PRIVACY POLICY

Your Privacy

At Simplify Finance we are committed to protecting your privacy as an online visitor to our website. We use the information we collect about you to maximize the services that we provide to you. Simplify Finance respects the privacy and confidentiality of the information provided by you and adheres to the Australian Privacy Principles. Please read our separate Privacy Policy below carefully.

You may change your details at any time by advising us in writing via email. All information Simplify Finance receives from its customers is protected by our secure server. Simplify Finance secure server software encrypts all customer information before it is sent to us. Furthermore, all customer data collected is secured against unauthorized use or access. Credit card information is not stored by us on our servers.

Storage and Security of Your Information

We receive and store information you enter on our website or give us in any other way from time to time. You may provide basic contact information such as your name, phone number, address, and email address to enable us to send information or process your product order and we may also collect additional information at other times, including but not limited to, when you provide feedback, change your content or email preferences, respond to a survey, or communicate with Simplify Finance customer support or queries.

We may use personal information collected from you for the purpose of providing you with direct marketing material, updates regarding our website and information in the form of a newsletter. This will only apply if you have registered or subscribed to such publications by your registering your details with us. However if you wish to cease receiving any such information you may let us know either by email or unsubscribing at any time and your request will be actioned as soon as possible.

Individual profile and company details are not used for any other purpose. Details are only supplied to a third party supplier when it is required by law, for goods or services which you have purchased or to protect Simplify Finance copyright, trademarks and other legal rights.

We respect the privacy of our online visitors. We may collect information on or through this website that can personally identify you. For example, we collect personally identifiable information which you volunteer to us to respond to visitor questions and comments about us and our products and services, and to mail e-newsletters (“Personal Data”).

We will use all reasonable means to protect the confidentiality of your Personal Data while in our possession or control. We will not knowingly share any of your Personal Data with any third party other than our service providers who assist us in providing the information and/or services we are providing to you. To the extent that we do share your personal information with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this privacy policy. Some of our service providers may be overseas and may not be subject to Australian Privacy Laws. Please contact us if you require specific details.

Any non-personal information, communications and material you send to this website or to us by email, or which we obtain from third parties without promises of confidentiality, may be kept, used and disclosed by us on a non-confidential basis. We are free to use and reproduce any such information freely, and for any purpose whatsoever. Specifically, we will be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose, including developing, manufacturing or marketing products.

Open and Transparent Management of Personal Information

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:

• 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 contact details (eg 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 (eg: transaction and saving statement), 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. Usually, credit-related information is exchanged between credit and finance providers and credit reporting bodies.

Sensitive Information
We may collect sensitive information from individuals if they apply for an insurance related product, or where it relates to the provision of a product or service related to our credit activities. 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 such as information about your religion, ethnicity, health or criminal record.

Where possible, we collect personal information directly from the individual. 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.

What Do We Collect via Your Website Activity and Internet Activity?

We you access our website, we 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 secures channels being utilized 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. We will do this by looking at our relationship with the individual and whether the personal information relates to our relationship with them.

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 the personal information, 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.
• If we know that as part of our relationship with an individual that we are likely to disclose their personal information to another identifiable entity, we will usually notify the individual of the following matters:
• the identity and contact details of that organisation; and
• why their information may be disclosed to the organisation.

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.

If we purchase personal information for the purposes of direct marketing we will conduct appropriate due diligence to ensure appropriate consents from the individuals have been obtained.

Cross-Border Disclosure of Personal Information

We may disclose your information to organizations 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 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’s 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.

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 hold personal information on secure IT systems. All IT systems are appropriately updated with passwords, virus scanning software and firewalls when needed.

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.

We will usually destroy personal information that is held electronically and in paper form seven years after our relationship with the individual ends. We will do this by shredding paper copies and deleting electronic records containing personal information about the individual or permanently de-identifying the individuals within those records.

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 an individual requests access to their personal information we will conduct a search of our customer relationship database. This search will also indicate if there are any paper records that contain personal information.

Disclosure and Access of Information

We will not give access to the 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 access the privacy of other individuals;
• be frivolous or vexatious;

relate to anticipated legal proceedings, and the correct method of access to personal information is by the process of discovery in those legal proceedings;
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 a matter where unlawful activity or misconduct that relates to our functions or activities;
prejudice an enforcement related activity of an enforcement body (such as ASIC); or
reveal commercially sensitive information.

When we receive a request for access we will usually respond to the individual with 7 days. Depending on the nature of the request we may be able to provide the personal information at the same time as when the request is made.

If the individual is requesting a large amount of personal information or the request cannot be dealt with immediately, then after we have investigated the request for access we will advise the individual what personal information we hold and provide details of that personal information.

We will comply with all reasonable requests by an individual to provide details of the personal information that we hold in the requested format.

If we do not provide access to the information we will provide written reasons setting out why we do not believe we need to provide access. We will also advise the individual they can access our Internal Dispute Resolution (IDR) and External Dispute Resolution (EDR) schemes if they are dissatisfied with a decision not to provide access to personal information.

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.

If we correct any personal information that we have previously disclosed, we will take reasonable steps to notify the entity to which we disclosed the information of the correction. We may not always make corrections to an individual’s personal information. When we do not make requested corrections, we will provide reasons for our refusal to make the correction and provide details of our IDR and EDR procedures.

If, after notifying the individual of our refusal to correct personal information, the individual requests us to issue a statement on the record that contains the personal information, we will take reasonable steps to do so.

Cookies

A cookie is a small file placed in your web browser that collects information about your web browsing behaviour. Use of cookies allows a website to tailor its configuration to your needs and preferences. Cookies do not access information stored on your computer or any personal information (e.g. name, address, email address or telephone number). Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of a website

Our website uses cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

Disclosure of Your Information

We may from time to time need to disclose certain information, which may include your Personal Data, to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request. Also, Simplify Finance may use your Personal Data to protect the rights, property or safety of Simplify Finance its customers or third parties.

Finally, if there is a change of control in one of our businesses (whether by merger, sale, or otherwise), or a sale or transfer of its assets, customer information, which may include your Personal Data, could be disclosed to a potential purchaser under an agreement to maintain confidentiality, or could be sold or transferred as part of that transaction. And finally we would only disclose your information in good faith and where required by any of the above circumstances.

Third Parties

Simplify Finance does not and will not sell or deal in personal or customer information. We will never disclose your personal details to a third party except the necessary information required by providers of products or services you have purchased or to protect the rights, property or safety of Simplify Finance, its customers or third parties or if required by law.

We may however use in a general sense without any reference to your name, your information to create marketing statistics, identify user demands and to assist it in meeting customer needs generally. In addition, we may use the information that you provide to improve our website and services but not for any other use.

Security

Simplify Finance strives to ensure the security, integrity and privacy of personal information submitted to our website, and periodically updates its security measures in light of current technologies.

Links

This website may contain links to other websites. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Simplify Finance is not responsible for the privacy practices of such other websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

Change in Privacy Policy

As we plan to ensure our privacy policy remains current, this policy is subject to change. We may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on this website. Please return periodically to review our privacy policy.

If you have any questions or concerns at any time about our privacy policy or the use of your personal information, please contact us at Simplify Finance and we will respond within 48 hours.

What Happens if You Want To Complain?

If you have concerns about whether we have complied with the Privacy Act or this privacy policy and would like to make a complaint please contact our Privacy Representative by email at compliance@spfgroup.com.au or on 08 9286 6888.

Examples of issues include internet privacy complaints, security breaches and misuse of personal information. Your complaint will be considered through our internal complaints resolution process and we will try to respond with a decision within 30 days of you making the complaint.

If you remain dissatisfied with how your compliant has been managed you may contact the following entities:

1. The Australian Financial Complaints Authority (AFCA)
Phone: on 1800 931 678,
Email: at info@afca.org.au,
In writing: GPO Box 3, Melbourne VIC 3001

2. Office of the Australian Information Commissioner (OAIC)
Email: www.oaic.gov.au
Phone: or 1300 363 992

Any issues regarding spam or telemarketing will generally be referred by OAIC to the Australian Communications and Media Authority (ACMA).