First Class Loans Privacy Policy
Privacy Policy – Respecting your privacy
This privacy policy applies to you if you are an individual who is a client, or a guarantor or potential guarantor of the obligations of a client, of a mortgage broker (your mortgage broker) that:
- obtains or makes use of mortgage aggregation services provided by Professional Lenders Association Network of Australia Pty Ltd as trustee for the PLAN Australia Unit Trust (PLAN Australia) ABN 24 086 084 832]; or
- is a credit representative (Credit Representative) of First Class Loans Pty Ltd ABN 57 163 556 474,
or if you give us information in relation to any product or service administered by PLAN Australia or First Class Loans Pty Ltd.We respect your personal information, and this Privacy Policy explains how we handle it. We are grateful for the trust and confidence you have in us to safeguard your privacy. The policy covers PLAN Australia and First Class Loans Pty Ltd.In this privacy policy, “we” or “us” means either of PLAN Australia or First Class Loans Pty Ltd. Each of us is a member of the National Australia Bank Group (the Group) of companies.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. As some of our related companies may have specific legal requirements, they may have separate, but consistent policies. Please view these if they are more relevant to your relationship with the Group.
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 (thismay also include voice biometrics where permitted);
- credit information such as details relating to credit history, credit capacity and eligibility for credit; and
- other information we think is necessary relating to the services we provide to your mortgage broker oryou.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 your mortgage broker or the products or services for which your mortgage broker assists you or its client to apply.
What do we collect via your website activity?
When you use our websites or mobile applications we may collect information about your location or activity including IP address or telephone number.If you use our online services, we monitor your use of those online interactions. This is done to ensure we can verify you and can receive information from us, to identify ways we can improve our services for you and to understand you better.
How do we collect your personal information?
How we collect and hold your information
We might collect your information when you make a complaint about your mortgage broker or the products or services for which your mortgage broker assisted you or its client to apply.Also, we might collect your information if you call us or use our websites.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We do this only if it’s necessary to do so. Instances of when we may need to include where:
- your mortgage broker gives us information about you in relation to your dealings with him or her or in anapplication for credit or other finance facilities; or
- the financial institution, that makes products or services available to you or the person whose obligationsyou guarantee, gives us your information in relation to managing commissions or requests they may have of us or your mortgage broker relating to those products or services.What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to supply services to your mortgage broker appropriately and enable them to conduct their business efficiently.How we collect and hold your credit information
We will collect your credit information from details given to us by you, your mortgage broker or the financial institution that makes products or services available to you or the person whose obligations you guarantee.What do we do when we get information we didn’t ask for?
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 information we obtain directly 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, 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.Where we collect your personal information from third parties (and you’re not necessarily aware), if that information can be used to identify you, we will take reasonable steps to notify you of the circumstances of that collection. We recommend our customers regularly review our website to review updates to this policy and our Privacy Notice (http://www.planaustralia.com.au/privacy-policy).
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 personalinformation 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:
- confidentiality requirements of our employees;
- document storage security policies;
- security measures for access to our systems;
- only giving access to personal information to a person who is verified to be able to receive thatinformation;
- control of access to our buildings; and
- electronic security systems, such as firewalls and data encryption on our websites.For more information on our online security and how you can protect yourself online see http://www.nab.com.au/personal/internet-banking/securityWe can 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’re also required to keep some of your information for certain periods of time under law, such as the Corporations Act, for example. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
How we use your personal information
What are the main reasons we collect, hold and use your information? We may use your information to:
- administer our relationship with your mortgage broker including monitoring compliance with credit law,answering requests and complaints and generally managing the services we provide; and
- answer requests made by financial institutions that make products or services available to you or theperson whose obligations you guarantee.
What are the other ways we use your information?
We may also use your personal information to:
allow us to run our business and perform administrative and operational tasks, like:
- training staff;
- risk management;
- systems development and testing, including our websites and other online channels;
- undertaking planning, research and statistical analysis;
preventing or investigating any fraud, crime or misconduct or any suspected fraud, crime or misconduct;
as required by law, regulation or codes binding us;
managing our relationships with financial institutions on our panel of financial institutions;
allowing us to run our business and perform administrative and operational tasks (such as training staff, risk management; developing and marketing products and services, undertaking planning, research and statistical analysis; and systems development and testing);
investigating and dealing with suspected or actual unlawful activity; and
for any purpose for which you have given your consent.
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 and Group members for any purposes for which we may use your information.
Also, we may share your information with third parties in relation to services we provide to your mortgage broker or in relation to any of the purposes described above. Those third parties may include:
- your mortgage broker or any individual or company that employs or contracts with your mortgage broker;
- in the case of the Aggregator, First Class Loans Pty Ltd as the ACL holder that authorises the Aggregator to engage in creditactivities;
- referrers that referred your business to your mortgage broker;
- lenders and financial services suppliers that have made products or services available to you;
- organisations, like fraud reporting agencies or industry associations, that may identify, investigate and/orprevent fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
- government or regulatory bodies as required or authorised by law. In some instances, these bodies mayshare the information with relevant foreign authorities;
- 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 are not likely to disclose your information to organisations overseas. However, 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
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 (like a copy of a phone call you may have had with us – we can put it on a disk for you). We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
If we can’t give you access, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
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.
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.
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:
Privacy Officer
First Class Loans Pty Ltd
63 Lennox Street
Richmond NSW 2753
Telephone: 1300 200 1110
Email address: [email protected]
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: [email protected]
- Fax: +61 2 9284 9666
- Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
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: Privacy Officer
First Class Loans Pty Ltd
63 Lennox Street
Richmond NSW 2753
Telephone: 1300 200 1110
Email address: [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 strict regulations that require us to know who we’re dealing with.
Changes to this Privacy Policy
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website. Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement. In addition, over the course of our relationship with you, we may tell you more about how we handle your information.
Would you like to have a Chat?
We are always happy to chat to you about any privacy issues or alike.