This Policy also includes our credit reporting policy, that is, it covers additional information on how we manage your personal information collected in connection with a credit application, or a credit facility. We refer to this credit-related information below as credit information.
If you are in a country that is a member of the European Economic Area (EEA), the EU General Data Protection Regulation 2016/679 (‘GDPR’) governs the way we collect, use, hold, process and disclose your personal information. Under the GDPR, we are a data controller. We make decisions on how and why your personal information is processed.
What personal information do we collect and how do we use it?
We will ask you for personal information when we assist you with your finance or your clients’ finance. We use the information you provide to advise on and assist with your credit needs or your clients’ credit needs. We only provide your information to the companies with whom you choose to deal with (and their representatives).
The types of information that we collect and hold about you or your clients’ could include:
• ID information such as name, postal or email address, telephone numbers, and date of birth;
• other contact details such as social media handles;
• financial details such as tax file number;
• information necessary to provide you with an estimated commercial property interest rate via our Comr8 tool such as project and lease details, estimated amount of borrowing, estimated loan term and the type of security being financed; and
• other information we think is necessary.
We also use your information to send you requested product information and to enable us to manage your ongoing relationship with us e.g. invoicing, client surveys, newsletters etc. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
We may occasionally notify you about promotions, new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post.
You can let us know at any time if you no longer wish to receive direct marketing offers from us by contacting us at email@example.com. We will process your request as soon as practicable.
We may also use your information internally to help us improve our services and help resolve any problems.
How do we collect your personal information?
The means by which we collect your personal information will depend on the nature of the services that we are providing to you. We may collect your personal information:
- directly from you, either in person, via email or our website or any other social media platforms or over the phone;
- from publicly available sources, for example, the electoral role, the telephone directory; or
- from third parties, related or not related, including but not limited to third party service providers or third party websites, social media accounts or apps.
What if you don’t provide some information to us?
If you don’t provide your information to us, it may not be possible:
- for us to give you the credit assistance you seek from us;
- to assist in finding a loan or lease relevant to your circumstances;
- verify your identity or protect against fraud;
- to provide you with an estimated commercial property interest rate via our Comr8 tool; or
- to let you know about other products or services that might be suitable for your financial needs.
How do we hold and protect your information?
We strive to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements
We hold the information we collect from you. In some cases, your file is archived and sent to an external data storage provider for a period of time. We only use storage providers located in Australia who are also regulated by the Privacy Act. We ensure that your information is safe. We maintain physical security over our paper and electronic data and premises by using locks and security systems.
Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our credit licensee e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.
We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.
If you wish to access or correct your personal information, please write to firstname.lastname@example.org
We do not charge for receiving a request for access to personal information or for complying with a correction request.
How do you make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.
Need more help?
If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:
- Online: www.oaic.gov.au/privacy
- Phone: 1300 363 992
- Email: email@example.com
- Fax: +61 2 9284 9666
- Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601.