handled your personal information

To exercise these rights, please contact our Privacy Officer using the details below. We will respond within 30 days. If you are unsatisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC).

10. Cookies and Website Analytics

Our website uses cookies and similar technologies to improve your browsing experience and to understand how visitors use our site. You may disable cookies through your browser settings; however, some features of our website may not function correctly if cookies are disabled.

We do not use cookies to identify you personally or track your activity across third-party websites.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated policy will be posted on this page with a revised "Last updated" date. We encourage you to review this page periodically.

12. Contact Us

If you have a question or concern about this Privacy Policy or how we handle your personal information, please contact our Privacy Officer:

You may also contact the OAIC if you believe your privacy rights have been breached.