Who is Moula?
Moula Money Group (Moula), incorporating Moula Money Pty Ltd (ABN 95 164 875 325) and its subsidiary, Moula Funding Pty Ltd (ABN 64 607 734 154), operates a business providing business loans and financing facilities (up to $250,000) to the small and medium enterprise business community. Moula does not provide consumer credit or consumer finance. All loans and financing facilities provided by Moula are for business purposes only.
Our privacy commitment
Who do we collect personal information from?
Moula collects personal information from people who are customers or potential customers (i.e. borrowers), from referrers and merchants under our referral program, finance brokers, and from other people who are connected to its operations and activities.
Please note that how we handle the credit and credit eligibility information that we collect is set out in our Credit Policy.
What is personal information?
Personal information is any information or an opinion, whether true or not, about you that identifies you, or from which you are reasonably identifiable.
How does Moula collect my personal information?
When you visit the Moula website or apply for a loan, we collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from the site.
When you visit the Moula website or apply for a loan or finance facility, we also collect information about your transactions and your activities. Where you provide secure access to your transaction accounts (banking and cloud accounting, for example), we may access those accounts after the date of the application, for the purposes of managing your facility.
In addition, we may collect the following types of information from you:
- contact information, such as your name, address, phone, email and other similar information;
- if you apply for a loan through our referral program, or you accessed our application program from a link provided by a third party (such as a referrer, merchant, broker or intermediary), information about you provided by that third party;
- information that you provide to Moula in your finance application (even if your application is ultimately rejected by Moula);
- where you have applied for finance, information about your credit history which Moula collects from third parties, including credit bureaus and credit reporting agencies.
In addition, your telephone calls to us may be monitored or recorded for training and record purposes.
See our Credit Policy for information about the credit and credit eligibility information that we collect.
For what purpose is my personal information being collected?
The primary purpose for which Moula collects personal information is so that it can carry out its business of making loans and offering finance facilities to small and medium-sized businesses. See our Credit Policy for more information.
We may also use your personal information to:
- respond to your enquiries and concerns and resolve disputes;
- customise, measure and improve our loan application process and service and the content, layout and operation of our website and loan application process;
- deliver targeted marketing, service update notices and promotional offers based on your communication preferences;
- assess your finance application, including by reviewing any previous finance applications you may have made, and the reasons for granting or rejecting those applications;
- offer and provide finance to you;
- notify you of other relevant products and services (including third party products and services) that may be of interest to you;
- follow up on any partially completed finance applications, or check in with you if you have not visited our website in a while (subject to your communication preferences);
- contact you by email or telephone (by voice call or SMS); and
- to comply with our legal and regulatory requirements.
Generally, you have no obligation to provide Moula with any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with the services requested or allow you to participate in marketing activities that depend on the collection of that information.
Third party marketing
From time to time, we participate in data collectives where we share your personal information with other organisations. We may share the information you provide with those data collectives. However, if you do not wish to receive communications from a third party, please contact us at Moula at email@example.com.
Where we use your personal information to send you marketing and promotional information by post, email or we contact you by telephone, you will be provided with an opportunity to opt-out of receiving such information. If you wish to opt-out, please contact us at Moula at firstname.lastname@example.org.
Website usage information and cookies
You may decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website and the Moula services. You can refer to the ‘help’ section of your browser or installed applications for instructions on blocking, disabling or deleting cookies.
In what situations may I deal with Moula anonymously or by pseudonym?
To whom is my personal information usually disclosed?
In carrying out our business, we may need to disclose your personal information to others, as follows:
- within our corporate group and subsidiaries;
- Credit bureaus, credit reporting agencies, and collection agencies: see our Credit Policy for more information.
- Service providers under contract: who help with our business operations such as fraud prevention, bill collection, marketing, direct debit services (for example, Ezidebit) and technology services – where we engage such service providers, our contracts provide that they may only use your personal information in connection with the services they perform for us
- Third party marketing: as stated above, we may provide your contact details to other organisations to contact you with information that may be of interest to you (unless you advise us that you do not want us to)
- Law enforcement, government agencies or other third parties as required by law: when we need to comply with law or credit card rules, or when we believe that the disclosure of personal information is necessary to prevent harm or financial loss, to report suspected illegal activity or to investigate contraventions of our loan arrangements
- For our marketing and promotional activities, we may provide your personal information temporarily to contractors who perform services on our behalf, such as mailing houses, printers, information technology services providers (including offshore cloud computing service providers), database contractors and teleservice bureaus. Such contractors are subject to privacy and security contractual arrangements.
- If we are otherwise permitted or required to do so by law.
- Some recipients may be located outside of Australia. The recipients may be located in the U.S, UK, the Philippines, and nations in the EU. Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Principles in the Privacy Act.
- If you have been referred to Moula by a third party under Moula’s Commercial Referral Program or other referral programs (such as Moula’s merchant referral program), or have accessed the Moula loan application page through a link provided by a third party, you acknowledge and agree that:
- the information provided in your loan application is, to the best of your knowledge, complete, accurate and up-to-date; and
- your personal information (including information about the status of your finance application, any information gathered during the assessment process, and any information about any defaults or late payments under any business loan or drawing granted to you by Moula) may be shared by Moula with the relevant third party referrer for the purposes of loan assessment and administering the relevant Moula third party referral program.
Where is my personal information stored?
Your personal information will be stored on a password-protected electronic database, which may be a Moula database, a database maintained by a cloud hosting service provider or other third party database storage or server provider. All such personal information is maintained within the effective control of Moula. We have arrangements which require third party service providers to maintain the security of the information and we take reasonable steps to protect the privacy and security of that information.
After this time, we will either de-identify it or destroy it in accordance with privacy law requirements.
How is my personal information secured?
We use Secure Socket Layer (SSL) certificates which is the industry standard for encrypting your credit card and debit card numbers, your name and address so that it cannot be viewed by any third party over the internet. Your financial information is encrypted on our servers and access to this information is restricted to authorised Moula staff only.
Please notify us immediately if you become aware of any breach of security.
Dealing with unsolicited information
Unless there is a legitimate purpose for retention, we will take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified as soon as practicable.
We do not use government identifiers (e.g. tax file numbers or Medicare numbers) to identify individuals.
Access to your personal information
Moula will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we request that you identify, as clearly as possible, the type/s of information requested. We will deal with your request to provide access to your personal information within a reasonable period after the request is made and you agree we may charge you our reasonable costs incurred in supplying you with access to this information.
Your rights to access personal information are not absolute and in certain circumstances, privacy laws dictate that we are not required to grant access such as where access would have an unreasonable impact on the privacy of other individuals, providing access would be unlawful, or access may prejudice commercial negotiations, legal proceedings, enforcement activities or appropriate action being taken in respect of a suspected unlawful activity or serious misconduct. If we refuse your request, we will notify you in writing of our reasons (unless it would be unreasonable to do so) and explain how you can take the matter further if you are not satisfied with our response.
Updating your personal information
You may ask us to update or correct the personal information we hold about you at any time. We will take reasonable steps to verify your identity before granting access or making any corrections to your information. We will deal with your request to update or correct your personal information within a reasonable period after the request is made. We also have obligations to take reasonable steps to correct personal information we hold when we are satisfied that it is inaccurate, out- of-date, incomplete, irrelevant or misleading for the purpose for which it is held.
If you require access to, or wish to update your personal information, please contact us at Moula at email@example.com.
Website and Social Media
When a user visits our website or our social media sites, we may collect certain information such as browser type, operating system, website visited immediately before coming to our website, etc. This information is used in an aggregated manner to analyse how users use our website, such that we can improve our services.
We may from time to time use web beacons and cookies on our website. Web beacons (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our services to provide information or communicate with us. Cookies are very small files which a website uses to identify users when a user comes back to the site and to store details about that user’s use of the site. Cookies are not malicious programs that access or damage a user’s computer or device. Most web browsers automatically accept cookies but a user can choose to reject cookies by changing the browser settings. However, this may prevent a user from taking full advantage of our website.
Our website may from time to time use web beacons or cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant advertising to website visitors through third parties.
When you access our services via your mobile device or computer, we may automatically collect information about your device or computer, including unique device identifiers (e.g., IMEI number, serial number, etc.), operating system, hardware model, etc.
Our website may from time to time have links to other websites not owned or controlled by us. These links are meant for users’ convenience only. Links to third party websites do not constitute sponsorship, endorsement or approval of these websites. Please be aware that We are not responsible for the privacy practices of other such websites. We encourage users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
Problems or queries
Who do we collect credit and credit eligibility information about?
We collect credit and credit eligibility information about our customers who apply for and/or are given loans or finance facilities and any guarantors of those loans or finance facilities.
What credit and credit eligibility information does Moula collect?
The kinds of credit and credit eligibility information that we collect and hold are:
- identification information such as your name, date of birth, sex, address(es), employment/business details and driver’s license number;
- that you have applied for commercial credit with Moula or other credit providers and the amount of credit applied for;
- that Moula, or another credit provider, is a current credit provider of yours and details of the type, characteristics and amount of credit provided to you;
- information regarding the fact that Moula has accessed your consumer credit information in connection with its assessment of an application for commercial credit;
- details of you defaulting on a repayment being at least 60 days overdue and over $150 in value;
- information about you having paid any amount previously reported as being in default;
- information about whether you have entered into a new arrangement with Moula or another credit provider in relation to credit provided to you by Moula or another credit provider;
- details of credit provided to you by Moula or another credit provider being paid or otherwise terminated;
- personal insolvency information, court judgments or other publically available information about your creditworthiness;
- information regarding an opinion of another credit provider, that you have committed a serious credit infringement in relation to consumer credit provided to you by that credit provider; and
- information that we obtain from credit reporting bodies about you such as reports, records, credit scores or assessments and any information that we then derive from that information which has a bearing on your creditworthiness (such as internal credit scores, assessments, summaries or evaluations).
Purposes for which we use and disclose credit and credit eligibility information.
Moula collects, holds, uses and/or discloses credit and related information about you for the purpose of assessing your application for commercial credit, and if successful to manage your commercial credit account (including collecting any overdue payments). We may also collect, hold, use and/or disclose this information to:
- assess whether to accept you as a guarantor in relation to commercial credit;
- inform our agents or debt collectors for the purpose of collecting overdue payments;
- notify credit reporting bodies or other credit providers of a default in relation to commercial credit provided to you by Moula;
- assist or seek to assist you in avoiding defaulting on repayment obligations;
- exchange information with credit reporting bodies such as Illion, Equifax and Experian;
- provide a reference to another credit provider or receive a reference from another credit provider in relation to assessing an application by you for commercial credit;
- comply with our obligations under Australian law, including under the Privacy Act and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
- if you apply for a loan through any of our referral programs, to administer those programs.
Disclosure to and by credit reporting bodies.
Moula may generally disclose to credit reporting bodies the following information about you:
- identification details;
- that you have applied for commercial credit with Moula and the amount of credit required;
- that Moula is a current commercial credit provider to you;
- whether you have met, or failed to meet, your repayment obligations to Moula;
- details of you defaulting on a repayment in relation to commercial credit provided to you by Moula;
- you having paid any amount previously reported as being in default;
- details of credit that Moula has provided to you being paid or otherwise terminated.
A credit reporting body to whom Moula discloses your credit information, may include that information in reports that are then provided to other credit providers for the purpose of those providers assessing your credit worthiness, including in relation to consumer credit.
The credit reporting bodies that we deal with are Equifax and Illion, who can be contacted using the following details:
Pre-screening for direct marketing and fraud
Please note that you can contact credit reporting bodies directly to request that they do not use credit reporting information about you for the purpose of pre-screening for direct marketing by a credit provider, or that they do not use or disclose credit reporting information about you if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.
Access to your credit and related information
To ensure you have access to the most up-to-date credit and related information about you, consider requesting access to the information which credit reporting bodies hold about you.
Generally you are also entitled to access the credit eligibility information which Moula holds about you. We will need to verify your identity before we can provide access. We will endeavour to respond to all requests for access within 30 days of the request. Please note that we may need to charge you our reasonable costs of providing you with access.
We may, however, refuse a request for access in circumstances permitted by the Privacy Act such as if providing access would be unlawful, if we are required or authorised to do so by or under an Australian law or court/ tribunal order, or if giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body. If we refuse your request, we will notify you in writing of our reasons (unless it would be unreasonable to do so) and explain how you can take the matter further.
Correction of your credit and related information
You are also able to request correction of the credit information and credit eligibility information we hold about you. We will need to verify your identity before we can make any corrections.
If we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct the information within 30 days of your request, or another period we agree with you in writing. In considering your request, we may need to consult with a credit reporting body or other credit provider that holds or held the relevant information about you. If we correct your information we will confirm this in writing (and we will also notify any credit reporting body or credit provider with whom we have consulted in relation to the correction). If we are not satisfied that a correction is required, we will confirm this in writing and explain why, including evidence showing the information is correct. We will also explain what you can do if you are not satisfied with our response.
We will also take reasonable steps to correct information independently of any request from you, if we are satisfied that, having regard to the purpose for which it is held, the information is inaccurate, out-of-date, incomplete, misleading or irrelevant.
Complaints or queries
If you are concerned that we may not have acted in accordance with our obligations as a credit provider under the Privacy Act or the registered Credit Reporting Code, please contact our Privacy Officer at firstname.lastname@example.org.
We may need to verify your identity and we will, within 7 days, acknowledge your complaint in writing and explain how we will deal with and investigate it. Depending on the nature of your complaint and the information to which it relates, we may need to consult with and/or notify particular credit reporting bodies or other credit providers.
We will make a decision about your complaint following our investigation, and will advise of this in writing within 30 days or such longer period as we agree with you in writing.
If you are not satisfied with our decision, you can take your complaint to either:
Last updated: February 2018