About
this policy
This
policy is for LOANS FOR CHOICE PTY LTD
(“we,”, “us”, “our”), who is considered an Australian Privacy Principles (APP)
entity, as defined in the Privacy Amendment (Enhancing Privacy Protection) Act
2012.
This
policy outlines the following, including but not limited to:
·
who
we are and what our main function or activity is;
·
the
kinds of Personal Information (PI) we collect and hold;
Who
are we and what is our main function or activity?
We
are finance brokers. We provide “Credit Assistance” when we:
1. Suggest or assist you to
apply for a particular credit contract with a particular credit provider; or
2. Suggest or assist you to
apply for an increase to the credit limit of a particular credit contract with
a particular credit provider; or
3. Suggest you remain in a
particular credit contract with a particular credit provider.
You
(the customer) engage us (the broker) to arrange a loan on your behalf. You
acknowledge that we act as an independent contractor to assist you to obtain
and negotiate a loan.
We
have access to a panel of financiers and offer a variety of finance and
insurance products, both consumer and commercial, tailored to suit our
customers’ needs and objectives.
What
is Personal Information (PI) and what kinds do we collect and hold?
PI
is information or an opinion about an identified individual or an individual
who is reasonably identifiable. Examples of the kinds of PI we collect include,
but are not limited to an individual’s:
·
name,
signature, residential, business or e-mail address, telephone number, date of
birth, medical records, bank account details and expenditure details;
·
employment
details, such as business address, contact details, job title and salary; and
·
credit
report information, such as credit history, credit accounts, repayment history
information, inquiries, defaults and bankruptcy etc.
Sensitive
Information is also a form of PI and can include information or an opinion
about an individual’s racial or ethnic origin, political opinions, religious
beliefs, criminal record or health information. Generally, we are not required
to collect Sensitive Information as it is not reasonably necessary for our main
function or activity.
However,
if you require information about any insurance products we offer, we may need
to obtain health information from you. If this is the case, we will inform you
and obtain your consent prior to obtaining the information.
How
we collect your PI
In
the majority of cases, we will collect your PI directly from you when you apply
for a finance and / or insurance product and this is referred to as ‘solicited
information.’ Where you consent for us to do so, we can also collect your PI
from third parties, such as employers, accountants, banks or referrers (who may
simply provide us with your contact details.)
Why do we collect your PI and how do we hold, use and who do we disclose it
to?
We
collect your PI to provide you with finance and / or insurance products you’ve
requested.
We
collect and store information about you subject to Australia’s privacy and
credit reporting laws including the Privacy (Credit Reporting) Code 2024 (CR
Code). Your credit and personal information will be handled in accordance with
the CR Code.
If we proceed with providing finance and / or insurance products to you, we
will hold your PI for a period of seven years after the finance contract has
ceased. After that period, we will delete the PI we no longer require.
We
disclose your PI to the following sources, including but not limited to:
·
financiers;
·
insurers;
·
credit
reporting bodies in order to obtain credit information about you;
·
your
employer, bank, solicitor or accountant to verify the information you’ve
provided us;
·
the
supplier (e.g. motor vehicle dealership) from where you are purchasing the
asset where applicable; and
·
your
referees or contacts if we are unable to contact you.
How
we deal with an individuals who remain anonymous or use a pseudonym?
You
have the option of not identifying yourself or of using a pseudonym when
dealing with us. For example, if you contacted us with a general enquiry about
our products, services or the financiers or insurers we have on our panel, you
don’t need to identify yourself.
However,
if you elect to apply for a finance and/ or insurance product, you will need to
identify yourself, as your PI is required to support a finance application.
How
we deal with solicited information
We
will only collect information form you or from a third party with your consent,
that is reasonably necessary for our main function or activity, that is, any
activity related to a finance and or insurance application. Whilst we generally
don’t collect sensitive information, we will only do so if it is related to our
main function or activity and we obtain your consent to collect it.
How
we deal with unsolicited information
If
we receive PI about you that you did not solicit, we will determine if we could
have obtained this information by lawful and fair means. An example may be
where we obtain information about you from your accountant or solicitor.
However, if we determine we would be unable to collect the information by
lawful and fair means or if the information is not reasonably necessary for our
main function or activity, we will destroy or permanently de-identify the
information.
Notification
of the collection and use of personal information
When
we collect PI directly from you, we will advise you of the purposes for which
it was collected, who it will be disclosed to and why, how you can access your
PI and seek its correction or how you can make a complaint if you believe your
PI was not handled in accordance with this policy or the APPs.
In
circumstances where we collect PI from a third party about you, we will inform
you of that collection and if the PI is reasonably necessary for our main
function or activity, how we intend on using it and who we will disclose it to.
Direct
marketing and how you can opt out of receiving marketing material
We
may use the PI we collected from you for the purpose of marketing about
additional products or services available to you, both via our group and third
parties. These marketing activities may be conducted via e-mail, telephone,
social media platforms, SMS, mail or any other electronic means. We won’t sell
your PI to any organization outside our group.
If
you do not wish to receive marketing material from us, you can opt out and any
time but simply sending an e-mail and we will update our records and systems
accordingly. Alternatively, you can call us and advise us you no longer wish to
receive marketing material. Generally speaking, we will stop sending direct
marketing material to you within 30 days of receiving the request.
Cross-border
disclosure of PI
Our
group operates in Australia, however, we may share your information with
organisations outside Australia whom we are affiliated and have contractual
arrangements with. These countries include, but are not limited to:
·
Germany;
·
New
Zealand;
·
United
Kingdom;
·
Philippines;
·
India;
·
Singapore;
·
Japan;
·
Malaysia;
·
Vietnam;
and
·
the
United States of America.
As
electronic or networked storage can be accessed from various countries via an
internet connection, it’s not always practicable to know in which country your
information may be held. If your information is stored in this way, disclosures
may occur in countries other than those listed.
Overseas
organisations may be required to disclose information we share with them under
a foreign law. In those instances, we will not be responsible for that
disclosure.
Use
and collection of government related identifiers
As
part of the finance application process, we may collect government related
identifiers from you that appear on certain documents. Examples of government
related identifiers include, but are not limited to:
·
Driver’s
Licence numbers;
·
Passport
numbers; and
·
Tax
File Numbers.
We
won’t use a government related identifier to identify you or your application,
as generally we will use your name and / or an application number.
When
providing certain finance and / or insurance products to you, we may be
required to disclose certain government related identifies, such as a Driver’s
Licence number to a financier or insurer, which forms part of their
identification process.
However,
there are specific requirements relating to Tax File Numbers. Under the Tax
File Number Rule 2015, TFNs should only be collected under superannuation,
taxation and personal assistance laws. We will take all reasonable steps to
permanently de-identify any TFN that appears on a document we have received
from you, your employer or accountant.
How
we ensure your PI is up to date and accurate
We
will make every reasonable effort to ensure that the PI we hold about you is
accurate, up to date and complete. However, if any of your PI needs to be
updated, please contact us (refer to the Contact Us section of this policy) and
we will update it for you.
How
do we keep your PI secure?
We
take the security of your PI seriously and as information is stored both
electronically and in hardcopy format, we have a variety of safety measures in
place to protect your PI from misuse, modification, interference, loss,
unauthorized access or disclosure. Some of the safety measures include, but are
not limited to:
·
confidentiality
agreements requirements of our employees and external representatives;
·
document
storage security policies;
·
security
measures for access to our systems;
·
only
giving access to PI to authorized staff and representatives who require access
to such information;
·
premises
security; and
·
electronic
security systems such as firewalls and data encryption.
Where
we store PI physically or electronically with third party data storage
providers, we have contractual arrangements to ensure those providers take
appropriate security measures to protect that that information and restrict
those who access it. In the event of a data breach involving your information,
we will notify you as soon as practicable in accordance with our obligations
under the CR Code.
This
policy is for LOANS FOR CHOICE PTY LTD
(“we,”, “us”, “our”), who is considered an Australian Privacy Principles (APP)
entity, as defined in the Privacy Amendment (Enhancing Privacy Protection) Act
2012.
This
policy outlines the following, including but not limited to:
·
who
we are and what our main function or activity is;
·
the
kinds of Personal Information (PI) we collect and hold;
Who
are we and what is our main function or activity?
We
are finance brokers. We provide “Credit Assistance” when we:
1. Suggest or assist you to
apply for a particular credit contract with a particular credit provider; or
2. Suggest or assist you to
apply for an increase to the credit limit of a particular credit contract with
a particular credit provider; or
3. Suggest you remain in a
particular credit contract with a particular credit provider.
You
(the customer) engage us (the broker) to arrange a loan on your behalf. You
acknowledge that we act as an independent contractor to assist you to obtain
and negotiate a loan.
We
have access to a panel of financiers and offer a variety of finance and
insurance products, both consumer and commercial, tailored to suit our
customers’ needs and objectives.
What
is Personal Information (PI) and what kinds do we collect and hold?
PI
is information or an opinion about an identified individual or an individual
who is reasonably identifiable. Examples of the kinds of PI we collect include,
but are not limited to an individual’s:
·
name,
signature, residential, business or e-mail address, telephone number, date of
birth, medical records, bank account details and expenditure details;
·
employment
details, such as business address, contact details, job title and salary; and
·
credit
report information, such as credit history, credit accounts, repayment history
information, inquiries, defaults and bankruptcy etc.
Sensitive
Information is also a form of PI and can include information or an opinion
about an individual’s racial or ethnic origin, political opinions, religious
beliefs, criminal record or health information. Generally, we are not required
to collect Sensitive Information as it is not reasonably necessary for our main
function or activity.
However,
if you require information about any insurance products we offer, we may need
to obtain health information from you. If this is the case, we will inform you
and obtain your consent prior to obtaining the information.
How
we collect your PI
In
the majority of cases, we will collect your PI directly from you when you apply
for a finance and / or insurance product and this is referred to as ‘solicited
information.’ Where you consent for us to do so, we can also collect your PI
from third parties, such as employers, accountants, banks or referrers (who may
simply provide us with your contact details.)
Why do we collect your PI and how do we hold, use and who do we disclose it
to?
We
collect your PI to provide you with finance and / or insurance products you’ve
requested.
We
collect and store information about you subject to Australia’s privacy and
credit reporting laws including the Privacy (Credit Reporting) Code 2024 (CR
Code). Your credit and personal information will be handled in accordance with
the CR Code.
If we proceed with providing finance and / or insurance products to you, we
will hold your PI for a period of seven years after the finance contract has
ceased. After that period, we will delete the PI we no longer require.
We
disclose your PI to the following sources, including but not limited to:
·
financiers;
·
insurers;
·
credit
reporting bodies in order to obtain credit information about you;
·
your
employer, bank, solicitor or accountant to verify the information you’ve
provided us;
·
the
supplier (e.g. motor vehicle dealership) from where you are purchasing the
asset where applicable; and
·
your
referees or contacts if we are unable to contact you.
How
we deal with an individuals who remain anonymous or use a pseudonym?
You
have the option of not identifying yourself or of using a pseudonym when
dealing with us. For example, if you contacted us with a general enquiry about
our products, services or the financiers or insurers we have on our panel, you
don’t need to identify yourself.
However,
if you elect to apply for a finance and/ or insurance product, you will need to
identify yourself, as your PI is required to support a finance application.
How
we deal with solicited information
We
will only collect information form you or from a third party with your consent,
that is reasonably necessary for our main function or activity, that is, any
activity related to a finance and or insurance application. Whilst we generally
don’t collect sensitive information, we will only do so if it is related to our
main function or activity and we obtain your consent to collect it.
How
we deal with unsolicited information
If
we receive PI about you that you did not solicit, we will determine if we could
have obtained this information by lawful and fair means. An example may be
where we obtain information about you from your accountant or solicitor.
However, if we determine we would be unable to collect the information by
lawful and fair means or if the information is not reasonably necessary for our
main function or activity, we will destroy or permanently de-identify the
information.
Notification
of the collection and use of personal information
When
we collect PI directly from you, we will advise you of the purposes for which
it was collected, who it will be disclosed to and why, how you can access your
PI and seek its correction or how you can make a complaint if you believe your
PI was not handled in accordance with this policy or the APPs.
In
circumstances where we collect PI from a third party about you, we will inform
you of that collection and if the PI is reasonably necessary for our main
function or activity, how we intend on using it and who we will disclose it to.
Direct
marketing and how you can opt out of receiving marketing material
We
may use the PI we collected from you for the purpose of marketing about
additional products or services available to you, both via our group and third
parties. These marketing activities may be conducted via e-mail, telephone,
social media platforms, SMS, mail or any other electronic means. We won’t sell
your PI to any organization outside our group.
If
you do not wish to receive marketing material from us, you can opt out and any
time but simply sending an e-mail and we will update our records and systems
accordingly. Alternatively, you can call us and advise us you no longer wish to
receive marketing material. Generally speaking, we will stop sending direct
marketing material to you within 30 days of receiving the request.
Cross-border
disclosure of PI
Our
group operates in Australia, however, we may share your information with
organisations outside Australia whom we are affiliated and have contractual
arrangements with. These countries include, but are not limited to:
·
Germany;
·
New
Zealand;
·
United
Kingdom;
·
Philippines;
·
India;
·
Singapore;
·
Japan;
·
Malaysia;
·
Vietnam;
and
·
the
United States of America.
As
electronic or networked storage can be accessed from various countries via an
internet connection, it’s not always practicable to know in which country your
information may be held. If your information is stored in this way, disclosures
may occur in countries other than those listed.
Overseas
organisations may be required to disclose information we share with them under
a foreign law. In those instances, we will not be responsible for that
disclosure.
Use
and collection of government related identifiers
As
part of the finance application process, we may collect government related
identifiers from you that appear on certain documents. Examples of government
related identifiers include, but are not limited to:
·
Driver’s
Licence numbers;
·
Passport
numbers; and
·
Tax
File Numbers.
We
won’t use a government related identifier to identify you or your application,
as generally we will use your name and / or an application number.
When
providing certain finance and / or insurance products to you, we may be
required to disclose certain government related identifies, such as a Driver’s
Licence number to a financier or insurer, which forms part of their
identification process.
However,
there are specific requirements relating to Tax File Numbers. Under the Tax
File Number Rule 2015, TFNs should only be collected under superannuation,
taxation and personal assistance laws. We will take all reasonable steps to
permanently de-identify any TFN that appears on a document we have received
from you, your employer or accountant.
How
we ensure your PI is up to date and accurate
We
will make every reasonable effort to ensure that the PI we hold about you is
accurate, up to date and complete. However, if any of your PI needs to be
updated, please contact us (refer to the Contact Us section of this policy) and
we will update it for you.
How
do we keep your PI secure?
We
take the security of your PI seriously and as information is stored both
electronically and in hardcopy format, we have a variety of safety measures in
place to protect your PI from misuse, modification, interference, loss,
unauthorized access or disclosure. Some of the safety measures include, but are
not limited to:
·
confidentiality
agreements requirements of our employees and external representatives;
·
document
storage security policies;
·
security
measures for access to our systems;
·
only
giving access to PI to authorized staff and representatives who require access
to such information;
·
premises
security; and
·
electronic
security systems such as firewalls and data encryption.
Where
we store PI physically or electronically with third party data storage
providers, we have contractual arrangements to ensure those providers take
appropriate security measures to protect that that information and restrict
those who access it. In the event of a data breach involving your information,
we will notify you as soon as practicable in accordance with our obligations
under the CR Code.