Privacy & Credit Policies

Leda® is a registered trademark of Leda Universal Pty Ltd (ABN 89 655 964 177). Leda Universal Pty Ltd (Leda) operates a business providing financing facilities to the small and medium enterprise business community. Leda does not provide consumer credit or consumer finance. All financing facilities provided by Leda are for business purposes only. Leda may update or amend this Privacy Policy and Credit Policy from time to time. Leda will provide prior notice on its website (or by such other form of communication as may be appropriate) before making any changes to this Privacy Policy that are likely to materially impact your use of the services provided by Leda

Your personal information will always be handled by Leda in accordance with our Privacy Policy and the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy sets out Leda’s policies on the management of personal information including how Leda collects personal information, the purposes for which Leda uses information, and to whom this information is disclosed.

Leda collects personal information from people who are customers or potential customers (i.e. borrowers), from referrers and merchants under our referral program, 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.

Personal information is any information or an opinion, whether true or not, about you that identifies you, or from which you are reasonably identifiable.

When you visit the Leda website, apply to be a merchant or apply for finance, or use your Leda facility, 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 Leda website, apply for finance or use your Leda 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, or intermediary), information about you provided by that third party;
• information that you provide to Leda in your finance application (even if your application is ultimately rejected by Leda);
• where you have applied for finance, information about your credit history which Leda collects from third parties, including credit bureaus and credit reporting agencies; and
• when you use your Leda facility, your transaction information.

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.

The primary purpose for which Leda collects personal information is so that it can carry out its business of 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 finance loan application process and service and the content, layout and operation of our website and 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);
• for the purposes of analytics and data modelling; and
• to comply with our legal and regulatory requirements.

Generally, you have no obligation to provide Leda 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.

From time to time, we may 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 info@leda.inc.

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 info@leda.inc.

When you access our website, we may use software embedded in our website (such as JavaScript) and we may place small data files (or cookies) on your computer or other device to collect information about which pages you view and how you reach them, what you do when you visit a page, the length of time you remain on the page, and how we perform in providing content to you. We do not presently associate such information with an identifiable person and so the collection of such information is not personal information. 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 Leda services. You can refer to the ‘help’ section of your browser or installed applications for instructions on blocking, disabling or deleting cookies. This privacy policy applies to our website and not any linked sites which are not operated or controlled by us. We encourage you to read the privacy policies of each website that collects your personal information.

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, financing, marketing, direct debit services (for example, Westpac) 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)
• Merchants and third parties: we may provide your personal information for the purposes of facilitating your application, or transactions. Where you have been referred to us by a merchant or other third party, we may share your personal information for the purposes of research, analytics and marketing.
• 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.
• 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 Leda by a third party under Leda’s Commercial Referral Program or other referral programs (such as Leda’s merchant referral program), or have accessed the Leda 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 Leda) may be shared by Leda with the relevant third party referrer for the purposes of loan assessment and administering the relevant Leda third party referral program.

Your personal information will be stored on a password-protected electronic database, which may be a Leda 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 Leda. 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. Your personal information will stay on the database for as long as we need it to carry out the purposes described in this Privacy Policy. After this time, we will either de-identify it or destroy it in accordance with privacy law requirements.

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 Leda staff only. Except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth). Please notify us immediately if you become aware of any breach of security.

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.

Leda 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.

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 info@leda.inc

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.

If you have any queries or complaints about our handling of your personal information in accordance with privacy laws or for further information about Leda’s Privacy Policy, please contact our Privacy Officer at info@leda.inc. If you are contacting us to complain about an alleged breach of this Privacy Policy or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we made need.