Who are we?
‘We’, ‘us’ and ‘our’ refer to Home Edge Pty Ltd T/as Home Edge Finance ABN 84 346 830 317, Credit Representative Number 364730, Australian Credit Licence Holder eChoice Home loans Pty Ltd 390502 and our related businesses.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
We advise that any personal information we collect about you, will only be used for the purposes we have collected it or as allowed under the law. It is important to us, that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your privacy and personal information.
When we use the termpersonal information,we are referring to information from which your identity is reasonably apparent. This may include specific data or an opinion about you. The personal information we hold about you may also include credit information.
Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history and any defaults or bankruptcies. Credit information is typically exchanged between credit and finance providers and credit reporting bodies.
The personal information we may collect about you includes your name, date of birth, address, account details, occupation and any other information we made need to identify you.
If you are applying for finance we may also collect 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. If you apply for any insurance product through us, we may also collect your health information but this will only occurwith your consent.
Open and transparent management of personal information
We will manage personal information, including credit information, in an open and transparent manner. At the time of collecting personal information, we will communicate:
- what type of personal information is being collected
- who that personal information will be disclosed to
- how we use that personal information
We have appointed a Privacy Compliance Officer, who will deal with any queries regarding access to or correction of personal information or any privacy related complaints. We ensure all our employees are trained at regular intervals to ensure they understand our obligations under the Privacy Act, including the Australian Privacy Principles.
Remaining anonymous or using a pseudonym
Generally we are not able to deal with customers who do not wish to identify themselves. Where possible and appropriate, we will provide information of a general nature to unidentified individuals.
Collection of personal information
We collect personal information for the following purposes:
- arranging and assessing an application for credit
- managing credit
- providing individuals with the products or services they have requested
- managing our relationship with individuals
- protecting individuals and ourselves from error or fraud
- complying with regulatory requirements
We may collect sensitive information from individuals when they apply for an insurance related product.
We only collect sensitive information directly from the individual and with their consent.
We may also collect sensitive information when it has been provided as part of a loan application. Any sensitive information that is collected in this way, is only used for the purpose for which it is provided, and is collected with the individual’s consent.
We collect personal information directly from the individual, where possible.
Unsolicited personal information
If we received unsolicited personal information, we will determine whether we could have collected that personal information by lawful and fair means, and whether it is related to one of the specified purposes of collecting personal information listed. We will do this by looking at our relationship with the individual and whether the personal information relates to our relationship with them.
If we could not have collected the personal information by lawful and fair means, or the personal information does not relate to one of our specified purposes for collecting the personal information, we will destroy the personal information.
Notification of the collection of personal information
When we first collect personal information from an individual, we will notify them that we have collected their personal information. We will require the individual to sign a notification and consent form,which details how we will use and disclose their personal information.
This notification will provide the individual with information about:
- the purposes of the collection of their personal information and credit information
- those entities that we usually disclose personal information or credit information to
- what happens if the individual chooses not to provide us with personal information
- direct marketing that may be undertaken by us or any related companies
- when we are required to collect personal information under an Australian law, such as the National Consumer Credit Protection Act (Cth) 2009 or the Anti-Money Laundering and Counter Terrorism Financing Act (Cth) 2006
- any disclosure of personal information that we make to an overseas entity
If we know that as part of our relationship with the individual, we will disclose their personal information to another identifiable entity, such as a specific lender, we will notify the individual at the time we first collect their personal information of:
- the identity and contact details of that organisation
- why their information may be disclosed to the organisation
Use or disclosure of personal information
The purpose of collecting an individual’s personal information will be outlined in the notification and consent received by the individual.
During our relationship with an individual, if we decide that we wish to usetheir personal information for an additional purpose, we will obtain their consent, unless the purpose is related to the primary purpose or we are permitted under law to do so.
We notify individuals at the time of collecting their personal information, that their personal information will be used by us and any associated businesses for the purposes of direct marketing.
In all of our direct marketing communications, we will provide a prominent statement about how an individual can elect not to receive direct marketing. If the direct marketing communication is by email, we will provide an ‘unsubscribe’ function within the email.
We will keep appropriate records to ensure thatany individuals who have asked not to receive direct marketing communications, do not receive them. We do not apply a fee to unsubscribe from direct marketing communications.
We do not sell personal information and we do not use sensitive information for the purposes of direct marketing.
If we purchase personal information for the purposes of direct marketing, we will conduct appropriate due diligence to ensure appropriate consent has been obtained from the individual/sconcerned.
Cross-border disclosure of personal information
We do not disclose personal information overseas.
We may use cloud storage and IT servers that may be located overseas to store the personal information we hold.
Adoption, use or disclosure of government related identifiers
We do not use government related identifiers to identify individuals.
We may receive tax file numbers in the course of assessing an application for credit but we do not use or disclose tax file numbers for any purpose.
Quality of personal information
We rely on individuals to help us to ensure that their personal information is accurate, up-to-date and complete.
If we become aware that personal information is inaccurate, out-of-date or incomplete, such as when mail is returned, we will update our systems accordingly.
Security of personal information
We hold personal information on secure IT systems. All IT systems are appropriately updated with passwords, virus scanning software and firewalls as necessary.
Any paper records are only accessible to employees and others as they are needed. Any paper records are held within an office that is locked and security protected at night.
We will usually destroy personal information that is held electronically and in paper form seven years after our relationship with the individual ends. We will do this by shredding paper copies and deleting electronic records containing personal information about the individual or permanently de-identifying the individuals within those records.
Access to personal information
Individuals may request access to any personal information that we hold about them. We will not charge an individual for requesting access to their personal information.
Prior to disclosing any personal information, we will verify the individual’s identity.
When an individual requests access to their personal information we will conduct a search of our customer relationship database. This search will also indicate if there are any paper records that contain personal information.
We will not give access to the personal information that we hold about an individual where it is unreasonable or impracticable to provide access, or in circumstances where the request is likely to:
- pose a serious threat to the life, health or safety of any individual, or to public health or public safety
- unreasonably access the privacy of other individuals
- be frivolous or vexatious
- relate to anticipated legal proceedings, and the correct method of access to personal information is by the process of discovery in those legal proceedings
- reveal the intentions of the entity in relation to negotiations with the individual in such a way as to prejudice those negotiations
- be unlawful or in breach of an Australian law
- prejudice the taking of appropriate action in relation to a matter where unlawful activity or misconduct that relates to our functions or activities
- prejudice an enforcement related activities of an enforcement body (such as ASIC)
- reveal commercially sensitive information
When we receive a request for access we will normally respond to the individual within 7 days. Depending on the nature of the request, we may be able to provide the personal information as soon as the request is made.
If the individual is requesting a large amount of personal information or the request cannot be dealt with immediately, we will investigate the request for access, advise the individual what personal information we hold and provide details of that personal information as soon as reasonably possible.
We will comply with all reasonable requests by an individual to provide details of the personal information that we hold in the requested format.
If we do not provide access to the information we will provide written reasons setting out why we do not believe we need to provide access. We will also advise the individual they can access our Internal Dispute Resolution (IDR) and External Dispute Resolution (EDR) schemes if they are dissatisfied with a decision not to provide access to personal information.
Correction of personal information
If we hold personal information about an individual and we are reasonably satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading, or we receive a request to correct the information, we will take reasonable steps to correct the information.
If we correct personal information that we have previously disclosed, we will take reasonable steps to notify the entity to which we disclosed the information of the correction. We may not always make corrections to an individual’s personal information. When we do not make requested corrections, we will provide reasons for our refusal to make the correction and provide details of our IDR and EDR procedures.
If, after notifying the individual of our refusal to correct personal information, the individual requests us to issue a statement on the record that contains the personal information; we will take reasonable steps to do so.
Information from third parties
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 those third parties have collected 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 via our website, information about your preferences, ‘cookies’ or other information you have provided about yourself may be shared between us and the third party.
Advertising and tracking
When you view our advertisements on a Third Party website, the advertising company may use ‘cookies’ and other tracking systems to collect information such as:
- the server your computer is logged onto
- your web browser
- the date and time of your visit
- the performance of their marketing
When you access our website after clicking on one of our advertisements on a Third Party website, the advertising company may collect information about how you utilise our website (e.g. which pages you view) and whether you complete an online enquiry.
We use ‘cookies’ to provide you with better and more customised service and with a more effective website.
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can be retrieved by our web page servers at a later time. Cookies are frequently used by most websites and you can choose if and how a cookie will be accepted by configuring the preferences and options in your internet browser.
We do not generally disclose personal information obtained from cookies to overseas entities in the course of our activities.
Your IP address is the identifier 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.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our complaints officer on 03 9885 8831.
We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.
We are a member of the Credit Ombudsman Services Limited (COSL). If you have been unable to resolve your complaint to your satisfaction, you can refer your complaint to COSL by visiting their website www.cosl.com.au or by phoning 1800 138 422.
If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.
You may request further information about the way we manage your personal information by contacting us.
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.