At FinancePath your privacy is important to us.
Who are we?
'We', 'us' and 'our' refer to FinancePath ACN 134 548 128 and our related businesses.
FinancePath's commitment to protecting your privacy
When you apply for a new product or service, the application form includes a privacy consent. This privacy consent outlines how any information about you may be used and disclosed.
What information does FinancePath hold?
The types of information we hold about you will depend on the type of product or service requested by you.
Generally, we keep a record of one or more of the following types of information about you:
- information that identifies you, such as your name, address and other information provided by you or people nominated by you. We refer to this as "personal information";
- if you apply for a loan or credit card or guarantee another person's loan, credit information about you and property reports about any property which secures your obligations to us. Credit information includes: your identity; the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information, default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information; and publicly available information. It also includes credit eligibility information, which is is credit reporting information supplied to us by a credit reporting body and any information that we derive from it. Collectively, we refer to this as "credit-related information".
- if you apply for insurance, information about what is being insured (including health information about you, your income and your occupation if you are requesting life, health or accident insurance), information about your beneficiaries, and information about property owned by you if you are requesting some type of property insurance;
- account transaction information, including credits and debits or claims information for insurance products.
We will only collect sensitive information about you (for example, health information or information about your racial or ethnic origin or any criminal record) with your consent and where it is necessary for our business purposes. If we do have to collect sensitive information, we will do so in accordance with the National Privacy Principles.
Sometimes we act as an agent for others when collecting information about you, such as for our preferred insurance companies. We will tell you when we do this.
During the course of our relationship with you, we may gather information about you relating to all products and services that we or our preferred suppliers provide to you. This information is used to help us form views about how we can improve our relationship with you.
How does FinancePath collect information from its website?
We collect and hold information about you when you:
- complete an online application or other type of form;
- provide us with your email address; or
- access and use our services through our website.
We also collect some statistical information about visitors from our website (for example, the number of visitors, pages viewed, types of transactions conducted, time spent online and documents downloaded). Some of this statistical information is collected by using cookies, but none of the statistical information we collect allows us to identify a visitor. We use this information to evaluate our website performance and continually improve our services.
Other than statistical information, we do not collect any information about you through our website unless you provide the information to us.
How does FinancePath generally collect your information?
Generally, where reasonable and practical, we will collect personal information about you directly from you. We may also collect information about you that is publicly available (for example, from public registers) or made available by third parties. For example, you may authorise us to collect information from a third party, such as your employer to confirm your income details, or we may engage an agent (such as a mortgage broker) to collect information on our behalf, or you may be named as a referee or beneficiary in another application for one of our products or services.
How may FinancePath use your personal information?
We use your personal information for the purposes of:
- processing your application for our products or services;
- managing and administering all products and services we provide to you, including banking, treasury, financial planning and insurance products and services;
- assessing, processing and investigating claims made under any insurance products we provide to you;
- ensuring our internal business operations are running smoothly, which may include fulfilling legal requirements and conducting confidential systems maintenance and testing;
- direct marketing and managing our relationship with you; and
- complying with our legal obligations.
Your personal information may also be used by us or our related businesses to help assess our relationship with you, analyse products and services, evaluate the needs of our customers, and develop new products.
Unless you inform us or have previously told us not to, we may also provide access to your personal information to our related businesses to inform you of products and services which we think may be of interest or value to you. Your health information or information about your medical history will not be disclosed to our related businesses for this purpose.
We may use your information to provide you with information about products or special offers you may find of interest, changes to our business, or new products or services being offered by us or any company we are associated with.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our office. 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.
Who does FinancePath disclose personal information to?
Generally, we must obtain your consent before we disclose your personal or credit-related information.
Sometimes the law requires us to disclose information about you. For example, we must tell the Australian Tax Office how much interest we pay you, or we must provide your account details to a court if we are ordered to do so under a subpoena.
We may also disclose your personal information to:
- our external service providers (which may be located overseas) that provide services and infrastructure systems to us. This is on a confidential basis and may include organisations that provide card authorisation, clearing and settlement services (such as Visa or MasterCard), our lenders' mortgage insurer, claims investigators, mailing houses, property valuers, surveyors, auctioneers, and real estate agents;
- prospective funders or other intermediaries in relation to your finance requirements;
- other persons who have an interest in any property offered to FinancePath as security;
- any party acquiring an interest in any business or your credit or loan account and any related securities provided by you or any other person;
- government agencies in connection with your loan, such as for stamping and registration of mortgages;
- any organisation which you request us to;
- any person who represents you or acts on your behalf, including your financial adviser, broker, solicitor, accountant or guardian;
- your employer, former employer, referees or identity verification services;
- any person with whom you transact (for example, merchants, to process your transactions) or any financial institution nominated by you (for example, in direct debit).
We will not disclose your health information or information about your medical history unless you tell us to.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
the person or organisation has a commitment to protecting your personal information at least equal to our commitment; or you have consented to us making the disclosure.
We may disclose your personal and credit-related information to overseas entities that provide support functions to us, including in Manilla. We take reasonable steps to ensure your personal information remains protected under the Australian Privacy Principals, and we ensure appropriate data handling and security arrangements are in place. You may obtain more information about these entities by contacting us.
We may use cloud storage and IT servers that may be located overseas to store the personal information we hold about you.
Who does FinancePath disclose credit-related information to?
We exchange credit-related information for the purposes of assessing your application for finance and managing that finance. If you propose to be a guarantor, one of our checks may involve obtaining a credit report about you.
When we obtain credit eligibility information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.
We exchange your credit-related information with credit reporting bodies. We use the credit-related information that we exchange with the credit reporting body to confirm your identity, assess your creditworthiness, assess your application for finance or your capacity to be a guarantor, and manage your finance.
The information we can exchange includes your identification details, what type of loans you have, how much you have borrowed, whether or not you have met your loan payment obligations, and if you have committed a serious credit infringement (such as fraud).
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-related information that we hold about you and make a request for us to correct that credit-related information if needed. See the heading 'Correction of your information' below.
Sometimes 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:
How does FinancePath protect the security of your information?
We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.
We provide the maximum level of security when you use our online products and services.
We have physical, electronic and procedural safeguards to protect your information held by us. For example, your personal information is stored in secured office premises, in electronic databases requiring logins and passwords for access. Access to information stored electronically is restricted to staff whose job purpose requires access. We require all staff to maintain the confidentiality of customer information.
Any visitor to any part of our premises in which customer personal information is kept is required to register with a security desk or be accompanied by a member of staff while in the premises.
We use secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer needed by us for any purpose.
What are your rights?
You do not need to give us any personal information we request. However, if you do not give us your personal information, we may not be able to process your application, fulfil your request or provide you with an appropriate level of service.
Updating your information
It is crucial to our relationship that the information we hold about you is accurate and up to date. During the course of our relationship with you, we will ask you to inform us if any of your information has changed.
You may change the information held by us by contacting us. Generally, we rely on you to inform us if the information we hold is inaccurate or incomplete.
Access to your information
You can request access to the personal and credit-related information we hold about you at any time. We will process your request within a reasonable time, usually 14 days for a straightforward request. More time may be needed depending on the nature of the request. There is no fee for requesting access to your information, however, we may charge you the reasonable cost of processing your request.
Sometimes we are not required to provide you with access for example, if the law says we can deny access. If we refuse you access to your personal or credit-related information, we will tell you the reason why.
Denied access to your Information
Situations may occur where we are not required to provide you with access to your information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if you request is vexatious. An explanation will be provided to you, if we deny you access to your information.
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 information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.
Where sensitive information is collected, stored, used or transferred about you, we will only use this information if you have consented or in the exercise or defence of a legal claim. Sensitive information may include, memberships in trade or professional association or trade unions, sexual preferences, criminal record or health.
Correction of your information
We try to ensure that the personal information we hold about you is accurate, complete and up-to-date. You must promptly notify us if there are any changes to your personal information.
You may ask us at any time to correct the personal information we hold about you if you believe is incorrect or out-of-date.
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 or credit-related information within 30 days.
If we refuse to correct the personal or credit-related information we hold about you, we will provide you with our reasons for not correcting the information. You may request that we attach a statement to that information noting that you consider it is not accurate, complete or up-to-date.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our how we have handled your personal or credit-related information, you may contact our complaints officer on 1300 780 440.
We will acknowledge your complaint within 24 hrs or 1 business day and aim to resolve the complaint within 30 days.
If you are dissatisfied with the response of our complaints officer, you may make a complaint to our External Dispute Resolution Scheme, Australian Financial Complaints Authority (AFCA) which can be contacted on 1800 931 678, or to the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.
We will try to answer any questions you may have, correct any error on our part or resolve any complaint that you may have about our information handling practices.