Dated: January 2020

1. Introduction
This Privacy Policy sets out the policy of the Industrial and Commercial Bank of China (ICBC, ‘We’, ‘us' and ‘our' refers to Industrial and Commercial Bank Sydney Branch ARBN 57 086 866 506, AFSL 324233 and our related businesses).

This policy addresses the collection, use, disclosure and protection of personal information by ICBC and/or our related bodies corporate (including those in other jurisdictions), as well as how you can access and change your information, ask a question or make a compliant.

2. Our commitment to protect your privacy
We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.

The personal information we collect and deal with often relates to individuals in their capacity as officers or other representatives of a corporate client entity. We also deal with individuals in their capacity as shareholders and/or guarantors of corporate clients, and/or as holders of units in certain funds, and in these cases we also collect and deal with credit related information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.

3. Personal information
We collect personal information that is necessary for us to perform our functions and activities, in a manner which complies with the applicable laws and regulations. Unless it is unreasonable or impractical we will collect personal information directly from you.

When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.

Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

The kinds of personal information we may collect, use, disclose and retain includes:
1.Information about your identify – including name, date of birth, address, contact details, gender and marital status
2.Financial and transaction information
3.employment details
4.tax residency details and tax file numbers
5.identity verification details
6.complaint and enquiry details
7.Credit related information.
8.Other Personal Information, such as details of your interaction with us

4. Why we collect your personal information
We collect personal information for the purposes of assessing your application for finance and managing that finance. We may also collect your personal information for:
1.administer and promote our products and services to you or to an entity which you represent
2.comply with record keeping and reporting requirements
3.comply with laws, including to verify your identity and complete anti-money laundering and counter terrorism checks, and
4.Detect, prevent and investigate and prosecute crimes and illegal conduct.

If we are not provided with this personal information, we may not be able to fully provide our service to you or your connected entities.

5. How do we collect your personal information?
Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from credit reporting bodies and from finance brokers and other people such as accountants and lawyers.

6. How we usually use and disclose your personal information
Any personal information which we collect about you may be used by us for the purpose for which it was disclosed to us, or any related purposes. For instance, we may from time to time use your personal information to inform you of products and services which may be of interest to you or your connected entities.

We may disclose your personal information to:
1.other members of the ICBC Group, for purposes including to ensure their compliance with laws to enable us to tailor our products and services to meet your needs
2.other organisations that are outside of the ICBC Group who have agreements to provide products and services to the ICBC Australia Group and who we have a relationship with;
3.our agents, credit managers and related service providers who assist us in the management and administration of our services;
4.our other agents and service providers who provide various services, in connection with our products and services;
5.anybody who represents you, such as finance brokers, lawyers, and accountants;
6.anyone, where you have provided us consent;
7.regulatory bodies, government agencies, law enforcement bodies, courts and relevant dispute resolution schemes
8.participants in the payments system and other financial institutions for the purposes of resolving disputes or errors or other matters arising out of your use of ICBC Australia Group products.
9.investors, agents or advisers, or any entity that has an interest in your finance or our business;

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
a)the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
b)you have consented to us making the disclosure.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.

7. Credit information
We may collect, hold, use and disclose certain credit related information about individuals in the connection with our services. This credit information, may be disclosed to credit reporting bodies, and includes information that identifies you, and credit eligibility information.

We may collect and hold any type of credit-related information about individuals which is permitted under the Privacy Act, including:
1.Permitted identify particulars
2.Details of relevant product or service
3.Confirmation of previous information requests to credit reporting bodies made by third parties
4.Details of other credit providers to the individual and the terms of those arrangements
5.Permitted payment default information, including information about related payment arrangements and subsequent repayments
6.Other repayment history information
7.Information about serious credit infringements (fraud)
8.Information about adverse court judgements
9.Publically available information about the individuals creditworthiness
10.Certain insolvency information from the National Personal Insolvency Index; and
11.Any credit score or credit risk assessment indicating a credit reporting body’s or credit provider’s analysis of the individual’s eligibility for credit.

The information may be collected in a number of ways, such as obtaining it directly from you or from a person acting on your behalf.

We will use this information:
1.To assess an application by you, or a Connected Entity, for credit (including assessing any proposed guarantors)
2.To manage credit we may provide (including servicing and administration of our products)
3.To participate in credit reporting systems and providing information to credit reporting bodies as permitted by Part III A of the Privacy Act and the Credit Reporting Code;
4.For internal management purposes
5.To assist you if we consider that you may be at risk of defaulting on your credit related obligations
6.To undertake debt recovery and enforcement activities, including in relation to guarantors
7.To meet legal and regulatory requirements (such as reporting matters to regulators or enforcement bodies)
8.To deal with complaints and legal proceedings
9.To derive scores , ratings and other information relating to your credit worthiness which are used in our decision-making process; and
10.To assist other credit providers to do the same

This credit information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit information we hold about you.

We may disclose your credit information to ICBC China, and to other overseas entities that provide support functions to us. These entities are located in the People's Republic of China. You may obtain more information about these entities by contacting us.

8. Direct marketing
From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.

If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on (02) 9475 5500 or by writing to us at info@icbc.com.au or Level 42, Tower 1, International Tower, 100 Barangaroo Avenue, Sydney 2000. If the direct marketing is 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.

9. Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

10. Access and correction to your personal and credit information
On request by you, we will provide you with access to the personal and credit information we hold about you. You may request access to any of the personal information we hold about you during business hours. There is no fee to ask for your information but we might charge a fee to cover the cost we spend finding and putting together the information you want.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal or credit information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.

An explanation will be provided to you, if we deny you access to the personal or credit information we hold about you.

If any of the personal or credit information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit information within 30 days.

We may need to consult with other finance providers or credit reporting bodies or entities as part of our investigation.

If we refuse to correct personal or credit information we will provide you with our reasons for not correcting the information.

11. Using government identifiers
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

12. 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, for example, if you make general inquiries about interest rates or current promotional offers.

13. Sensitive information
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.

14. How safe and secure is your personal information that we hold?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

15. Data Breaches
In the unfortunate event that ICBC breaches your privacy data we will undertake an investigation of the matter and depending on the nature and seriousness of the breach notify you of the circumstances and risks associated with the breach. Specifically ICBC will assess whether the data breach is likely to result in serious harm. Should this occur we will also provide you with recommendations about the steps you are able to take in response to the breach.

16. Complaints
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act and the Credit Reporting Code, you may contact our complaints officer on 02 9475 5501 or via compliance@icbc.com.au.

We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.

If you are dissatisfied with the response of our complaints officer you may make a complaint to our External Dispute Resolution Scheme, the Australian Financial Complaints Authority (AFCA) which can be contacted on 1800 367 287, or you may go to the AFCA website for further contact details and how to lodge a complaint: https://www.afca.org.au/about-afca/.

Alternatively you may contact the Privacy Commissioner on either 1300 363 992 or at www.oaic.gov.au.