We need to collect personal information about you to provide you with our broking & related services. This privacy statement tells you how we collect your information, what we use the information for and who we share the information with. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How information is collected from you
We will collect your information from you directly whenever we can, like from enquiries we make of you when you seek credit assistance from us. We may verify that information from sources referred to in the responses to those enquiries or in this privacy statement.
How information is collected from other sources
Sometimes we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:
· we collect information from third parties about a loan or lease in relation to which you seek our services;
· we can’t get hold of you and we rely on public information (for example, from public registers or social media) or made available by third parties to update your contact details; or
· we exchange information with your legal or financial advisers or other representatives.
When the law authorises or requires collection of information
Some law may require us to collect personal information about you. For example, we may require your information to verify your identity under Australian Anti-Money Laundering law.
How your information may be used
We may use your information for purposes including:
· giving you credit assistance;
· giving you information about loan products or related services including help, guidance and advice;
· considering whether you are eligible for a loan or lease or any related service you requested including identifying or verifying you or your authority to act on behalf of a customer;
· assisting you to prepare an application for a lease or a loan;
· administering services we provide, for example, to answer requests or deal with complaints;
· administering payments we receive, or any payments we make, relating to your loan or lease;
· Identifying you;
· telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
· telling you about other suppliers, with whom we have arrangements, that supply goods or services that may be of interest to you;
· identifying opportunities to improve our service to you and improving our service to you;
· allowing us to run our business efficiently and perform general administrative tasks;
· preventing or investigating any fraud or crime or any suspected fraud or crime;
· as required by law, regulation or codes binding us; and
· any purpose to which you have consented.
You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.
What happens if you don’t provide information
If you don’t provide your information to us, it may not be possible to:
· assist in finding a loan or lease relevant to your circumstances;
· verify your identity or protect against fraud; or
· let you know about products or services that might be suitable for your financial needs.
Sharing Your Information
We may use and share your information with other organisations for any purpose described above.
Sharing with your representatives and referees
We may share your information with:
· your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); and
· your referees, like your employer, to confirm details about you.
Sharing with third parties
We may share your information with third parties in relation to services we provide to you or goods or services in which we reasonably consider you may be interested. Those third parties may include:
· the mortgage aggregator through whom we may submit loan or lease applications to lenders or lessors on the mortgage aggregator’s panel;
· the Australian Credit Licence holder Harry Pontikis that authorises us to engage in credit activities;
· referrers that referred your business to us;
· financial services suppliers with whom we have arrangements;
· lenders, lessors, lender’s mortgage insurers and other loan or lease intermediaries;
· organisations, like fraud reporting agencies, that may identify, investigate and/or prevent fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
· government or regulatory bodies as required or authorised by law. In some instances, these bodies may share the information with relevant foreign authorities;
· guarantors and prospective guarantors of your loan or lease;
· service providers, agents, contractors and advisers that assist us to conduct our business;
· any organisation that wishes to take an interest in our business or assets; and
· any third party to which you consent to us sharing your information.
Sharing outside of Australia
We may use overseas organisations to help conduct our business. As a result, we may need to share your information with such organisations outside Australia. The countries in which those organisations are located are: India or Philippines.
However, 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.
Information about other people
If you give information to us about another person (like your co-applicant) in relation to the services we provide, you will let that other person know that:
· we have collected their information to provide those services or for any other purpose set out in this privacy notice;
· we may exchange this information with other organisations set out in this privacy notice;
- access the information we hold about that other person,
by using our contact details above; and
· we may not be able to provide those services to you unless we obtain their information.
As part of our obligation to your financial well-being, we will refer you to a Financial Advisor to call you and discuss your insurance requirements
'We receive services to support the broking services we give you. We receive mortgage aggregation services from PLAN Australia. Sometimes they collect personal information about customers to manage customer enquiries or complaints, commission payments or file reviews. If you want to find out how they manage your personal information, please click on the link below:
If you have any questions about this, please do not hesitate to contact us.
WHAT TO DO IF YOU HAVE A DISPUTE OR COMPLAINT?
We are committed to providing our customers with the best possible service. If at any time we have not met our obligations – or you have a complaint about any of our services – please inform us so we can work towards a resolution. We will endeavour to deal with your complaint promptly, thoroughly and fairly.
HOW TO MAKE A COMPLAINT AND THE COMPLAINTS PROCESS?
We adopt the definition of ‘complaint’ in AS ISO 10002-2006 namely as “an expression of dissatisfaction made to an organization, related to its products or services or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected”.
If you have a complaint, we request you follow these steps:
1. Lodge a complaint using our Internal Dispute Resolution (IDR) procedure by contacting the Complaints Officer Harry Pontikis via :
· Phone: 1300 137 539
· E-mail: firstname.lastname@example.org
· Mail: Attention Harry Pontikis, Chocolate Money, PO Box 1054, Hampton North 3188
2. Speak to any representative of our business who will refer you to the Complaints Officer.
We will treat informal complaints seriously and refer them to the IDR unless they are resolved by the end of the next business day. Complaints which are resolved to the customer’s satisfaction by the end of the next business day (starting from when the complaint was received) will not require the full IDR process to be applied.
If referred to the IDR, the Complaints Officer will review the complaint carefully and promptly taking such steps and review such documentation as a reasonable person would do. Response to complaints will be within appropriate time limits and unresolved complaints will be referred to an External Disputes Resolution (EDR) Scheme.
THIRD PARTY PRODUCTS OR SERVICES
If your complaint relates to a product or service acquired through a third party (for example, a lender) we may ask you to contact the relevant third party. They will deal with your complaint under their complaints resolution process.
If you are not satisfied with the resolution of your complaint by the third party under their complaints resolution process, you are entitled to have your dispute considered by their External Dispute Resolution Scheme. Please contact the third party for further details.
KEEPING YOU INFORMED
The Complaints Officer will provide a written ‘final response’ to the complainant within 45 days (21 days where the complaint relates to default) which states:
· The final outcome for the dispute at IDR
· The right to take their dispute to the EDR (no matter what the results of the investigation was at the IDR)
· The name and contact details of EDR scheme
If the Complaints Officer is unable to give a final response within the specified period, the Complaints Officer will, before the end of the period:
· Inform the complainant of the reasons for the delay
· Advise the complainant of their right to complain to the EDR
· Provide the complainant with the name and contact details of EDR scheme
STILL NOT SATISFIED?
If you do not think we have resolved your complaint to your satisfaction, you may take the matter – free of charge – to the External Disputes Resolution Scheme (provided it is within the scheme’s terms of reference) as detailed below. You may also refer the matter to the relevant External Disputes Resolution Scheme at any time, but if our internal process is still in progress, we may request that our internal processes are completed before you consider taking the matter further.
Our external dispute resolution service provider is the Australian Financial Complaints Authority, which can be contacted via:
Time limits may apply to complain to AFCA and so you should act promptly or otherwise consult the AFCA websites to find out if or when the time limit relevant to your circumstances expires.