What information do we collect?
Generally, the personal information we collect consists of your full name and contact details. This may include postal and email address, phone and mobile number and business contact details. Where relevant we may ask you for other information. To deliver our more complex services, it may be necessary to collect information including employment status, income, dependencies and asset and liability, income and expense information.
Where we are providing services relating to the origination and administration or loans, we may also be required to collect:
- Information obtained from credit checks carried out during the loan approval process (but only if you have authorized such checks to be carried out);
- Identification information relevant to applications requiring compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act; and
- Information about the progress of any loan provided to you, or which you have guaranteed, including your communications with us.
We may also collect personal information such as your IP address and web activity through third party companies such as Social media platforms, Salesforce Marketing Cloud or Google Analytics if you interact with us over the internet.
Usually we will not collect sensitive information (e.g. data relating to professional memberships, race or ethnic origin, religious beliefs, political opinions, criminal record, physical or mental health, or sexual orientation) from you. We may do so only if it is reasonably necessary for one or more of our functions and you explicitly consent beforehand.
On occasion, we may also collect information about you from others, such as:
- Companies or bodies that you own shares in or have an interest in.
If you do not provide all the information we request, we may no longer be able to provide a product or service to you.
How We Collect Your Personal Information
There are many ways we may collect personal information from you. These include in person at a meeting or seminar, when you register for e-newsletters, fill out a form, or correspond with us via our website, email or by telephone.
We never sell, rent or trade your personal information.
We may collect your personal information from our related companies and other third parties who provide services to us or on our behalf.
On occasion it may be necessary for us to collect your personal information from a publicly available source. We will only do so where you have consented, you would reasonably expect us to do so, or if it is necessary for us to perform a specific service.
How We Use Your Personal Information
Collecting your personal information allows us to provide you with the products and services you’ve asked for, respond to your requests and provide you with information about the Group.
The Group also collects, uses and exchanges your information so that we can:
- keep clients and contacts informed of current developments and the products and services we offer;
- maintain contact with clients;
- notify contacts and clients of events, products and services;
- manage and administer the products and services we offer;
- comply with laws, and assist government or law enforcement agencies;
- manage our businesses;
- improve our websites to provide you with a personalised experience; and
- provide you with information about other products and services offered by the Group that may be relevant to you.
Who do we share your personal information with?
Depending on the product or service you have applied for, we may share your personal information with other members of the Group.
We may also disclose your personal information to third parties outside of the Group, including:
- those involved in providing, managing or administering your product or service;
- credit reporting bodies or other approved third parties who are authorized to assess the validity of identification information;
- those involved in product planning and development;
- government agencies such as those which administer land titles and revenue or (where applicable) foreign investments;
- financial institutions, such as banks, as well as guarantors and prospective guarantors of your facility;
- businesses who assist us with our work, including direct marketing, debt recovery and IT support;
- current or previous employers;
- your representatives, including your broker, accountant, financial planner and legal advisers;
- those required or authorised by law, for example, government or regulatory bodies for purposes; and
- Organisations that help identify illegal activities and prevent fraud.
Disclosure of your personal information to overseas recipients
The Group operates in Australia, New Zealand and in the Asia-Pacific Region. As a result, your personal information is likely to be used in other States, Territories and overseas. Where your personal information is provided to overseas entities, we will take reasonable steps to ensure that the information remains secure and is used in a manner consistent with this policy and our obligations under the Privacy Act 1988 (Cth).
We may use your personal information to market our services. If at any stage you no longer wish to receive this marketing, please send an email to firstname.lastname@example.org with your full name, postcode, mobile number and the communication mediums you wish to unsubscribe from. We will endeavour to process your request within 21 days.
We will hold your personal information for such time as required to fulfil the purposes for which it was collected, or as required by law.
Security Of Your Personal Information
We take the security of your personal information very seriously. We will take reasonable commercial measures to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Your information may be kept in electronic form or hard copy.
We implement a number of processes to ensure your personal information is safeguarded. Our processes include the following:
- information storage security policies;
- security measures for systems access;
- providing discreet meeting areas for confidential discussions;
- accessed control for our Customer Relationship Management systems; and
- secure web forms when collecting sensitive information.
We take reasonable care to ensure any personal information you provide us via our website is protected. For example, if we require your sensitive information our websites have electronic security systems in place which include data encryption. Depending on your involvement with our Company and the type of information collected, user identifiers, passwords or other access codes may also be used to control access to your personal information.
Access To Your Personal Information
To request access to your personal information, please email us at (email@example.com). Before we give you the information, we will need to confirm your identity.
In certain circumstances we may be able to deal with your request over the telephone or in person. Otherwise we will endeavour to process your request within 21 days. In some circumstances we may refuse to give you access. We will explain why if that is the case (e.g. it may unreasonably affect the privacy of others).
We take reasonable steps to ensure that the personal information we collect and store is accurate, up-to-date and complete. Please contact us if you think the personal information we hold about you is not accurate, up-to- date or complete.
You are not required to provide us with any personal information as a visitor to our website. You may choose to remain anonymous or to provide us with a pseudonym if you do not wish to reveal your identity. However, please be aware that if this is impractical we may be unable to provide you with proper services.
Most browsers are programmed to accept cookies. If you wish to erase or block Cookies, you may be able to do this by changing the settings of your browser.
Blogs, Forums, And Other Social Media
The Group is not responsible for any use, misuse or misappropriation by other users of any personal information that you contribute in this manner.
If you have a complaint or concern about how we handle your personal information, please let us know and we will try to fix it.
To make a complaint, please email us at (firstname.lastname@example.org). We will look into the issue and endeavor to respond to your complaint within 30 days.
If you are not satisfied with how we manage your complaint, you may take your complaint directly to Australian Financial Complaints Authority (AFCA) or the Office of the Australian Information Commissioner (OAIC) at: https://www.oaic.gov.au/privacy/making-a- privacy-complaint.
How To Contact Us
We are committed to respecting your right to privacy and protecting your personal information. You may request further information about the way we manage your personal information by contacting the Privacy Officer at Positive Real Estate.
Positive Real Estate Pty Ltd
PO Box 133
Phone: 1300 365 886