PRIVACY
POLICY

1. Our Commitment to Privacy

Marshall Freeman (MF) respects your right to privacy. We are committed to handling your personal information in accordance with the relevant privacy regulatory frameworks, including:

• In Australia: the Privacy Act 1988, the Australian Privacy Principles and the relevant guidelines issued by the Office of Australian Information Commissioner.
• In New Zealand: the Privacy Act 2020, the New Zealand Information Privacy Principles, and the relevant guidelines issued by the Office of the Privacy Commissioner.

This Privacy Policy explains how MF collects, uses, stores and discloses your personal information when we carry out debt collection and related services on behalf of our clients.

2. Why We Collect Information

We collect personal information that is necessary for us to identify, contact and communicate with individuals in connection with a debt, including but not limited to:

• Managing and recovering debts on behalf of clients
• Contacting debtors about outstanding accounts
• Verifying identities before discussing account details
• Responding to enquiries and complaints
• Meeting our legal, regulatory and contractual obligations
• Gathering and aggregating information for statistical, prudential, actuarial and research purposes

We only collect information that is reasonably necessary for these functions.

3. Types of Information We Collect

3.1 The personal information we collect may include:

• Name, date of birth and contact details (address, phone, email)
• Identification details (drivers license, account numbers)
• Financial and credit information
• Details of the debt and who the debt is owed to
• Employment and income details (if relevant to repayment)
• Communication records with our staff

3.2 Where necessary we may store credit card information on file for future transactions once a card has been used for payment. This stored information allows for seamless future payments and improves the customer experience.

3.3 We may also collect sensitive information (such as health or hardship information) where you choose to provide it to us to assist with resolving a debt account. This information will only be collected with your consent and handled securely.

3.4 To protect against fraud, or where we are legally required to, we may take any necessary steps to verify information we collect.

4. How We Collect Information

We collect information directly from you when:

• You speak with our staff by phone, email, SMS or mail
• You complete a payment or hardship form
• You visit our website or use our online services

We may also receive information from third parties including:

• Our clients (the Creditor/s or organization that has engaged us to collect a debt)
• Public available sources
• Credit reporting bodies and other relevant third parties
• External service providers assisting with the debt recovery process

We take reasonable steps to ensure all information collected from third parties is accurate, up to date and relevant.

5. Use and Disclosure of Information

5.1 We use your information to:

• Contact you regarding outstanding debts
• Confirm and verify identity or account details
• Assess hardship or repayment proposals
• Process payments and maintain accurate records
• Communicate with our clients about account progress
• Negotiate repayment arrangements
• Comply with legal or regulatory requirements
• Undertake complaint handling or dispute resolution processes

5.2 We may disclose your information to:

• The client or creditor who engaged us
• Payment service providers, lawyers, or external agents assisting in collection
• Regulatory Authorities or Government Offices as required or compelled by law
• Credit reporting bodies

5.3 We will only disclose personal information overseas where it is necessary for our operations, you have consented, the disclosure is authorised by law, or a permitted general situation applies.

5.4 We will not sell, rent or trade your personal information.

6. Storage and Security

6.1 We store information in secure electronic systems and, where applicable, locked physical files. We use access controls, encryption and staff training to protect your information from misuse, interference, loss, unauthorized access, modification or disclosure.

6.2 We have not and will not adopt any record keeping systems that utilize government related identifiers.

6.3 Where information we hold is identified as no longer necessary for any purpose we ensure it is effectively and securely destroyed, for example, by shredding or pulping in the case of paper records or by degaussing and other means in the case of e-records and equipment.

7. Access and Correction

7.1 You have the right to request MF correct any personal information we hold if you believe it is inaccurate, incomplete or outdated. Any requests for correction will need to be made in writing to the Contact email noted below. Your identity will need to be verified before any correction request is considered. We also reserve the right to request any evidentiary information to verify or support any such request as necessary.

7.2 Requests for access to limited amounts of personal information, such as routine administrative matters that we have on our records, can generally be handled over the phone. Other access requests will require a written request to be made to the Contact email noted below. Your identity will also need to be verified before any access is considered.

7.3 We will immediately acknowledge once your request is received, and aim to have a response to you within 30 days. In particular circumstances we are permitted by law to deny your request for access, or limit the access we provide. Our decision will be in writing and will set out the reasons for the refusal, the mechanisms available to complain and any other relevant matters.

8. Complaints and Enquiries

If you have a concern or any feedback about how we have handled your personal information, please contact us first via our website, or to the Contact email noted below. We will immediately acknowledge receipt of your complaint, investigate and aim to respond to your complaint within 30 days in accordance with our internal processes.

If you are not satisfied with our response, you may wish to also refer your matter to the following authorities:

Australia:
Office of Australian Information Commissioner
Website: www.oaic.gov.au
Ph: 1300 363 992
Post: GPO Box 5288, Sydney, NSW 2001

In New Zealand:
The Privacy Commissioner's Office
Website: www.privacy.org.nz
Email: enquiries@privacy.org.nz
Ph: +649 3028680 / 0800 803 909

9. Updates to this Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website or upon request.

10. Contact

For any questions or comments regarding this Policy, please feel free to contact: collections@marshallfreeman.com