Respecting your privacy
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 credit facility. We refer to this credit- related information below as credit information
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
- ID information such as your name, postal or email address, telephone numbers, and date of birth;
- other contact details such as social media handles;
- financial details such as your tax file number;
- credit information such as details relating to credit history, credit capacity, and eligibility for credit (‘credit worthiness’); and
- other information we think is necessary.
Information from a credit reporting body
When we’re checking your credit worthiness and at other times, we might collect information about you that you obtain from credit reporting bodies.
What sensitive information do we collect?
Sometimes we need to collect sensitive information about you, for instance in relation to some insurance applications. This could include things like medical checks, medical consultation reports or other information about your health. Unless required by law, we will only collect sensitive information with your consent.
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions which require us to collect personal information, like the National Consumer Credit Protection Act.
What do we collect via your website activity?
If you use our website or our programs, we may monitor your use of the website and our programs to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.
We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de-identified information from users of our website or our programs. That information could include IP addresses or geographical information to ensure your use of our web and our programs is secure.
We also collect de-identified information if you use our website or our programs. Although the information collected does not identify an individual, it does provide us with useful statistics so that we can analyse and improve our web services and programs. If you disclose information through our websites, you may receive cookies, which are data that a website transfers to a user’s hard drive for record-keeping purposes. Cookies can facilitate a user’s ongoing access to and use of a website.
The cookies allow us to track website usage patterns and to compile data that can help us improve our web content.
How do we collect your personal information?
How we collect and hold your information
We understand that your personal information needs to be looked after and isn’t something you leave lying around for just anybody to take. So unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.
There are many ways we seek information from you. We might collect your information when:
- a Credit Representative fills out an application (the Credit Representative Application) and information supporting the Credit Representative Application. That information may include a credit report about you that you obtain for us;
- a Broker fills out an application (the Broker Application) and information supporting the Broker Application. That information may include a credit report about you that you obtain for us;
- a Loan Writer fills out an application for accreditation (Accreditation Application) to present loan applications to our panel lenders on the Broker’s behalf and information supporting the Accreditation Application;
- a referrer notification (Referrer Notification) is filled out to notify us of the Broker’s arrangement with a Referrer; or
- a third party notification (Third Party Notification), is filled out to notify us of a Broker’s arrangement with a Third Party.
Also, we might collect your information when you’ve given us a call or used our websites or our programs. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We do this only if it’s necessary to do so. Instances of when we may need to include where:
- we can’t get hold of you and we rely on publicly available information to update your contact details;
- we need information from an insurer about an insurance application you make through us; and
- at your request, we exchange information with your legal or financial advisers or other representatives.
- we may obtain information from the police or from ASIC or other government authorities to check your probity and assist it to assess the broker application or the credit representative application;
- we may obtain information from financial institutions on the Aggregator’s panel of financial institutions relating to application conversion ratios, application submission quality and use of online services;
- in the case of the BLSSA, we may obtain information from our insurance broker or the insurer that supplies Group Professional Indemnity Insurance cover to BLSSA’s credit representatives relating to your request to opt in to that cover;
- we may obtain information from other sources referred to in the Credit Representative Application, Broker Application, Accreditation Application, Referrer Notification or Third Party Notification, if we consider it necessary;
- if you are the director, partner or proprietor of a Credit Representative, Broker, Loan Writer, Referrer or Third Party, we may collect information about you from the Broker on whose behalf you or the Loan Writer or Referrer conducts business or refers clients or with whom the Third Party shares commissions; and
- we may ask for other information from you from time to time to enable us to improve our services or to review the general needs of Credit Representatives, potential Credit Representatives, Brokers and potential Brokers.
From time to time, we may request information about Brokers and Loan Writers from our panel lenders relating to loan application conversion ratios, use of online services and loan application submission quality.
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
- consider a Credit Representative Application, Broker Application, Accreditation Application, Referrer Notification or Third Party Notification;
- provide you with the product or service you want;
- manage or administer your product or service;
- verify your identity or protect against fraud; or
- let you know about other products or services from across the Group that might better meet your financial, e-commerce and lifestyle needs.
How we collect and hold your credit information
We will collect your credit information from details included in a Credit Representative Application or Broker Application. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
- other credit providers;
- your referees;
- your agents and other representatives like your accountants or solicitors;
- bodies that issue identification documents to help us check your identity; and
- our service providers involved in helping us to provide credit or to administer credit, including our debt collectors and our legal advisers.
What do we do when we get information we didn’t ask for?
Because we are a big organisation, people often share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
When will we notify you that we have received your information?
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- confidentiality requirements of our employees;
- document storage security policies;
- security measures for access to our systems;
- only giving access to personal information to a person who is verified to be able to receive that information;
- control of access to our buildings; and
- electronic security systems, such as firewalls and data encryption on our websites.
We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law, such as the Corporations Act, for example. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
How we use your personal information
What are the main reasons we collect, hold and use your information?
Because we offer a range of services and products, collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:
- provide you with information about products and services;
- consider a Credit Representative’s or a Broker’s request for products and services, including eligibility for those products and services;
- process a Credit Representative Application, a Broker Application, an Accreditation Application, a Referrer Notification or a Third Party Notification and provide products and services; and
- administer our relationship with the Credit Representative, Broker, Loan Writer, Referrer or Third Party which includes answering requests and complaints, taking any required legal action in connection with that relationship and generally managing the products and services we supply.
Can we use your information for marketing our products and services?
Given our wide organisation scope, we think we’ve learnt a lot of things along the way and we’d like to share what we know about our products with you. We may use or disclose your personal information to let you know about products and services from across the Group that might better serve your financial, e-commerce and lifestyle needs, or running competitions or promotions and other opportunities in which you may be interested.
We may conduct these marketing activities via email, telephone, SMS, iM, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites), or based on your use of Group programs. We will always let you know that you can opt out from receiving our third party or Group program marketing offers.
Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.
With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation outside of the Group.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from the Group (see ‘Contact Us’). We will process your request as soon as practicable.
What are the other ways we use your information?
We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:
- giving you information about a product or service;
- considering whether you are eligible for a product or service;
- processing your application and providing you with a product or service;
- administering the product or service we provide you, which includes answering your requests and complaints, varying products and services and managing our relevant product portfolios;
- identifying you or verifying your authority to act on behalf of a Credit
Representative, a Broker, a Loan Writer, a Referrer or a Third Party;
- telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, iM, mail, or any other electronic means including via social networking forums), unless you tell us not to;
- assisting in arrangements with other organisations in relation to a product or service we make available to you;
- allowing us to run our business and perform administrative and operational tasks, such as:
- training staff;
- developing and marketing products and services;
- risk management;
- systems development and testing, including our websites and other online
- undertaking planning, research and statistical analysis;
- determining whether a beneficiary will be paid a benefit;
- preventing or investigating any fraud or crime, or any suspected fraud or crime;
- as required by law, regulation or codes binding us;
- maintaining a database of Brokers, Loan Writers, Referrers and Third Parties, to, amongst other things, track and make payments of commissions and other amounts to them;
- managing our relationship with you;
- managing our relationships with our panel lenders;
- investigating and dealing with suspected or actual unlawful activity;
- assisting in improving industry standards relating to engaging in credit activities; and
- assisting with recovering amounts owing to us; and
- for any purpose for which you have given your consent.
Who do we share your personal information with
To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations and Group members for any purposes for which we may use your information.
Sharing with the Group
We may share your personal information with other Group members. This could depend on the product or service you have applied for and the Group member you are dealing with.
Sharing at your request
We may share your personal information with:
- your representative or any person acting on your behalf (for example, accountants or solicitors); and
- your referees to confirm details about you.
Sharing with third parties
We may share your personal information with third parties outside of the Group, including:
- our panel lenders;
- industry bodies of which we are a member;
- lender’s mortgage insurers or title insurers;
- in the case of the Licensee, its insurance broker or the insurer that supplies Group Professional Indemnity Insurance cover to the Licensee’s credit representatives, but only if you are considering opting in, or have opted in, to that cover;
- those involved in providing, managing or administering the product or service we provide to you;
- authorised representatives of the Group who sell products or services on our behalf;
- superannuation and managed funds organisations, and their advisers;
- medical professionals, medical facilities or health authorities who verify any health information you may provide;
- valuers, insurers (including lenders’ mortgage insurers and title insurers) , re-insurers, claim assessors and investigators;
- brokers or referrers who refer your application or business to us;
- loyalty programme partners;
- other financial institutions, such as banks;
- organisations involved in debt collecting, including purchasers of debt;
- fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
- organisations involved in surveying or registering a security property or which otherwise have an interest in such property;
- real estate agents;
- government or regulatory bodies (including ASIC and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
- our accountants, auditors or lawyers and other external advisers;
- rating agencies to the extent necessary to allow the rating agency to rate particular investments;
- guarantors and prospective guarantors of your obligations to us;
- organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
- organisations that participate with us in payments systems including merchants, payment organisations and organisations that produce statements for us;
- our joint venture partners that conduct business with us;
- organisations involved in a corporate re-organisation or transfer of Group assets or business;
- organisations that assist with our product planning, research and development;
- mailing houses and telemarketing agencies who assist us to communicate with you;
- other organisations involved in our normal business practices, including our agents and contractors; and
- where you’ve given your consent.
Sharing outside of Australia
The Group runs its business in Australia and overseas. Group members may need to share some of your information (including credit information) with organisations outside Australia. Sometimes, they may need to ask you before this happens. You can view a list of the countries in which those overseas organisations are located at www.nab.com.au/privacy/overseas-countries-list/
We may store your information in cloud or other types of networked or electronic storage. 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.
How do you access your personal information?
How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone.
We will give you access to your information in the form you want it where it’s reasonable and practical (such as a copy of a phone call you may have had with us – we can put it on a disk for you). We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
- we believe there is a threat to life or public safety;
- there is an unreasonable impact on other individuals;
- the request is frivolous;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- it would be unlawful;
- it would jeopardise taking action against serious misconduct by you;
- it would be likely to harm the activities of an enforcement body (e.g. the police); or
- it would harm the confidentiality of our commercial information.
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
How do you correct your personal information?
How we correct your information
Contact us if you think there is something wrong with the information we hold about you and we’ll try t correct it if it’s:
- irrelevant; or
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
How do you make a complaint?
How do you generally 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.
You can contact us by using the details below: The Privacy Officer
Advantedge Financial Services Pty Ltd
Level 10, 101 Collins Street
Melbourne Vic 3000
Telephone: 03 8616 1600
Email address: firstname.lastname@example.org
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.
If you have contacted us by phone or in person and feel your issue still hasn’t been resolved, the next step is to contact our Customer Resolutions team
Complaints and Disputes
Advantedge Financial Services Pty Ltd
P.O. Box 626 Collins Street West
Melbourne Vic 8007
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
We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
What if you want to interact with us anonymously or use a pseudonym?
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way however as we are often governed by strict regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
- it is impracticable; or
- we are required or authorised by law or a court/tribunal order to deal with you personally.
What do we do with government-related identifiers?
In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website.