WHO ARE WE?
Homeloans Ltd (ACN: 095 034 003, ACL: 247829) and our related businesses RESIMAC Limited (ACN: 002 997 935, ACL 247283), State Custodians Pty Ltd (ACN: 118337367, ACL: 390850), Paywise (ACN:007 388 696 ) and RHG Mortgages (ABN:48065912932) are collectively known as the Homeloans Group and are referred to in this Policy as "us," "we," and "our".
The Homeloans Group is an organisation that offers financial products and services and provides credit to approved applicants. We also provide funding via our established and longstanding Mortgage Originator partners. We also process and assess information when investors invest funds with us. We may also market or provide other products from time to time, pursuant to our licenses.
OUR COMMITMENT TO PROTECT YOUR PRIVACY
We take privacy seriously as part of our commitment to providing our customers with excellent service and to achieving excellence in compliance.
This document sets out our Privacy commitment in respect of personal information (including credit information) that you may provide to us.
You may request this Policy in an alternative form where appropriate and without charge.
When we refer to personal information, we mean information or an opinion about you, from which you are, or may reasonably be, identified.
The kinds of personal information we may collect about you may include (but is not limited to) your name, date of birth, driver's licence number, marital status, phone number, email address, address, nationality, employment history, income, assets, liabilities, living expenses and repayment history information.
Credit information is a subset of personal information, which is used to assess your eligibility to be provided with credit and may include any finance that you have outstanding, your repayment history in respect of that credit, and any defaults. Usually, credit information is exchanged between lenders and credit reporting bodies.
If you are applying for credit, we may also collect other information such as 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.
Due to the nature of the services provided by us, some of the information collected may be sensitive information, including, but not limited to, details about your health or ethnic background. For example, you may be asked to provide information about whether or not you are an Aboriginal or Torres Strait Islander or if you are applying for insurance. In addition, you may be asked for information about pre-existing medical conditions.
It is not common practice for us to collect other sensitive information about you (such as information about your religion, trade union membership, political opinion, sexual preference, or criminal record), and we will only do so if such information is required for one or more of our functions or activities.
We will only collect sensitive information about you with your consent or where required or authorised or otherwise permitted under law.
WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
We will only collect information if it is reasonably necessary for one or more of our functions or activities.
We collect and receive personal information about you in order to conduct our business and to provide our services, including the purposes set out under the headings below.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We may collect personal information from you in a number of circumstances, including where you:
- make an enquiry with us via telephone, email or by visiting our office;
- lodge or partially lodge a loan enquiry or request a quote through our website;
- apply or partially apply, to be a borrower or guarantor;
- attend an event hosted by us;
- apply for employment with us;
- apply or partially apply for accreditation as a business partner, aggregator, broker or introducer of loans or other products;
- provide any other service to us either directly or through your employer;
- interact with us via social media; or
- register to use a related product or service offering.
Where reasonable and practical, we will collect personal information from you directly.
We will also collect information about you from third parties, such as a partner or spouse who contacts us on your behalf, from our contractors who supply services to us, through our business partners and referrers (such as mortgage originators and brokers), from a publicly maintained record or from other individuals, credit reporting bodies or companies or individuals authorised by you.
If you do not provide the information requested by us, we may not be able to provide you with our services.
PURPOSE FOR WHICH WE USE AND DISCLOSE INFORMATION
We may use and disclose your personal information for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your personal information for the following purposes:
- to provide you with the products or services you requested;
- to verify your identity;
- to assess, process and manage your application to be a borrower or guarantor, including to verify your details and assess our risk;
- to provide you with credit and manage that credit;
- to assess, process and manage your application for employment;
- for complaints handling or data analytics purposes;
- to manage our relationship with you;
- to assess, process and manage your application to be a business partner, aggregator, broker or introducer of loans or other products, including to verify your details and assess our risk;
- to manage our business, including obtaining advice and services from companies and contractors including the types set out below; and
- to provide you access to the customer rewards program.
HOW DO WE HOLD YOUR PERSONAL INFORMATION
The security of your information is very important to us. We will take reasonable steps (such as, but not limited to, restricting and monitoring access to personal information) to protect any personal information from misuse, loss, unauthorised access, modification, misuse or disclosure.
Your personal information may be held by us in paper form, electronic form, on our secure servers or in cloud storage.
Your personal information may be combined or linked with personal information held about another individual (i.e. where a loan is held in joint name).
We regularly review developments in security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as totally secure.
If we no longer require your information, and we are legally permitted to, we will take all reasonable steps to destroy or de-identify the information.
We take reasonable steps to preserve the security of cookie and personal information in accordance with this policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).
WHO WILL WE DISCLOSE YOUR PERSONAL INFORMATION TO?
The types of organisations that we may disclose information about you include:
- organisations which assist us to verify your identity;
- organisations that provide products or services used or marketed by us, including other credit providers, mortgage intermediaries (such as mortgage brokers, mortgage originators and mortgage managers), funders, lenders, valuers, trustee companies, financial institutions and securitisers, mortgage insurers, title insurers, surveyors, credit reporting agencies, rating agencies and debt collectors;
- other organisations that are involved in managing or administering your credit;
- your employer/s or referees, your guarantors, your professional advisors, your bank or anyone else where you have provided consent;
- any other organisation that may have or is considering having an interest in your loan, or in our business;
- companies and contractors who we retain to provide services for us, such as customer rewards programs, information and infrastructure systems IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your personal information to provide those services;
- people (such as investors, agents or advisors) or any entity considering acquiring an interest in our business or assets;
- where we are required to do so by law, such as under the Anti-Money Laundering and Courter Terrorism Financing Act 2006 (Cth) or the National Consumer Credit Protection Act 2009 (Cth); or
- other individuals or companies authorised by you or in relation to whom disclosure is permitted by law.
We may disclose your personal and credit information to overseas entities that provide support functions to us including entities in New Zealand and the Philippines. You may obtain more information about these entities by contacting us.
Prior to disclosing any of your personal information to another person or organisation, we will take reasonable steps to satisfy ourselves that:
(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
(b) you have consented to us making the disclosure.
COLLECTING AND DISCLOSING CREDIT INFORMATION
We may collect the following kinds of credit information and exchange this information with credit reporting bodies and other entities:
- credit liability information, being information about your existing finance which includes the name of the credit provider, whether the credit provider holds an Australian Credit Licence, the type of finance, the date the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;
- repayment history information which is information about whether you meet your repayments on time;
- information about the type of finance that you are applying for;
- default and payment information; and
- court proceedings information.
We exchange this credit information for the purposes of assessing your application for credit and managing that credit.
We exchange your credit information with credit reporting bodies. We use the credit information that we exchange with the credit reporting body to assess your creditworthiness, assess your application for finance and managing your finance.
If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement then we may disclose this information to a credit reporting body.
You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information if needed. Please refer to the heading access and correction of your personal and credit information, below.
At times, your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting body at any time to request that your credit information is not used in this way.
You may contact the credit reporting body to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the credit reporting body receives your notification the credit reporting body must not use or disclose that credit information.
You can contact any of the following credit reporting bodies for more information:
From time to time we may use your personal information to provide you with current information about mortgage loans, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company (such as QBE Insurance) that we are associated with. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Officer on 1300 764 447.
Similarly, if you wish to know the source of information being used, you can request this information by contacting the Privacy Officer on 1300 764 447.
We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that use or disclosure.
UPDATING YOUR PERSONAL INFORMATION
It is important to our relationship that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information (including your credit related personal information) that we hold about you, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
ACCESS AND CORRECTION OF YOUR PERSONAL AND CREDIT INFORMATION
We will provide you with access to the personal and credit information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the personal or credit information we hold about you, at any time, using the details specified below.
We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately or within a reasonable period after receiving your request. We may need to contact other entities to properly investigate your request.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request. Otherwise, we will provide an initial response to you within seven days of receiving your request.
Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct personal information we will provide you with our reasons for not correcting the information.
DENIED ACCESS TO PERSONAL OR CREDIT INFORMATION
There are circumstances in which we are not required to provide you with access to personal information or to credit information, and in those circumstances, we may decline any request you make.
An explanation will be provided to you if we deny you access to your personal information we hold.
USING GOVERNMENT IDENTIFIERS
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other as than where we are required by law to do so.
BUSINESS WITHOUT IDENTIFYING YOU
In most circumstances, it will be necessary for us to identify you in order to successfully do business with you, however, where, it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information.
Such a situation would include where you make general inquiries about interest rates or current promotional offers.
VISITING OUR WEBSITE
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose, at any time, if and how a cookie will be accepted by configuring your preferences and option in your internet browser.
- to allocate a unique number to your internet browsers;
- to customise our website for you;
- for statistical purposes (i.e. the date and time your visited our website and what pages you visited;
- to identify if you have accessed a Third party website;
- for security purposes; and
- rejecting cookies may have the effect of limiting access to our website functionality.
Your Internet Protocol address (IP address) is the numerical identifies for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.
Third Party Websites
Our website also contains links to the websites of third party providers of goods and services (Third Party websites). If you have accessed Third Party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties
Where you access a third-party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
FURTHER INFORMATION AND COMPLAINTS
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer on 1300 764 447. We will acknowledge receipt of your complaint within two business days.
We will investigate your complaint and provide a response to you within a maximum of forty-five calendar days, provided that we have all necessary information and have completed any investigation required. If further information, assessment, or investigation is required, we will seek to agree alternative time frames with you.
If you are dissatisfied with the response of our complaints officer you may make a complaint to our External Dispute Resolution Scheme, Credit Ombudsman Service Limited, which can be contacted on 1800 138 422 or firstname.lastname@example.org or the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.
You can contact us by calling 1300 764 447 or by writing to:
Level 9, 45 Clarence Street, Sydney NSW 2000
PO Box H284 Australia Square NSW 1215
Alternatively, you can email us at email@example.com
We regularly review our policies to keep up to date with market expectations, technology, the law and market place practices.