Privacy Policy 

1    OUR COMMITMENT TO PROTECT YOUR PRIVACY

This Privacy Policy sets out how Pepper Money (“we”, “us”, “our”) collects, uses and discloses personal information (including credit-related information) about you and how you can contact us if you have any questions about how your information is handled.

Pepper Money entities include:

  • Pepper Money Limited;
  • Pepper Asset Finance Pty Limited;
  • Pepper New Zealand Limited, at Oxford Edge Limited, 3a / 335 Lincoln Road, Addington, Christchurch, 8024 , New Zealand; and
  • other affiliate entities (“Pepper Money”).

This Privacy Policy applies to personal information that we collect, use and disclose in connection with:

  • use of Pepper Money’s website(s):
  • any enquiries or applications you make through the Website, or by email or telephone with us;
  • our assessment and processing of applications for credit or finance leases, and the ongoing administration of those arrangements;
  • our role as servicer of loan portfolios operated by other lenders;
  • our processing and assessment of information when investors invest funds with us; and
  • the provision and marketing of our products and services, (collectively, the “Services”).

This Privacy Policy also applies to information collected from candidates in connection with the application and recruitment process for employment with us. 

We are bound by the Privacy Act 1988 (Cth) (“Australian Privacy Act”), the Australian Privacy Principles (“APPs”) contained in the Australian Privacy Act, the Privacy (Credit Reporting) Code 2025, and other applicable laws in Australia. We are also bound by the Privacy Act 2020 (“NZ Privacy Act”), the Credit Reporting Privacy Code 2020, and any other applicable laws in New Zealand.

 

2    WHO IS PEPPER MONEY?

Pepper Money offers financial products and services, credit and finance leases to approved applicants. We act as servicer of loan portfolios operated by other lenders. 

 

3    WHAT INFORMATION DO WE COLLECT?

Personal Information

When we refer to personal information, we mean information or an opinion about you, from which you are, or may reasonably be, identified.

Personal information we may collect about you includes (but is not limited to): your name, date of birth, phone number, email address, address, preferences and interests about our products and services and other information relevant to customer surveys, social media, product research and/or offers.

If you are applying for a loan or provide a guarantee, the information may include: ages and number of your dependants and cohabitants; gender, date of birth, driver's licence card details, passport details, marital status, nationality, employment history, income, assets, liabilities and repayment history information and financial hardship arrangement information including whether you have made a financial hardship arrangement with us, the length of time you have resided at your current address; and your employment details and proof of earnings and expenses.

We will only collect health information from you or from your health care providers with your consent.

We may also collect credit-related personal information about you. Credit-related personal information means:

  • Credit information, which is information that includes your identity; the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information, financial hardship information (including information that any repayments are affected by a financial hardship arrangement), default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and 
  • Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.

Sensitive Information

Personal information also includes ‘sensitive information’. Due to the nature of the services provided by us, some of the information we collect may be sensitive information, including details about your race, ethnic background or health information and may include any information you tell us about any vulnerability you may have. For example,  if you are making a hardship application, we may also ask you about any medical conditions you may have.

Website Information

When you use the Website, we may collect information about your location or activity including IP address, telephone number and whether you have accessed a third-party site from the Website. We refer to this information as ‘website information’.

Some of this website information is collected using cookies (see section 13 ‘OUR WEBSITE’) and is used to improve our services and enhance your online experience with us and does not identify the internet browser. Where we do identify you (such as where a customer has logged onto one of our online services), we will treat any use or disclosure of that information in accordance with this Privacy Policy.

Employment candidate personal information

If you apply for employment with us or a member of Pepper Money, this Privacy Policy applies to the personal information that you share with us, or that is otherwise acquired by us indirectly, during the application and/or recruitment process, including but not limited to:

  • your name, address, email address, telephone number and other contact information;
  • personal information contained in your CV, resume, cover letter and other accompanying documents relating to your application;
  • personal information obtained from interviews and reference checks (including referee checks, national police check and an insolvency check); and
  • personal information obtained from publicly available sources.

Government Identifiers

We may collect personal information about you from government agencies, and if we collect government identifiers, such as your tax file number or Inland Revenue Department (IRD) number, we will not use or disclose this information other than as set out in this Privacy Policy or otherwise authorised by law. We will never use an Australian government identifier in order to identify you.

 

4    WHAT WE DO WITH INFORMATION WE DID NOT ASK FOR

Where we receive unsolicited information, we will check whether that information is reasonably necessary for our functions or activities. If it is, we will handle this information the same way described in this Privacy Policy. If not, we will ensure we de-identify it or destroy it.  

 

5    WHY WE COLLECT YOUR INFORMATION

We collect your information for the primary purpose of providing and improving the Services. This enables us to:

  • verify your identity;
  • share your information with credit reporting bodies and carry out credit checks with them to assess your borrowing position;
  • assess and obtain approval for loans and other products;
  • accredit you as an aggregator, broker or introducer of loans and other products (if applicable);
  • accept investments; and
  • assess whether to make a loan to a borrower where you have offered to act as guarantor.

From time to time, we also collect your information for a secondary purpose (in addition to the primary purpose). Information may be applied towards a secondary purpose if the secondary purpose is related to a primary purpose of collection and the use or disclosure would be within your reasonable expectations. Relevant secondary purposes arising in connection with this privacy policy may include (without limitation) to:

  • comply with our legal obligations; 
  • maintain and improve our services and products;
  • direct marketing (see section 11);
  • complaints handling or data analytics purposes;
  • providing customer service and support, including through digital communication channels such as online messaging, chat services and automated systems (for example chatbots or voice bots);
  • assisting with account management and servicing activities, including communicating with customers regarding their accounts or overdue payments;
  • conduct data matching exercises of existing customer databases with marketing, advertising, and data matching service providers for the purposes of delivering marketing across certain online digital mediums such as social media and other digital platforms such as Google;
  • carry out the application and recruitment process, which includes, but is not limited to, assessing your application and skills, identifying you, verifying your information, conducting reference checks (including referee checks, national police checks and insolvency checks), and complying with all applicable laws and regulations;
  • monitoring and reviewing communications (including calls, chats and messages) for quality assurance, training, compliance and service improvement purposes, including generating transcripts or communication analytics;
  • detecting, investigating and preventing fraud, scams or other unlawful activity;
  • improving our products, services, customer experience and operational processes, including through data analytics and the development or improvement of automated systems used to support our services; and
  • developing, testing, training and improving technology systems used to support our business operations, including artificial intelligence (AI) or machine-learning systems used for customer communications, fraud detection, analytics or service delivery.

 

6    HOW DO WE COLLECT YOUR INFORMATION?

Personal information may be collected by us in a number of circumstances, including when an individual:

  • makes an enquiry with us via email or telephone;
  • visits our website;
  • contacts us through our digital services and communication channels, including online forms, email, telephone conversations, online messaging services and automated chat or voice systems (such as chatbots);
  • lodges a loan enquiry or requests a quote through our website;
  • applies to invest in a product offered by us;
  • applies to be a borrower or guarantor or a lessee under a finance lease;
  • attends an event hosted by us;
  • applies for employment with us;
  • participates in other activities we offer, such as competitions or surveys; or
  • applies for accreditation as an aggregator, broker or introducer of loans or other products.

We will also collect information about you from third parties, including:

  • contractors who supply services to us;
  • recruiters;
  • introducers (such as brokers and dealers);
  • referrers;
  • credit reporting bodies;
  • publicly available registers and records; and
  • other individuals or organisations where you have authorised them to provide information to us.

From time to time, we may also purchase lists containing personal information about individuals from organisations offering such lists for marketing purposes. We will use and disclose such information in accordance with this Privacy Policy.

If you do not provide the information requested by us, we may not be able to provide you with our Services.

If you provide personal information to us about another individual, you must ensure that you are authorised to disclose that information to us and that, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, in particular, the name and address of Pepper Money and the purposes of collection of their information.

We may also collect credit-related personal information about you as a result of credit checks that you authorise us to carry out.

The kinds of credit-related personal information we may collect about you includes:

  • information about your identity;
  • information about consumer credit loans that you have applied for or currently have including repayment history information and financial hardship arrangement information including whether you have made a financial hardship arrangement;
  • the type and amount of credit sought in each application;
  • default and payment information;
  • information about any court proceedings;
  • information about your personal insolvency; and
  • credit eligibility information, being credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.

 

7    USE OF ARTIFICIAL INTELLIGENCE AND AUTOMATED SYSTEMS

We may use automated technologies, including AI systems, to assist us in providing services and communicating with customers.

These technologies may include automated chat, messaging or voice systems (for example chatbots or voice bots) used to assist with customer enquiries, account servicing and communications regarding accounts, including overdue payments.

Where these systems are used:

  • they may collect personal information that you provide during the interaction;
  • interactions may be recorded, analysed or converted into transcripts for quality assurance, training and system improvement purposes;
  • information from interactions may be used to develop, test or improve automated systems used by us to support customer communications or service delivery; and
  • automated responses may be generated using information you provide and information we hold about your account.
  • Where appropriate, our staff may review or monitor interactions involving automated systems to help ensure the accuracy, quality and appropriateness of responses.

 

8    AUTOMATED DECISION MAKING

When you apply for one or more of our products and/or services, we may use computer-based systems to process the personal information you provide through our application and origination platforms. These systems may be used to assist in, or directly make, decisions in relation to your application.

These computer-based systems may:

  • perform income and expense verification (including responsible lending assessments such as Household Expenditure Measure benchmarking);
  • support “know your customer” (KYC) and identity verification processes; and
  • generate an outcome in relation to your application, which may include a decision to accept, refer, or reject your application for our products and/or services.

Where a decision is generated by a computer-based system, that decision may be used solely by us, or may be used in conjunction with human review and further assessment. In some cases, a “refer” outcome will require additional review, investigation, or the provision of further information before a final decision is made. Accordingly, any initial outcome generated by the system may not represent the final determination of your application.

The kinds of personal information that we use in the operation of such computer-based software is as follows:

  • identity information
  • financial information; and
  • credit history.

The systems used may be involved in:

  • decisions made solely by computer-based processes;
  • decisions that are assisted by computer-based processes (including where such processes substantially and directly inform or influence decision-making); and
  • the collection, analysis, and assessment of information used to support lending and identity verification decisions.

We will review and override system-generated outcomes where appropriate, including where further information is required or where additional verification is necessary.

 

9    HOW DO WE HANDLE YOUR PERSONAL INFORMATION?

We will use and disclose your personal information for the purposes as set out in this Privacy Policy, as well as purposes that are directly related, where you would reasonably expect us to. We may disclose your personal information to and/or collect your personal information from:

  • organisations that provide products or services used or marketed by us, including other credit providers, introducers (such as mortgage brokers, brokers and dealers), funders, lenders, valuers, trustee companies, financial institutions and securitisers, mortgage insurers, re-insurers, title insurers, surveyors, credit reporting agencies, rating agencies and debt collectors, security registration bodies, health care providers (where relevant to a hardship application), and other persons with an interest in property offered to us as security;
  • your employer/s or referees, your guarantors, your professional advisors, your bank and any other organisation that may have or is considering having an interest in your loan, or in our business;
  • other guarantors or borrowers (if more than one);
  • companies and contractors who we retain to provide services for us, such as IT contractors, call centres, payroll providers, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your personal information to provide those services;
  • anybody who represents you, such as introducers (including brokers and dealers), lawyers, guardians, persons holding power of attorney and accountants;
  • people considering acquiring an interest in our business or assets;
  • organisations involved in a corporate re-organisation or transfer of Pepper assets or business;
  • third parties, including government agencies and regulatory bodies where we are authorised to do so by law, such as under the Anti- Money Laundering and Counter Terrorism Financing Act 2006 (Cth) in Australia, and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 in New Zealand;
  • other financial institutions, for example to process a claim for mistaken payment;
  • external technology service providers that support our technology systems, including providers of AI, data analytics, communication platforms, cloud hosting and other IT services, who may process personal information on our behalf in order to provide those services;
  • associated businesses that may want to market products to you;
  • third parties to perform ad measurement services on your behalf;
  • third parties that may assist with verifying identification documents provided by you and fraud prevention, including optical character recognition (OCR);
  • other individuals or companies authorised by you; and
  • to anyone where you have provided consent.

By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case by case basis.

Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office and Inland Revenue Department in New Zealand.

 

10    OVERSEAS DISCLOSURE AND STORAGE

Sometimes, for the same purposes as set out in this Privacy Policy, we may need to provide your personal information to, or get personal information about you from, persons or entities located outside Australia and New Zealand. These countries privacy laws may not provide the same level of protection as Australia or New Zealand’s privacy laws. By providing us with your personal information, you consent to this disclosure.

We may store your personal information at our service providers’ data centre across the Asia-Pacific, European Union or the United States of America (although from time to time, there may also be other countries between which we may need to store your information). This includes where we may store information about you in the cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries through an internet connection, it is not always practical to know in which country information about you may be held.

We will ensure that appropriate safeguards are in place to protect your personal information to the extent it is transmitted outside Australia and New Zealand, through adequate protection mechanisms (consistent with the Australian and NZ Privacy Acts and with the European Commission’s Standard Contractual Clauses (for data transfers between EU and non-EU countries), as may be relevant.

 

11    DIRECT MARKETING

From time to time, we may use the personal information collected about you for the provision of the Services to contact you (including via mail, SMS, email, telephone or online) about news, special offers, products and services that may be of interest to you. We will only use your personal information for the secondary purpose of direct marketing where:

  • we have collected your personal information;
  • it is reasonably expected that the information would be used for the purposes of direct marketing;
  • we provide a simple means through which you can request not to receive marketing communications; and
  • you have not requested that such communications cease.

Our direct marketing is conducted by using:

  • personal information collected directly from you for general marketing purposes, including competitions, surveys and similar promotional activities; and
  • personal information obtained from third-party sources, which may include purchased marketing lists compiled by third-party data providers.

Where we use personal information obtained from a third-party source for direct marketing purposes, we will ensure that each direct marketing communication includes a simple and functional means by which you may opt out of receiving further communications from us and, provides details of the third-party source. We take reasonable steps to satisfy ourselves that the personal information obtained from third-party sources has been lawfully collected and that its use for direct marketing is permitted.

Pepper may use personal information it already holds about you to tailor and improve the relevance of its marketing communications.

You can contact us to update your marketing preferences at any time by using the Pepper privacy contact details described in section 18 ‘FURTHER INFORMATION AND COMPLAINTS’ if we are sending you direct marketing by email, you may also use the unsubscribe function.  We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

 

12    CREDIT-RELATED PERSONAL INFORMATION

Statement of notifiable matters

The law requires us to advise you of 'notifiable matters' in relation to how we may handle your credit-related information. You may request to have these notifiable matters (and this Privacy Policy) provided to you in an alternative form.

Credit checks and your credit score

Australia:

If you are applying to us for consumer credit (including a new credit account or to increase the limit on an existing credit account in Australia, we can do a credit check without asking for your consent.

If you are applying for commercial credit, or if you are a guarantor in relation to an application for credit, we may carry out a credit check about you with your consent. 

New Zealand:

If you apply to us for consumer credit (including a new credit account or to increase the limit on an existing credit account) or a commercial credit account or if you are a guarantor in relation to an application for credit, we may carry out a credit check about you with your consent. 

A credit check is when we ask a credit reporting body for information about the loans you’ve applied for and taken out in the past, and how you’ve managed those loans.

The credit reporting body will record the fact that we have done a credit check.  This will show on your credit report as a ‘credit enquiry’ (also known as an ‘information request’).  The enquiry may be disclosed to other credit providers, and used and disclosed by the credit reporting body or a credit provider, including in the calculation of a credit score.

When a credit enquiry is recorded on your credit report, it can affect your credit score in different ways.  It might go up, down, or stay the same.  This depends on factors like the type of credit you’re applying for, how many other credit checks you’ve had recently, and other details in your credit report.  An enquiry is more likely to lower your credit score if you make a lot of credit applications in a short time.

The information we may access includes your repayment history information, which shows whether you have a history of making required payments on time (and whether any have been made after they are due), and financial hardship information.

We may exchange your personal information and credit-related information with credit reporting bodies. We use the credit-related information that we exchange with the credit reporting body to confirm your identity, assess your creditworthiness, assess your application for finance or your capacity to be a guarantor and manage your finance. 

The credit reporting body may hold on their credit reporting databases the personal information and credit-related information that we provide to them, and use and disclose that information in relation to the credit products you have with us to other credit providers to assist them to assess your credit worthiness or for any other lawful purpose, including debt collection. We may also obtain information that other credit providers have provided to the credit reporting body to use in our assessments of your credit-worthiness.

The information that we can exchange includes your identification details, what type of loans you have, how much you have borrowed, whether or not you have met your loan payment obligations and if you have committed a serious credit infringement (such as obtaining credit by fraud). 

If you fail to meet your payment obligations in relation to any loan that we have provided to you, or any loan that we have arranged for you, or if you commit a serious credit infringement, we may disclose this to the credit reporting body.

You may access the credit information that we hold about you. Please refer to the section 15 ‘HOW TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION’. You may also request that we correct any credit information that we hold about you if you believe the information is out-of-date, incomplete, or incorrect. Please refer to the section 14 ‘UPDATING YOUR PERSONAL INFORMATION’.

The information that we provide to a credit reporting body may sometimes be used for ‘credit pre-screening’ of direct marketing offers to be made by another credit provider. You have the right to request the credit reporting body to not use your credit-related information in this way. To opt-out of credit pre-screening, contact the credit reporting body using the contact details noted below.

You may also contact the credit reporting body to request that they not to use or disclose the personal information (including credit related information) they hold about you if you consider that you may have been or are likely to have been a victim of fraud or if you believe on reasonable grounds that the information, they hold about you is out-of-date, incomplete or incorrect. In Australia, credit reporting bodies must not use or disclose your credit-related information for a period of 21 days after you notify them that you may have been a victim of fraud. In New Zealand, you can request from credit reporting bodies to suppress your credit information for 10 working days, and you can ask for an extension of this period if you think the fraud is ongoing.

For further information, contact the following credit reporting bodies at:

Australia

New Zealand

 

13    OUR WEBSITE

Information from third parties

Our website may contain links to the websites of third-party providers of goods and services (Third Party websites). If you have accessed Third Party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.

Where you access a Third-Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.

Advertising and tracking

When you view our advertisements on a Third-Party website, the advertising company uses 'cookies' and in some cases 'web beacons' to collect information such as:

  • the server your computer is logged onto;
  • your browser type;
  • the date and time of your visit; and
  • the performance of their marketing efforts.

When you access our website after viewing one of our advertisements on a Third-Party website, the advertising company collects information on how you utilise our website (e.g. which pages you view) and whether you complete an online application.

Cookies

We use ‘cookies’ to provide you with better and more customised service and with a more effective website.

A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites, and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.

We use cookies for different purposes such as:

  • for security purposes;
  • to allocate a unique number to your internet browsers;
  • to customise our website and offers for you;
  • for statistical purposes; and
  • to identify if you have accessed a Third-Party Website.

IP Addresses

Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.

Online Applications and enquiries

When you send a completed online application or enquiry to us, we retain the information contained in that application or enquiry. We are able to then use that information to provide any services that you require.

 

14    UPDATING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you or any other person is accurate, up to date, and complete. Please let us know us as soon as you can if there have been any changes to the information you have provided us with, or if you believe that the information we hold about you may be inaccurate or incomplete. During the course of our relationship with you we may also ask you to inform us if any of your personal information has changed.

 

15    HOW TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION

You may request access to and correction of the personal information we hold about you, including any credit-related personal information. To make a request, please contact us using the Pepper privacy contact details set out in section 18 ‘FURTHER INFORMATION AND COMPLAINTS’.

Before providing access to your personal information, we may need to verify your identity. We will respond to your request within a reasonable period. We may charge a reasonable fee to cover the costs of retrieving and providing the information to you.

There may be circumstances where we are not required to provide you with access to personal information. For example, access may be refused where the information relates to existing or anticipated legal proceedings, or where a request is considered frivolous or vexatious. If we refuse or restrict access, we will provide you with written reasons for that decision.

Where appropriate, we may correct the information at the time of your request. Otherwise, we will provide an initial response within seven (7) days of receiving your request and will notify you within twenty (20) working days of our decision on your request.

As part of considering your request, we may need to consult with other finance providers, credit reporting bodies, or other relevant entities. If we refuse to correct the information, we will provide you with written reasons for our decision.

Where we have previously disclosed the information to another entity and a correction is made, we will take reasonable steps to notify that entity of the correction where appropriate.

 

16    BUSINESS WITHOUT IDENTIFYING YOU

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.

 

17    HOW SAFE AND SECURE IS YOUR PERSONAL INFORMATION THAT WE HOLD?

We will take reasonable steps to protect your personal information, including your credit-related personal information, by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed, permanently de-identified or put beyond use as soon as it becomes practically possible.

We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

 

18    FURTHER INFORMATION AND COMPLAINTS

If you would like further information about how we manage your personal information, or if you wish to make a complaint about a potential breach of your privacy, you may contact our Privacy Officer using the details below.

We will acknowledge and investigate any complaint you make about the handling of your personal information. We aim to provide a response within 15 working days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will notify you to seek to agree an alternative timeframe.

 

19    PEPPER PRIVACY CONTACT DETAILS

You can contact us by telephone, email or in writing using the details below:

The Privacy Officer
Pepper Money Limited
PO Box 6186
NORTH SYDNEY NSW 2060
Telephone: Australia: 1300 650 931  | New Zealand: 0800 945 658
Email: Australia: privacyofficer@pepper.com.au  |  New Zealand: privacy@peppermoney.co.nz.

 

20    EXTERNAL COMPLAINT BODIES

If you are dissatisfied with our response to your complaint, you may refer the matter to the relevant external privacy regulatory authority:

  • Australia | Office of the Australian Information Commissioner
    Phone: 1300 363 992
    Website: www.oaic.gov.au
    Mail: GPO Box 5218 Sydney NSW 2001

Further, you may also complain to our external Dispute Resolution Scheme  which can be contacted on the following:

  • Australia | Australian Financial Complaints Authority
    Phone: 1800 931 678 (fre call)
    Website: www.afca.org.au
    Mail: Australian Financial Complaints Authority, GPO Box 3, Melbourne, VIC 3001

 

21    CHANGES TO THIS PRIVACY POLICY

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market practices.

As a consequence, we may change this Privacy Policy from time to time. We will post any changes to this policy on our website. You may request this policy in an alternate form by contacting the Privacy Officer using the Pepper privacy contact details set out in section 18 ‘FURTHER INFORMATION AND COMPLAINTS’.

This Privacy Policy was last updated on 19 May 2026.

In addition, over the course of our relationship with you, we may tell you more about how we handle your information. This could be when you complete an application or form. We recommend you review these statements as they may have more specific details for your product holding.

 

22    DATA BREACH NOTIFICATION

In the event of a data breach (for Australia, being an eligible data breach as defined in the Australian Privacy Act, and for New Zealand, a notifiable privacy breach as defined in the NZ Privacy Act), we will:

  • comply with our obligations under the Notifiable Data Breaches scheme under the Australian and NZ Privacy Acts, including promptly investigating the breach;
  • where required, prepare a statement outlining the breach and provide it to the relevant privacy regulator (for Australia, OAIC, and for New Zealand by way of an online notice to the New Zealand Privacy Commissioner), and notify affected individuals; and
  • include details in that statement about the nature of the breach, the types of information involved, steps we recommend you take to protect yourself, and how you can contact us for further information.

If you have any questions about how we manage data breaches, please contact us by using the Pepper privacy contact details set out in section 18 ‘FURTHER INFORMATION AND COMPLAINTS.’

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