Disclosure & Consent.

Privacy Policy

Disclosure & Consent

Movement Finance is a credit representative (518479) of Mortgage Specialists Pty Ltd ACN 612 422 178 Australian Credit Licence 387025

Sergio Coelho is a credit representative (495197) of Mortgage Specialists Pty Ltd ACN 612 422 178 Australian Credit Licence 387025

PRIVACY POLICY

In handling your personal information, Mortgage Specialists Pty Ltd ABN 48 612 422 178 T/As Specialist Finance Group, Australian Credit Licence 387025, 325 Churchill Ave, Subiaco WA 6008, Australia, 08 9286 6888 and our Authorised Credit Representatives are committed to complying with the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles.


PRIVACY STATEMENT

We will manage personal information, including credit information, in an open and transparent manner. In doing so, we ensure that individuals are notified at the time of collecting their personal information about: what type of personal information is being collected; who that personal information will be disclosed to; and how we use that personal information.

We will be responsible for dealing 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.

We periodically update our privacy policy and will provide a copy of our privacy policy free of charge on request and in a suitable format.


ANONYMITY AND PSEUDONYMITY

Generally, we are not able to deal with customers who do not wish to identify themselves. However, 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 marketed by us and our associates;
  • managing our relationship with individuals;
  • protecting individuals and ourselves from error or fraud; and
  • complying with regulatory requirements.



TYPES OF PERSONAL INFORMATION WE MAY COLLECT AND HOLD

Personal information for the purposes of identification, your contact details (e.g. name, address, phone, email and other personal contact information), date of birth, occupation and employment history, family status and relationship information (cohabitants, defendants and the ages of those individuals in your household).


From time to time we may collect information that contains government identifiers which could include your tax file number. However, we do not use or disclose this information other than required by law.

Financial information relating to your overall financial position and for the purposes of our loan assessment. This information may include relevant bank statements (e.g. transaction and saving statements), credit card / store card statements, information related to your assets and liabilities.

Credit Reporting Information includes credit reports from credit reporting bodies. These reports will disclose repayment history with your loans and financial liabilities including information about overdue payments and defaults, information related to adverse credit history including infringements, insolvency or bankruptcy, court proceedings and other information that is publicly available. We use your credit-related information to assess your eligibility to be provided with finance. The credit-related information that is available on credit reports is generally exchanged between credit and finance providers and credit reporting bodies.


SENSITIVE INFORMATION

We may collect sensitive information from individuals if they are referred to an insurance agency or they apply for an insurance related product where the insurer may have affiliations with our business. Insurance products that may require sensitive information may include, but are not limited to, life insurance, income protection, TPD, etc.

We only collect sensitive information directly from the individual and with the individual's consent. Sensitive information that is collected in this way is only used for the purpose for which it is provided. This may include information about your religion, ethnicity, health information, criminal record or biometric information.


Where possible, we collect personal information directly from the individual. We might collect your information when you fill out a form with us, when you have 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.


WHAT DO WE COLLECT VIA YOUR WEBSITE ACTIVITY AND INTERNET ACTIVITY?

When you access our website, we may monitor your use of the site to ensure we can verify you and can receive information from us. This also helps to identify ways we can improve our services for you.


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, we do not expect personal information (including financial information) to be shared on that type of forum and would recommend more secure channels being utilised for the transmission of personal and/or sensitive information.


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.


UNSOLICITED PERSONAL INFORMATION

If we receive 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 purposes of collecting personal information above. 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 purposes for collecting it, 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 individuals to consent to our use and disclosure of 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 associates;
  • our privacy policy and where it can be found; and
  • any disclosure of personal information that we make to an overseas entity.


DIRECT MARKETING

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 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 an email we will provide an 'unsubscribe' function within the email.


We will keep appropriate records to ensure those individuals that have made requests 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. We do not use sensitive information for the purposes of direct marketing.


CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

We may disclose your information to organisations overseas who are contracted to us for the purposes of audits of loan files to ensure that legislative, regulatory and industry expectations have been met. We may store your information in the cloud or other types of networked or electronic storage.


We may use cloud storage and IT servers that may be located overseas to store the personal information we hold. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held.


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; however, we do not use or disclose tax file numbers for any purpose when engaging in credit activities.


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 take reasonable steps to protect the personal information we hold from misuse, interference and loss, as well as unauthorised access, modification or disclosure. Some of the controls that are used may include:

  • Access restrictions to data using physical and electronic barriers;
  • Appropriate training of representatives with confidentiality;
  • Education of representatives in recognising possible cyber intrusions;
  • Governance around the provisions of information to third parties;
  • ICT security including firewalls, malware scanning and encryption of data.

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.

In accordance with the Australian Privacy Principles, we keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We will take reasonable steps to destroy personal information or ensure it is de-identified if that information is no longer needed.


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 when it is reasonable and practicable to do so. We will verify the individual's identity prior to disclosing any personal information. When we receive a request for access we will usually respond to the individual within 7 days.


DISCLOSURE AND ACCESS OF INFORMATION

We will not give access to personal information that we hold about an individual where it is unreasonable or impracticable to provide access, or in circumstances where the request would likely:

  • pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
  • unreasonably affect the privacy of other individuals;
  • be frivolous or vexatious;
  • relate to anticipated legal proceedings where the correct method of access is by the process of discovery;
  • 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 unlawful activity or misconduct relating to our functions or activities;
  • prejudice an enforcement related activity of an enforcement body (such as ASIC); or
  • reveal commercially sensitive information.


If we do not provide access to information we will provide written reasons and advise the individual they can access our Internal Dispute Resolution (IDR) and External Dispute Resolution (EDR) schemes if they are dissatisfied with our decision.


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. When we do not make requested corrections, we will provide reasons for our refusal and provide details of our IDR and EDR procedures.


OUR INTERNAL DISPUTE RESOLUTION (IDR) SCHEME

We are committed to providing you with the best possible service. If at any time we have not met our obligations or you have a complaint about the service that we provide, please inform us so we can work towards a resolution. We will endeavour to deal with your complaint promptly, thoroughly and fairly. If you have a complaint, the following steps are available to you.


In the first instance, please contact Sergio Coelho.

We will acknowledge receipt of your complaint within 1 business day. If we are unable to resolve the complaint to your satisfaction within 5 business days, we will escalate the complaint to the Complaints Officer.

You can also contact the Complaints Officer directly as detailed below:


COMPLAINTS OFFICER

Name: Mark Norman Address: 325 Churchill Ave, Subiaco WA 6008, Australia Phone: 08 9286 6888 Email: compliance@spfgroup.com.au

Within 30 calendar days from the date you lodged the complaint with us, we will write to you advising you of the outcome of the investigation and the reason/s for our decision, or if required, we will inform you if more time is needed to complete the investigation.


OUR EXTERNAL DISPUTE RESOLUTION (EDR) SCHEME

If you do not think we have resolved your complaint to your satisfaction, or you have not heard from us within 30 calendar days, you may refer the matter to the EDR scheme, the Australian Financial Complaints Authority (AFCA).

You may also refer the matter to an EDR scheme at any time, but if our IDR process is still in progress, they may request that our IDR process be complete before considering the matter further.

The Australian Financial Complaints Authority (AFCA) EDR process is available to you at no cost:


Australian Financial Complaints Authority (AFCA)

Email: info@afca.org.au Phone: 1800 931 678 Address: GPO Box 3, Melbourne VIC 3001, Australia

MY LICENSEE AFCA DETAILS

Mortgage Specialists Pty Ltd AFCA Member Number: 42176

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