Introduction

This Privacy Policy outlines how we collect and use your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

We collect and handle personal information in accordance with our legal obligations, including those under the Privacy Act and the Australian Privacy Principles. In addition, where Finsure Finance and Insurance Pty Ltd handles credit information, it is also bound by Division 3 of Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code 2014.

This Policy describes how your personal information and, where applicable, credit information is collected, used, disclosed and held by members of Finsure Finance and Insurance Pty Ltd.

Why We Collect Personal Information

We collect and hold personal information for the purposes of:

• assessing your application for finance and managing that finance;
• letting you know about our other products and services;
• direct marketing;
• managing our relationship with you;
• processing applications to join our network; and
• complying with legal and regulatory obligations, including anti-money laundering, counter-terrorism financing, and consumer credit reporting laws.

Information We Collect From You

We collect information about you and your interactions with us. The personal information we may ask you to provide includes, but is not limited to:

• personal and contact details such as your name, phone number, residential or postal address, email address and date of birth;
• documentary evidence to verify your identity such as a certified copy of your driver’s licence, passport, birth certificate, citizenship certificate or marriage certificate;
• Australian Government-related identifiers and identity documents such as your Tax File Number and country of tax residency;
• financial details such as employment, income, assets and financial liabilities;
• information needed to provide our services, such as bank account details; and
• credit information, including a credit check. See Credit Information below.

If you are applying for finance, we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details, and proof of earnings and expenses.

If you apply for any insurance product through us, we may also collect your health information. We will only collect health information with your consent.

We do not collect sensitive information such as your political or religious beliefs or ethnic background unless required by law and permitted under applicable privacy legislation.

Information We Collect From Others

We may collect information about you in addition to what you voluntarily provide in order to comply with relevant laws and regulations.

If you apply for credit, we may obtain a credit report from a credit reporting body. We may also collect information about you that has been made available by third parties who are permitted to provide your data.

How Personal Information Is Collected

The personal information we collect about you comes primarily from you. We may also collect information from other sources such as finance brokers, accountants, lawyers, and other third parties.

Wherever there is a legal requirement for us to ask for information about you, we will inform you of the obligation and the consequences of not providing the requested information.

For example, in addition to obtaining personal information when you acquire a product or service from us, we may need documentary evidence of your identity, such as a certified copy of your driver’s licence, passport, or birth certificate. We may also collect your personal information by using electronic verification services or by searching publicly available sources such as public registers.

We will not collect personal information about you except where you have knowingly provided it to us or where we believe you have authorised a third party to provide it to us. Any information collected from publicly available sources will be protected in the same way as information you voluntarily disclose.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information, that the other person has consented to you providing it, and that we may collect, use and disclose that information as described in this Policy without taking any further steps required by law.

Can You Deal With Us Anonymously?

In general, you can visit our website without telling us who you are or revealing personal information about yourself. Our web servers collect domain names, not email addresses, of visitors.

However, if a request is made to deal with us anonymously and we are required or authorised by law to deal only with identified individuals, we will notify you of this.

How We Use and Disclose Your Personal Information

We only use and hold your personal information:

• to assess your application for finance and manage that finance;
• to provide you with the financial product you have sought from us;
• if you are applying to join our network;
• for employment-related purposes, including assessing, processing and managing an application for employment;
• to handle any complaints you may have;
• for any purpose permitted under the Privacy Act;
• for any purpose you have consented to; and
• for direct marketing and other permitted purposes set out in this Policy.

The types of external organisations to which we may disclose your personal information include:

• prospective funders or intermediaries in relation to your finance requirements;
• organisations involved in managing or administering your finance, such as third-party suppliers, printing and postal services, and call centres;
• associated businesses that may wish to market products to you;
• companies providing information or infrastructure systems to us;
• your representatives, such as finance brokers, lawyers and accountants;
• anyone where you have provided consent;
• parties where disclosure is required by law, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• investors, agents or advisers, or entities with an interest in our business;
• your employer, referees or identity verification services; and
• overseas entities that provide support functions to us.

You consent to us disclosing your information to these entities and allowing them to use your personal information to provide their services, without obtaining your consent on a case-by-case basis.

We may also disclose your personal information where it is:

• necessary to provide products or services to you or undertake related operations;
• required to carry out promotions or activities you have requested, or for direct marketing purposes unless you opt out;
• required by law, for example to ASIC or AUSTRAC;
• authorised by law, including where disclosure is in the public interest or needed to protect our interests;
• required to assist in law enforcement;
• required by any successor in title to our business; or
• made with your express or implied consent.

These entities may in turn disclose your personal information to other entities as described in their own privacy policies or notices.

Direct Marketing

From time to time, we may use your personal information to tell you about products and services we think may be of interest to you, changes to our organisation, or new products or services being offered by us or associated companies. We will stop if you tell us to.

We may contact you by mail, telephone, email, SMS, social media, or other electronic means, including targeted advertising through our website or online services.

We will not charge you for processing your opt-out request and will take reasonable steps to action it as soon as possible.

Credit Information

Credit information is information used to assess your eligibility to be provided with finance. It may include details of any finance you have outstanding, your repayment history, and any defaults. This information may also be relevant if you are joining our network.

Security of Collected Information

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Personal information is stored in electronic form.

We have implemented policies, procedures and systems to help keep your personal information secure. Access is limited to employees with a legitimate business need to use the information in a way consistent with the purpose for which it was collected and other permitted purposes set out in this Policy.

When your personal information is no longer required, we will take reasonable steps to destroy, delete or de-identify it securely. However, we may be required by law to retain certain information, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or the Archives Act 1983 (Cth).

Social Media

We compile and categorise a list of our followers on social media platforms. We may also receive aggregate, non-personalised statistics on our coverage in social media.

Cross-border Disclosure

Depending on the type of service or product we provide, your personal information may be disclosed to associated entities, contractors and unaffiliated service providers located in overseas jurisdictions, such as the Philippines.

The overseas jurisdictions to which your personal information may be disclosed can change from time to time.

Where Homelend Solutions discloses personal information to an overseas recipient, Finsure Finance and Insurance Pty Ltd will take reasonable steps to ensure the overseas recipients are carefully chosen and comply with this Policy.

Overseas recipients may not be subject to privacy obligations equivalent to those under the Privacy Act and may be compelled by foreign law to disclose information.

Access to and Correction of Personal Information

You have the right to request access to your personal information and to request correction of that information.

You can seek access or request correction by contacting us using the details provided at the end of this Policy.

We will provide access within a reasonable period and in the manner requested by you where possible. We may charge a reasonable fee to cover our costs. In exceptional circumstances permitted by the Privacy Act, we may decline access. If we do, we will inform you and explain why.

We take reasonable steps to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and not misleading. These steps may include asking you to confirm information we hold or updating it from public sources.

We ask that you notify us promptly if any personal information we hold is incorrect or if your contact details change.

We will respond to a request to correct personal information within 30 calendar days. There is no charge for making a request. If we refuse your request, we will provide written notice and an information statement if requested.

Lodging a Question or Complaint

If you have a question or complaint about how we have handled your personal information, please contact us using the details at the end of this Policy.

The Privacy Officer will acknowledge receipt of your complaint as promptly as possible after we receive it. We will endeavour to investigate and resolve your complaint within 30 calendar days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner.

Notifiable Data Breaches

We are required to notify you and the Office of the Australian Information Commissioner where a data breach is likely to result in serious harm to you.

If at any time you believe your personal information held by us has been the subject of a data breach, please contact us immediately using the contact details set out in this Policy.

Changes to This Policy

This Policy may be updated from time to time as Finsure Finance and Insurance Pty Ltd considers necessary. Material changes will be published on our website.

If you would like a copy of this Policy in another form, such as a paper copy, we will take reasonable steps to provide it in the requested format.

Contacting Us

If you need more information, want to access or update your personal information, have a privacy concern, or wish to contact us regarding any matter covered by this Policy, please use the following details:

If you are not satisfied with our response after completing our internal complaints process, you may contact the Office of the Australian Information Commissioner if your complaint relates to privacy.