Credit Reporting Policy (Consumer Finance)

Breeze Capital Pty Ltd ACN 147 671 949

Breeze Payment Plans Pty Ltd ACN 665 267 792

Breeze Living Pty Ltd t/as Breeze Finance ACN 665 265 592

Automated Collections Services Pty Ltd ACN 144 738 796
(and our related businesses)

About this Policy

This Credit Reporting Policy explains how Breeze Finance manages credit-related information in accordance with the Privacy Act 1988 (Cth), including Part IIIA (Credit Reporting), and the Privacy (Credit Reporting) Code 2014 (CR Code).

This policy outlines:

• how we collect, use, disclose, and manage credit-related information
• how we ensure the accuracy and integrity of credit information
• how individuals may access and request correction of their credit information
• how complaints and disputes are handled

Our Corporate Structure and Responsibility

Credit Provider (Legal Responsibility Holder)

Breeze Capital Pty Ltd (ACN 147 671 949) is the credit provider for the purposes of the Privacy Act 1988 (Cth).

Breeze Capital Pty Ltd is solely responsible for compliance with Part IIIA of the Privacy Act, including:

• reporting credit information to credit reporting bodies
• ensuring credit information is accurate, up to date, complete, and not misleading
• managing requests for access and correction of credit information
• compliance with the Privacy (Credit Reporting) Code 2014
• responding to credit reporting disputes and investigations

Loan Management and Customer Brand

Breeze Living Pty Ltd (ACN 665 265 592), trading as Breeze Finance, provides loan management and customer-facing services on behalf of Breeze Capital Pty Ltd.

These services include:

• loan onboarding and account administration
• customer communications and support
• coordination of loan servicing activities
• operational support for credit reporting processes

Breeze Living Pty Ltd does not act as a credit provider for the purposes of the Privacy Act 1988 (Cth).

Loan Servicing and Collections Provider

Automated Collection Services Pty Ltd (ACN 144 738 796) provides servicing and collections support services on behalf of Breeze Capital Pty Ltd.

These services may include:

• arrears and collections management
• administrative loan servicing support
• assistance with credit reporting operational processes
• coordination of dispute investigation workflows

All activities are performed on behalf of Breeze Capital Pty Ltd.

Responsibility Clarification

Notwithstanding any outsourcing or delegation of operational functions:

• Breeze Capital Pty Ltd remains solely responsible for all credit reporting obligations under the Privacy Act 1988 (Cth) and the CR Code
• operational functions performed by related entities or service providers do not transfer or reduce statutory responsibility
• In some cases, credit reporting bodies may display the name of an authorised servicing or reporting agent (such as Automated Collection Services Pty Ltd) in enquiry or account metadata fields due to system or character limitations; this does not affect or change the identity of Breeze Capital Pty Ltd as the credit provider responsible for the credit account and related credit reporting obligations.

Scope

This Policy applies to:

• applicants for consumer credit
• current and former consumer credit customers
• credit information we obtain from or disclose to credit reporting bodies
• credit reporting information we hold or use in connection with consumer finance

Types of Credit Information We Handle

We may collect, hold, use and disclose the following credit-related information:

• identification information
• credit application information and enquiries
• consumer credit liability information
• repayment history information (RHI)
• default information (where permitted under law)
• hardship arrangement information (where applicable and permitted)
• credit eligibility information received from credit reporting bodies
• information derived from credit reporting data
• fraud prevention and identity verification information

We only collect and use credit information that is reasonably necessary for our consumer lending functions.

Sources of Credit Information

We obtain credit information from:

• credit reporting bodies (Equifax, Illion, Experian)
• credit applications and supporting documentation provided by you
• internal account and repayment systems
• identity verification and fraud prevention services
• other credit providers (where permitted by law)

Use of Credit Information

We use credit information to:

• assess consumer credit applications
• verify identity and prevent fraud
• manage existing credit accounts
• monitor repayment performance
• meet legal and regulatory obligations
• comply with credit reporting obligations under Part IIIA

We do not use credit information for unrelated purposes.

Disclosure of Credit Information

We may disclose credit information to:

• credit reporting bodies (Equifax, Illion, Experian)
• service providers assisting with credit assessment or account management
• other credit providers (where permitted by law)
• internal staff and authorised representatives
• professional advisers (legal, accounting, compliance)
• regulators or law enforcement where required or authorised by law
• entities involved in sale, assignment or transfer of finance assets or business operations

We take reasonable steps to ensure disclosures are made in accordance with applicable legal requirements.

Credit Reporting Bodies

We may exchange credit information with:

• Equifax
• Illion
• Experian

These credit reporting bodies may use credit information to:

• maintain credit reports
• provide credit reporting services to other credit providers
• support fraud prevention and credit assessment functions as permitted by law

Accuracy and Data Quality

We take reasonable steps to ensure that credit information we report is:

• accurate
• up-to-date
• complete
• relevant
• not misleading

Our controls include:

• validation of account and repayment data prior to reporting
• review of account status before reporting defaults
• internal reconciliation processes
• investigation of discrepancies raised by customers or credit reporting bodies

Where we identify incorrect information, we take reasonable steps to correct it.

Access to Credit Information

You may request access to credit information we hold about you.

We will:

• verify your identity
• respond within a reasonable period in accordance with legal requirements
• provide access unless a legal exception applies

Requests should be made using the contact details in this Policy.

Correction of Credit Information

You may request correction of credit information you believe is:

• inaccurate
• out-of-date
• incomplete
• irrelevant
• misleading

We will:

• investigate your request in accordance with Part IIIA Division 5 of the Privacy Act 1988 (Cth)
• consult credit reporting bodies and relevant internal records where necessary
• determine whether correction is required
• notify you in writing of the outcome

Where appropriate, we will request credit reporting bodies update their records.

Credit Reporting Dispute Process

If you believe credit information we hold is incorrect or has been improperly handled, you may lodge a complaint with us.

We will:

• investigate your complaint in accordance with this Policy
• review internal records and supporting documentation
• consult credit reporting bodies where required
• keep you informed of progress
• provide a written outcome with reasons

Lodging a Dispute:

You may submit a credit reporting dispute by contacting our Privacy Officer.

Please include:

• your full name and contact details
• account details (if available)
• details of the information you believe is incorrect
• supporting documentation (if available)

Acknowledgement:

We will acknowledge receipt of your dispute within a reasonable time and may request additional information if required.

If correction is required:

We will take reasonable steps to:

• correct our records
• notify relevant credit reporting bodies
• ensure updated information is reflected where required

Investigation:

We will investigate your dispute by reviewing relevant internal records and, where necessary:

• consulting credit reporting bodies
• liaising with authorised service providers
• reviewing account and repayment information

All investigations are conducted under the authority of Breeze Capital Pty Ltd as the credit provider.

Timeframe:

We aim to resolve disputes within 30 days, unless an extension is permitted under the Privacy (Credit Reporting) Code 2014. If an extension is required, we will notify you.

Outcome:

We will notify you in writing of the outcome of your dispute, including:

• whether information has been corrected
• or why no correction is required

Where applicable, we will instruct credit reporting bodies to update their records.

External Escalation:

If you are not satisfied with the outcome, you may escalate the matter to:

• an external dispute resolution scheme (where applicable), or
• the Office of the Australian Information Commissioner (OAIC)

Defaults and Consumer Credit Reporting

We may report default information to credit reporting bodies where permitted under law.

We take reasonable steps to ensure:

• the debt is valid and payable
• required notices have been issued (where applicable)
• default amounts are accurate
• updates or removals are made where required

Where a default is disputed, we will investigate and take appropriate action under this Policy.

Hardship Information

Where applicable, we may record hardship arrangements in accordance with the Privacy Act and CR Code.

We ensure hardship information is:

• accurately recorded
• kept up to date
• corrected where arrangements change or conclude
• handled in accordance with legal requirements

Security of Credit Information

We take reasonable steps to protect credit information from:

• misuse
• interference
• loss
• unauthorised access, modification or disclosure

Safeguards include access controls, staff confidentiality obligations, encryption where appropriate, and system security protections.

Retention and Destruction

We retain credit information only for as long as necessary to:

• manage credit relationships
• comply with legal obligations
• meet credit reporting requirements

When no longer required, we take reasonable steps to securely destroy or de-identify the information.

Overseas Disclosure

We do not routinely disclose credit information overseas unless required for operational purposes and permitted by law.

Where overseas disclosure occurs, we take reasonable steps to ensure compliance with applicable Australian privacy requirements.

Relationship with Privacy Policy

This Credit Reporting Policy should be read together with our Privacy Policy.

In the event of any inconsistency, this Policy prevails to the extent of credit reporting information.

Availability of this Policy

This Policy is available on our website or upon request.

Contact Us

Operations Manager

Breeze Finance

PO Box 7795

Cloisters Square WA 6850

Alternatively you can call us on 1300 290 240

Review of Policy

We review this Policy periodically to ensure ongoing compliance with:

• the Privacy Act 1988 (Cth)
• the Privacy (Credit Reporting) Code 2014
• applicable regulatory guidance