Lending Loop Pty Ltd ACN 645 781 451 and its related bodies corporate ( Loop, we, our ) are committed to complying with applicable privacy laws in relation to the personal and credit information that we collect in the course of running our business.
Lending Loop is an Authorised Credit Representative (Credit Representative Number 529998) that offers services within the finance and mortgage brokering industry.
Where applicable, privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices.
In this document:
- “APPs” means the Australia Privacy Principles set out in the Privacy Act;
- “credit information” has the meaning set out in the Privacy Act, and (in summary) means personal information (other than sensitive information) that is, amongst other types of personal information, identification information about the individual, repayment history information about the individual, default information about the individual or payment information about the individual;
- “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
- “Privacy Act” means the Privacy Act 1988 (Cth); and
- “sensitive information” has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation, religious beliefs or affiliations and criminal record.
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
- ID information such as your name, postal or email address, telephone numbers, and date of birth;
- loan account numbers and loan account balances;
- other contact details such as social media handles; and
- other information we think is necessary relating to the products and services we provide.
Over the course of our relationship with you, we may collect and hold additional personal information about you, including transactional information, complaint or enquiries about products or services.
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.
What do we collect via your website activity?
If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.
If you start but don’t submit an online application, we can contact you using any of the contact details you’ve supplied to offer help completing it. The information in applications will be kept temporarily then destroyed if the application is not completed.
Some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our web applications is secure.
We collect de-identified information if you use one of our calculators or other programs. Although the information collected does not identify an individual, it does provide us with useful statistics so that we can analyse and improve our online services.
How do we collect your personal information?
How we collect and hold your information
Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up to date.
There are a number of ways in which we may seek information from you. We might collect your information when you fill out a form with us or via one of our partner sites, when you call our phone number or use our website. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details
How we collect your information from other sources
Sometimes, we will collect information about you from other sources as the Privacy Act permits. We will do this only if it’s reasonably necessary to do so, for example, where:
- we collect information from third parties about the loan or lease made available to you arising out of the services we provide you;
- we can’t get hold of you and we rely on public information to update your contact details; or
- we exchange information with your legal or financial advisers or other representatives.
What if you don’t want to provide us with your personal information?
If you don’t provide your information to us, it may not be possible:
- for us to provide you with the products or services you seek from us (including giving you the credit assistance you request);
- to assist in finding a loan or lease relevant to your circumstances;
- verify your identity or protect against fraud; or
- to let you know about other products or services that might be suitable for your financial needs.
How we collect and hold your credit information
We will collect your credit information in the course of you answering the enquiries we make of you relating to the credit assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
- your co-loan applicants or co-borrowers;
- your guarantors/proposed guarantors;
- your employer, accountant, real estate agent or other referees;
- your agents and other representatives like the person who referred your business to us, your solicitors, conveyancers and settlement agents;
- organisations that help us to process credit applications;
- organisations that check the security you are offering such as valuers;
- bodies that issue identification documents to help us check your identity; and
- our service providers involved in helping us to process any application you make for credit through us.
What do we do when we get information we didn’t ask for?
Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
When will we notify you that we have received your information?
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take all reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- document storage security policies;
- security measures for access to our systems; and
- only giving access to personal information to a person who is verified to be able to receive that information.
We may store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
Sensitive information is any information about a person’s racial or ethnic origin, membership of a political association, religious beliefs or affiliations, philosophical benefits, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information.
We will not ask you to disclose sensitive information, but if you elect to provide sensitive information it will be captured and stored.
How we use your personal information
What are the main reasons we collect, hold and use your information?
Collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:
- give you credit assistance
- give you information about loan products or related services;
- consider whether you are eligible for a loan or lease or any related service you requested;
- assist you to prepare an application for a lease or a loan;
- administer services we provide, for example, to answer requests or deal with complaints; and
- administer payments we receive, or any payments we make, relating to your loan or lease.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about other products or services we or a third party make available and that may be of interest to you.
We will always let you know that you can opt-out from receiving marketing offers.
With your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation.
Yes, You Can Opt-Out
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 are the other ways we use your information?
In addition, we may use your information for:
- 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;
- allowing us to run our business efficiently and perform general administrative tasks;
- rewarding a user of the Listing Loop platform (www.listingloop.com.au) (such as a real estate agent who acts on your behalf) who has introduced you to us or our related bodies corporate;
- preventing 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.
Who do we share your personal information with
To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
Sharing Your Information
We may use and share your information with other organisations for any purpose described above.
Sharing within our related bodies corporate
Lending Loop often works cooperatively with its related bodies corporate within the Listing Loop Global group, and may share your personal information with these entities.
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 products and services we provide to you. Those third parties may include:
- the mortgage aggregator and asset finance aggregators through whom we may submit loan or lease applications to lenders or lessors our licensees panel;
- referrers that referred your business to us;
- a contracted licenced broker;
- 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 (including the Australian Securities and Investments Commission and the Australian Tax Office) 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.
We receive services to support the broking services we provide you. We receive mortgage aggregation and asset finance aggregation services from several aggregators, these include:
- NewCo Financial Services (the holder of an Australian Credit Licence and who we are authorised under);
- Choice Aggregation Services;
- National Finance Choice; and
- College Capital Australia.
Sometimes they collect personal information about customers to manage customer enquiries or complaints, commissions payment or file reviews.
If you want to find out about how they manage your personal information, please visit their respective websites at the addresses detailed below:
Overseas transfers of personal information
We may disclose your personal information to our related entities, service providers and agents located overseas, including in Sweden, the United Kingdom, India and the United States of America. From time to time, we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.
By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
Accessing and correcting your personal information
You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our
reasons for refusing.
We will respond to all requests for access to or correction of personal information within a reasonable time.
What happens if there is a Data Breach?
In the unlikely event that we suspect that there has been a data breach that may cause you serious harm, we will take all reasonable steps to assess if your data has been accessed or lost, and if this information being accessed or lost may cause you serious harm. This assessment will always be completed expeditiously and within 30 days.
If we find that there has been a data breach that has the potential to cause you serious harm, this will be reported to the Office of the Information Commissioner and you directly.
How do you correct your personal information?
How we correct your personal information
Contact us if you think there is something wrong with the personal information we hold about you and we’ll try to correct it if it’s:
- irrelevant; or
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
What additional things do we have to do to correct your credit information?
If you ask us to correct credit information, we will help you with this in the following way.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Resolving personal information concerns
The Privacy Officer
1 Fuji Crescent, Mornington, Victoria, 3931
Telephone: 1300 695 667
Email: [email protected]
We take all complaints seriously, and will respond to your complaint within a reasonable period.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]
What additional things do we have to do to manage your complaints about credit information?
If your complaint relates to how we handled your access and correction requests
You may take your complaint directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.
For all other complaints relating to credit information
If you make a complaint about things (other than an access request or correction request) in relation to your credit information, we will let you know how we will deal with it within seven days.
Ask for more time if we can’t fix things in 30 days
If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
We care about your privacy.
Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
You can contact us by using the details below:
Lending Loop Pty Ltd
The Privacy Officer
1 Fuji Crescent, Mornington, Victoria, 3931
Telephone: 1300 695 667
Email: [email protected]
What if you want to interact with us anonymously or use a pseudonym?
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way, however, as we are often governed by regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
- it is impracticable; or
- we are required or authorised by law or a court/tribunal order to deal with you personally.
What do we do with government-related identifiers?
In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.
Updated: August 2021