Privacy Commitment, respecting your privacy This Privacy Policy is relevant to BFF Finance. We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information that you may provide to us. Our Privacy Policy
ensures your right to privacy as we recognise that any personal information we may collect about you will only be used for the purposes indicated in our policy. It is important to us that you are confident that any personal information we collect from you or is received by us, will be treated with appropriate respect ensuring protection of your personal information. If you are in a country that is a member of the European Economic Area (EEA), the EU General Data Protection Regulation 2016/679 (GDRP) governs the way we collect, use, hold, process and disclose your personal information. Under GDPR, we are a data controller. We make decisions on how and why your personal information is processed. This Policy
also includes our credit reporting policy, that is, it covers additional
information on how we manage your personal information collected in
connection with a credit application, or a credit facility. We refer to this credit-related information
below as credit information. BFF Finance is committed to complying with the Privacy Act 1988 (Cth), the Australian Privacy Principles and any other relevant laws when handling your personal information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au. Who is BFF Finance BFF Finance provides home lending, asset finance and personal loans. We engage lenders on your behalf to secure finance requirements of the borrower. You appoint us as your
Agent (Access Seeker) to obtain your credit information from a credit information
from a credit reporting body on your behalf and for the purpose of assisting
you with your finance application. You authorise us to disclose any credit
information we obtain to prospective financiers in connection with your
finance application. By providing personal information to us, you consent
to the collection, use and disclosure of your information in accordance with
this Policy and any other arrangements that apply between us. What personal information do we collect
and hold? General information 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 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 on-line
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. We also know that 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 also 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. We also collect de-identified information
from the online interactions of users who are not customers that use our web
services. Much of this data collection is done through the use of cookies and
used to improve our services and enhance users web experience with us e.g.
website statistics and does not identify individual customers but does
identify internet browser. Where we do identify you (such as where customers
are supplying us with information), we treat any use or disclosure in
accordance with this policy. 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, when you’ve given us a
call or used 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[1]. How we collect your information 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
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
give you the credit assistance you seek from us; ·
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
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 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? We’ve just told you some of the main
reasons why we collect your information, so here’s some more insight into the
ways we use your personal information including: ·
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; ·
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. What are the grounds which we deal
with your personal information under the GDPR Under the GDPR, we must have legal
grounds in order to process your personal information. The legal grounds that
we may relay on are: ·
Compliance with a legal obligation; ·
Where you have provided your consent;
and ·
For our legitimate interests, our main
legitimate interests for processing your personal information are: fraud,
security, due diligence, business operations and direct marketing. 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
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. 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; ·
valuers; ·
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 ASIC 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: http://www.choiceaggregationservices.com.au/privacy https://www.mmsg.com.au/wp-content/uploads/2017/08/privacy-policy-mmsg-november http://www.collegecapital.com.au/privacy Sharing outside of Australia Some of the recipients to whom we
disclose your personal information may be based overseas, including India and
the Philippines. Where we may be transferring personal information overseas,
we will either inform you and seek your consent to the arrangement or ensure
that appropriate contractual measures are in place to ensure that the
overseas entity protects the personal information to the same level as
required by NewCo Financial Services Pty Ltd under the Privacy Act. 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. Overseas organisations may be required
to disclose information we share with them under a foreign law. In those
instances, we will not be responsible for that disclosure. Where we transfer your information from
the EEA to a recipient outside the EEA we will ensure that an adequate level
of protection is in place to protect your personal information such as
putting in place contractual protections to ensure the security of your
information. Cookies We may collect personal information
about you through the use of cookies. When you access our website, we may
send a “cookie” (which is a small summary file containing a unique ID number)
to your computer. This enables us to recognize your computer and greet you
each time you visit our website without bothering you with a request to
register. It also enables us to keep track of products or services you view
so that we can send you news about those produces or services. We also use
cookies to measure traffic patterns, to determine which area of our website
have been visited and to measure transaction patterns in the aggregate. We
use this to research our users’ habits to that we can improve our online
products and services. Our cookies do not collect personal information. If
you do not wish to receive cookies, you can set your browser so that your
computer does not accept them. We may
log IP addresses (that is, the electronic addresses of computers connected to
the internet) to analyse trends, administer the website, track user
movements, and gather broad demographic information. How do you access your personal information? How you can generally access your information We‘ll
always give you access to your personal information unless there are certain
legal reasons why we can’t. You can ask us in writing to access your personal
information that we hold. In some
cases we may be able to deal with your request over the phone. We will
give you access to your information in the form you want it where it’s
reasonable and practical. We may charge you a small fee to cover
our costs when giving you access, but we’ll always check with you first. We’re not
always required to give you access to your personal information. Some of the
situations where we don’t have to give you access include when: ·
we believe there is a threat to life or public safety; ·
there is an unreasonable impact on
other individuals; ·
the request is frivolous; ·
the information wouldn’t be ordinarily
accessible because of legal proceedings; ·
it would prejudice negotiations with
you; ·
it would be unlawful; ·
it would jeopardise taking action
against serious misconduct by you; ·
it would be likely to harm the
activities of an enforcement body (e.g. the police); or ·
it would harm the confidentiality of our
commercial information. If we can’t
provide your information in the way you’ve requested, we will tell you why in
writing. If you have concerns, you can complain. See ‘Contact Us’. 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 information Contact us
if you think there is something wrong with the information we hold about you
and we’ll try to correct it if it’s: ·
inaccurate; ·
out‑of‑date; ·
incomplete; ·
irrelevant; or ·
misleading. 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. How do you make a complaint? How do you generally make a complaint? If you have
a complaint about how we handle your personal information, we want to hear
from you. You are always welcome to contact us. You can
contact us by using the details below: BFF Finance Level 3, 480 Collins Street MELBOURNE VIC 3000 0468 789 343 minnie.tolentino@nmcfinance.com.au We are committed
to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and
you should hear from us within five business days. Need
more help? If you still feel your issue hasn’t
been resolved to your satisfaction, then you can raise your concern with the
Office of the Australian Information Commissioner: Online: www.oaic.gov.au/privacy Phone: 1300 363 992 Email: enquiries@oaic.gov.au Fax: +61 2 9284 9666 Mail: GPO Box 5218 Sydney NSW 2001 or GPO
Box 2999 Canberra ACT 2601 If you are located in the EEA, you can
contact the relevant data protection authority (for example in the place you
reside in or where you believe we breached your rights). For example, the
Office of the UK Information Commissioner: Office of the UK Information
Commissioner Online: www.ico.gov.uk Phone: 0303 123 1113 Live chat: https://ico.org.uk/global/contact-us/live-chat 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. Your Rights under GDPR If you reside in the EEA, you can also: ·
object to the processing of your personal information or ask us to
delete, or restrict or stop using your personal information. There may be
circumstances where we are required to, or entitled to retain or continue
using your information. ·
Withdraw your consent to our processing of your information. We may
continue to process our information if we have another legitimate ground to
do so; ·
Ask us to send an electronic copy of your personal information,
including to another organization. You can contact us if you wish to exercise these rights. See “Contact
Us” for more information. If we refuse any request you make in relation to
these rights, we will write to you to explain why and how you can make a
complaint about our decision. Contact Us 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: Minnie Tolentino (BFF Finance) Level 3, 480 Collins Street MELBOURNE VIC 3000 Mob: 0468 789 343 minnie.tolentino@nmcfinance.com.au 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. Changes to this Privacy Policy This Policy may change. We will let
you know of any changes to this Policy by BFF Finance should you require a
copy of our Privacy Policy please specify the manner in which you would like
to receive it and a copy will be sent to you. | 
