Credit Reporting Policy

STELLA / STELLA STARPASS — Navun Pty Ltd

This Credit Reporting Policy is published by Navun Pty Ltd (ACN 649 693 434), trading as Stella Mgmt and STELLA STARPASS ("we", "us", "our"), in accordance with section 21C(3) of the Privacy Act 1988 (Cth) and the Privacy (Credit Reporting) Code 2024 ("CR Code"). It explains how we collect, hold, use and disclose credit information about individuals to whom we provide deferred payment of fees, and the rights those individuals have in relation to that credit information.

This Policy should be read together with our Privacy Policy, which sets out our general personal-information handling practices, and the STELLA STARPASS Terms and Conditions, which set out the contractual terms governing payment plans and default listing (including Section 4.17 thereof).

  1. OVERVIEW
    • We are bound by Part IIIA of the Privacy Act 1988 (Cth), the Australian Privacy Principles, and the CR Code.
    • This Policy describes the credit information and credit eligibility information we hold about individuals who enter into payment plans, instalment arrangements, or other deferred-payment arrangements with us, and how that information is managed.
    • In this Policy, "you" means an individual to whom we provide consumer credit (including by allowing you to defer payment of any fee for 7 days or more), and "we", "us", "our" means Navun Pty Ltd and its trading names.
  2. CREDIT PROVIDER STATUS
    • Where we offer you deferred payment of fees over a period of seven (7) days or more (including any payment plan, instalment arrangement, or subscription — including in connection with the Talent Deposit, STELLA STARPASS membership, or any other product or service), we are a "credit provider" within the meaning of section 6G of the Privacy Act, and Part IIIA of the Privacy Act applies to credit information we hold about you.
    • The credit we provide is consumer credit; it is not regulated by the National Consumer Credit Protection Act 2009 (Cth) because the credit charge component of our payment arrangements does not exceed the limits set out in section 6 of that Act.
  3. CREDIT REPORTING BODIES WE MAY DEAL WITH
    • We may disclose credit information to, and collect credit information from, one or more of the following credit reporting bodies ("CRBs"):
      • Equifax Australia Information Services and Solutions Pty Limited (ABN 26 000 602 862) — equifax.com.au — Phone 13 83 32
      • illion Australia Pty Ltd (ABN 95 006 399 677) — illion.com.au — Phone 13 23 33
      • Experian Australia Credit Services Pty Ltd (ABN 70 142 762 175) — experian.com.au — Phone 1300 783 684
    • Each CRB has its own credit reporting policy explaining how it manages your credit reporting information. You can obtain a copy of each CRB's policy free of charge by visiting their website.
  4. CREDIT INFORMATION WE HOLD
    • The credit information we may hold about you includes:
      • Identification information — your full name, date of birth, current and previous addresses, employer details, and driver's licence number;
      • Consumer credit liability information — the type and amount of credit provided, the terms and conditions of the credit, account-open and account-close dates, and the maximum amount of credit available;
      • Repayment history information — information about whether you have met your monthly payment obligations under the credit arrangement, and the date on which any overdue payment was made;
      • Default information — information about payments overdue for at least 60 days where the overdue amount is $150 or more, disclosed only after a section 6Q notice and a separate section 21D notice have been issued in accordance with the Privacy Act;
      • New arrangement information — where we and you enter into a new credit arrangement to vary or replace an existing arrangement;
      • Payments to clear default information — information about subsequent payments made by you to clear an overdue amount previously listed as a default;
      • Court proceedings information — information about any judgment given in court proceedings to which you are a party that is relevant to consumer credit;
      • Personal insolvency information — information from the National Personal Insolvency Index;
      • Serious credit infringements — where we reasonably believe that you have committed fraud or shown a clear intention not to comply with your credit obligations.
  5. HOW WE COLLECT, USE AND DISCLOSE CREDIT INFORMATION
    • Collection. We collect credit information directly from you (when you apply for a payment plan, sign a Representation Agreement, or contact us about your account), from CRBs, from collection agencies and debt purchasers, and from other third parties such as fraud-check services and identity-verification providers.
    • Use. We use credit information to:
      • assess applications for credit (including any payment plan, instalment arrangement, or subscription with deferred payment);
      • manage your account, including communicating with you about payments due and overdue;
      • collect overdue amounts, including by issuing section 6Q and section 21D notices and engaging collection agencies and debt purchasers;
      • verify your identity and prevent or investigate fraud;
      • comply with our legal obligations (including under the Privacy Act and the CR Code);
      • deal with complaints and disputes, including with regulators such as the Office of the Australian Information Commissioner (OAIC) and the Australian Financial Complaints Authority (AFCA).
    • Disclosure. We may disclose credit information to:
      • CRBs (subject to the requirements of Part IIIA of the Privacy Act and the CR Code);
      • collection agencies, debt purchasers and our legal advisers (for the purpose of recovering overdue amounts);
      • payment processors (including Stripe), card networks, and issuing banks (for the purpose of processing transactions and responding to disputes);
      • courts, tribunals, and regulators (where required or permitted by law);
      • our related companies and prospective purchasers of our business or assets (in connection with corporate transactions and group operations).
    • We do not use or disclose credit reporting information for direct marketing purposes (other than as expressly permitted under Part IIIA, including pre-screening of direct marketing by us where you have not opted out under section 11 below).
  6. DEFAULT LISTING — PROCESS AND PRECONDITIONS
    • We will only disclose default information about you to a CRB where all of the following preconditions are satisfied:
      • the overdue amount is $150 or more;
      • the amount has been overdue for at least 60 days;
      • we are not statute-barred from recovering the amount;
      • we have issued a written notice under section 6Q of the Privacy Act to your last-known contact address (including by email where customary) requesting payment of the overdue amount; and
      • we have issued a separate written notice under section 21D of the Privacy Act, given at least 30 days after the section 6Q notice, advising you of our intention to disclose default information to a CRB if payment is not received within 14 days.
    • We will lodge any default listing with the chosen CRB within 90 days of the section 21D notice.
    • A default listing on a CRB's records may remain on your credit file for up to five (5) years (or seven (7) years for serious credit infringements) and may adversely affect your ability to obtain credit, finance, telecommunications services, utilities, or rental accommodation during that period.
    • If you pay the overdue amount after a default has been listed, we will notify the CRB so that the listing is updated to record that the default has been paid.
  7. COMPREHENSIVE CREDIT REPORTING & REPAYMENT HISTORY INFORMATION
    • Comprehensive credit reporting ("CCR") is the practice of reporting positive credit information (including repayment history information) to CRBs, in addition to negative credit information such as defaults.
    • We reserve the right to participate in CCR and to disclose repayment history information about you to CRBs in respect of any payment plan, instalment arrangement, or other consumer credit arrangement we provide. Where we participate in CCR, we will update this Policy to reflect that participation.
    • Repayment history information may only be disclosed to a CRB by a licensed credit provider; where we are not licensed under the National Consumer Credit Protection Act, we will not disclose repayment history information to a CRB.
  8. ASSIGNMENT OF DEBT
    • Where we assign, transfer, or sell a debt owed by you to a third-party collections agency or debt purchaser, we may disclose to that party such credit information as is reasonably necessary to enable recovery of the debt.
    • An assignee that is itself a credit provider may exercise the rights of a credit provider under Part IIIA of the Privacy Act, including the right to disclose default information to a CRB on the same basis as set out in section 6 above.
    • An assignee will be required to handle your credit information in accordance with the Privacy Act and the CR Code.
  9. ACCESS TO YOUR CREDIT INFORMATION
    • You have the right to request access to credit information we hold about you. You may also request access to credit reporting information held about you by any CRB by contacting that CRB directly.
    • To request access from us, please write to our Privacy Compliance Officer at stella@stellamgmt.com.au or by post to the address listed in section 18 below. Please include your full name, date of birth, current address, and proof of identity sufficient for us to verify the request.
    • We will acknowledge your request within 7 days and respond within 30 days. There is no charge for making a request, but we may charge a reasonable fee to recover the cost of providing access (such as photocopying or postage). We will tell you about any fee before we incur it.
    • We may decline to provide access in limited circumstances permitted by the Privacy Act (for example, where giving access would have an unreasonable impact on the privacy of others, would prejudice a fraud investigation, or where we are required by law to refuse access). If we decline, we will tell you the reason and how to complain.
  10. CORRECTION OF YOUR CREDIT INFORMATION
    • If you believe that credit information we hold about you is inaccurate, out-of-date, incomplete, irrelevant, or misleading, you may request that we correct it.
    • To request correction, please email stella@stellamgmt.com.au with details of the information you believe is incorrect and what you believe the correct information should be.
    • We will acknowledge your request within 7 days. We will investigate the request and respond within 30 days. If the information is held by, or has been disclosed to, a CRB or another credit provider, we will consult with them about the correction.
    • If we are satisfied that the information is incorrect, we will correct it free of charge and notify any CRB or other credit provider to whom we have disclosed the information. If we are not satisfied that correction is required, we will tell you the reasons in writing and how you can complain.
  11. PRE-SCREENING OPT-OUT
    • A CRB may use credit reporting information about you for the purpose of "pre-screening" of direct marketing by a credit provider (a process by which a CRB assesses whether you are eligible to receive direct marketing offers).
    • You have the right to request that a CRB not use your credit reporting information for pre-screening of direct marketing. To exercise this right, contact the CRB directly using the contact details set out in section 3 above.
  12. FRAUD OPT-OUT
    • If you reasonably believe that you have been, or are likely to be, a victim of fraud (including identity fraud), you have the right to request that a CRB not use or disclose your credit reporting information.
    • A CRB must comply with such a request for an initial period of 21 days, and may extend that period if it is satisfied that the request continues to be justified. To exercise this right, contact the CRB directly.
    • If you believe you have been the victim of fraud or identity theft in connection with credit obtained from us, please contact us immediately at stella@stellamgmt.com.au so we can investigate and take appropriate action.
  13. FINANCIAL HARDSHIP REQUESTS
    • If you are unable to meet your payment obligations because of illness, unemployment, or other reasonable cause, you may make a financial hardship request under Division 3 of Part IIIA of the Privacy Act.
    • To make a hardship request, please email stella@stellamgmt.com.au with the subject line "Hardship Request" and a brief description of your circumstances. We may ask for further information to assess the request.
    • We will acknowledge your hardship request within 7 days and respond within 21 days of receiving any further information we reasonably request. Where appropriate, we may agree to vary the terms of your payment plan, defer or reduce payments, or enter into a new arrangement.
    • Where we agree to a hardship arrangement, we will record this as "financial hardship information" in accordance with the CR Code. A hardship arrangement does not extinguish the underlying debt unless we expressly agree in writing.
    • If we decline a hardship request, we will give you a written notice explaining the reasons and how you can complain (see section 14 below).
  14. COMPLAINTS PROCESS
    • If you believe we have failed to comply with Part IIIA of the Privacy Act, the CR Code, or this Policy, you may make a complaint to us.
    • Step 1 — Complain to us. Email stella@stellamgmt.com.au with the subject line "Credit Reporting Complaint" and a description of the issue. We will acknowledge your complaint within 7 days, investigate, and respond in writing within 30 days.
    • Step 2 — Escalate. If you are not satisfied with our response, or if we have not responded within 30 days, you may complain to:
      • the Office of the Australian Information Commissioner (OAIC) — oaic.gov.au — Phone 1300 363 992; or
      • where the complaint relates to a credit-related financial service, the Australian Financial Complaints Authority (AFCA) — afca.org.au — Phone 1800 931 678.
    • If your complaint relates to information held by a CRB, you should first complain to the relevant CRB. If you are not satisfied with the CRB's response, you may escalate to the OAIC.
  15. OVERSEAS DISCLOSURES
    • We do not currently disclose credit information to overseas recipients.
    • If we hold credit information using cloud-based service providers (including Stripe and our internal IT systems), some processing may occur in the United States, the European Union, the United Kingdom, Canada, or New Zealand. Our service providers are required to handle credit information in accordance with the Privacy Act and the CR Code, and we take reasonable steps to ensure that any overseas disclosure is consistent with the Australian Privacy Principles.
  16. RETENTION AND DESTRUCTION
    • We retain credit information for as long as is required for the purposes for which it was collected, to comply with our legal obligations, to enforce our rights, or to defend any claims. The maximum periods for which credit information may be held by a CRB are set out in section 20W of the Privacy Act and the CR Code.
    • When credit information is no longer required, we will destroy it or de-identify it in accordance with the Privacy Act.
  17. CHANGES TO THIS POLICY
    • We may update this Policy from time to time to reflect changes in our practices, in the Privacy Act, the CR Code, or other applicable law.
    • When we make a change, we will revise the "Last updated" date below and post the updated Policy on our website. The current version of this Policy is always available at stellamgmt.com.au/credit-reporting-policy.
  18. CONTACT US
    • For any questions about this Policy, to exercise your rights, or to make a complaint, please contact our Privacy Compliance Officer:
    • Privacy Compliance Officer
      Navun Pty Ltd (Stella Mgmt / STELLA STARPASS)
      Level 8, Suite 805, 220 Collins Street
      Melbourne VIC 3000, Australia
      Email: stella@stellamgmt.com.au

Last updated: April 2026