We respect your personal information, and this Privacy Policy explains how we handle it. The policy covers Brighten Home Loans Pty Ltd and RAFG Pty Ltd(referred to as ‘the Group’ or ‘we/us/our’ in this policy).
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.
The types of information that we collect and hold about you could include:
When we are checking your credit worthiness and at other times, we might collect information about you from and give it to credit reporting bodies. This information can include:
ID information: a record of your name(s) (including an alias or previous name), date of birth, gender, current or last known address and previous two addresses, name of current or last known employer and drivers licence number.
Information request: a record of a lender asking a credit reporting body for information in relation to a credit application, including the type and amount of credit applied for.
Default information: a record of your consumer credit1 payments being overdue.
Serious credit infringement: a record of when a lender reasonably believes that there has been a fraud relating to your consumer credit or that you have avoided paying your consumer credit payments and the credit provider can’t find you.
Personal insolvency information: a record relating to your bankruptcy or your entry into a debt agreement or personal insolvency agreement.
Court proceedings information: an Australian court judgment relating to your credit.
Publicly available information: a record relating to your activities in Australia and your credit worthiness.
Consumer credit liability information: certain details relating to your consumer credit, such as the name of the credit provider, whether the credit provider has an Australian Credit Licence, the type of consumer credit, the day on which the consumer credit was entered into and terminated, the maximum amount of credit available and certain repayment terms and conditions.
Repayment history information: a record of whether or not you’ve made monthly consumer credit payments and when they were paid.2
Payment information: If a lender gave a credit reporting body default information about you and the overdue amount is paid, a statement that the payment has been made.
New arrangement information: If a lender gave a credit reporting body default information about you and your consumer credit contract is varied or replaced, a statement about this.
We base some things on the information we get from credit reporting bodies, such as:
Information that we get from a credit reporting body or information we derive from such information is known as credit eligibility information.
Sometimes we need to collect sensitive information3 about you, for instance in relation to some insurance applications. This could include things like medical checks, medical consultation reports or other information about your health. Unless required by law, we will only collect sensitive information with your consent.
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth Anti-Money Laundering law.
We may disclose personal information about you to an organisation providing verification of your identity, including CRBs, and organisations such as Document Verification Service which provide on-line verification of your identity. The organisation will give us a report of whether that personal information matches personal and credit information held by the organisation. If we use these methods and are unable to verify your identity in this way we will let you know. We may also use information about your Passport, state or territory driver licence, Medicare card, citizenship certificate, birth certificate and any other identification documents (including documents of a foreign country) to match those details with the relevant registries using third party systems and record the results of that matching.
If you use our online services, we monitor your use of our online 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 online services is secure.
We also collect de-identified information if you use one of our Group calculators or other programs. Although the information collected does not identify an individual, it does provide the Group with useful statistics so that we can analyse and improve our online services. For more information on how we use cookies and tracking tags see our Cookies Policy (detailed below).
We understand that your personal information needs to be looked after and isn’t something you leave lying around for just anybody to take. So 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 many ways we 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 websites. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.4
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:
If you don’t provide your personal information to us, we may not be able to:
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:
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, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
Because we offer a range of services and products, 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:
Given our experience, we think we’ve learnt a lot of things along the way and we’d like to share what we know about our products with you. We may use or disclose your personal information to let you know about products and services from across the Group that might better serve your financial, e-commerce and lifestyle needs, or running competitions or promotions and other opportunities in which you may be interested.
We may conduct these marketing activities via email, telephone, SMS, iM, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites), or based on your use of Group programs. We will always let you know that you can opt out from receiving our third party or Group program marketing offers.
Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.
With your consent, we may disclose your personal information to third parties such as mortgage lenders, insurers, brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time.
You can let us know at any time if you no longer wish to receive direct marketing offers from the Group (see ‘Contact Us’). We will process your request as soon as practicable.
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:
In addition to the ways for using personal information mentioned above, we may also use your credit information to:
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.
We may share your personal information with other Group members. This could depend on the product or service you have applied for and the Group member you are dealing with.
We may need to share your personal information with:
We may disclose information about you to a credit reporting body if you are applying for credit or you have obtained credit from us or if you guarantee or are considering guaranteeing the obligations of another person to us or you are a director of a company that is loan applicant or borrower or guarantor. When we give your information to a credit reporting body, it may be included in reports that the credit reporting body gives other organisations (such as other lenders) to help them assess your credit worthiness.
Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get credit from other lenders.
We may share your personal information with third parties outside of the Group, including:
The Group runs its business in Australia.
A Group member may need to share some of your information it collects from us about you (including credit information) with organisations outside Australia. Sometimes, they may need to ask you before this happens.
Some credit reporting agencies, title insurers and other third parties have operations outside of Australia. The countries in which they have related corporations include: the Philippines, USA, Canada, the United Kingdom, Malaysia, India, China, Hong Kong SAR, Macau SAR, Indonesia, Singapore and Vietnam.
We may store your information (including personal and credit-related information) in cloud or other types of networked or electronic storage and will take reasonable steps to ensure its security. However, 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. If your information is stored in this way, disclosures may occur in countries other than those listed.
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.
We will not share any of your credit information with a credit reporting body, unless it has a business operation in Australia. We are not likely to share credit information we obtain about you from a credit reporting body or that we derive from that 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 or at our office. We will give you access to your information in the form you want it where it’s reasonable and practical (such as 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.
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:
In relation to credit eligibility information5, the exceptions may differ.
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’.
Where you request access to credit information about you that we’ve got from credit reporting bodies (or based on that information), you have the following additional rights.
We must:
We may also restrict what we give you if it would harm the confidentiality of our commercial information.
If we refuse to give access to any credit eligibility information, we will tell you why in writing. If you have concerns, you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
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:
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.
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:
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.
If you ask us to correct credit information, we will help you with this in the following way.
Whether we made the mistake or some one 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.
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.
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.
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.
Brighten Home Loans has an Internal Dispute Resolution (IDR) process to investigate and respond to all customer complaints within 45 days. Our IDR process is detailed below.
When we receive a complaint, the matter is referred to a manager with the appropriate knowledge and authority to undertake the investigation.
The manager completes a thorough investigation of your complaint and sources any supporting documentation if required. Once their investigation is completed, full details and results are returned to the Customer Relations team for assessment.
Once we receive the completed complaint investigation, we will then provide the outcome of the investigation and the reasons for reaching that decision to you in the same way you contacted us whether that’s by post, fax, email (if submitted via our website), or telephone.
If you aren’t satisfied with our response to your complaint, you have the option to contact the Australian Financial Complaints Authority (AFCA) with your concerns.
Before you contact AFCA, you must give Brighten Home Loans the opportunity to investigate and respond to your complaint.
You can contact the AFCA at www.afca.org.au or on 1800 931 678.
You can contact us by using the details below:
The Privacy Officer
Brighten Home Loans
BOX H338, Australia Square, NSW 1215
Phone +61 2 8880 6633
[email protected]
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.
If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with our external dispute resolution scheme, Australian Financial Complaints Authority (AFCA), which can be contacted at www.afca.org.au or on 1800 931 678 or the Office of the Australian Information Commissioner:
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.
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.
If we can’t fix things within 45 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.
As outlined above, if you apply for credit or have a credit facility with us, we may give your personal information to one or more credit reporting bodies. The contact details of the credit reporting bodies we may use are outlined below. Each credit reporting body has a credit reporting policy about how they handle your information. You can obtain copies of these policies at their websites.
If you believe that you have been or are likely to be the victim of fraud (including identity fraud), you can request a credit reporting body not to use or disclose the information they hold about you. If you do this, the credit reporting body mustn’t use or disclose the information during an initial 21 day period without your consent (unless the use or disclosure is required by law). This is known as a ban period.
If, after the initial 21 day ban period, the credit reporting body believes on reasonable grounds that you continue to be or are likely to be the victim of fraud, the credit reporting body must extend the ban period as they think reasonable in the circumstances. The credit reporting body must give you a written notice of the extension.
Credit reporting bodies can use the personal information about you that they collect for a pre-screening assessment at the request of a credit provider unless you ask them not to. A pre-screening assessment is an assessment of individuals to see if they satisfy particular eligibility requirements of a credit provider to receive direct marketing. You have the right to contact a credit reporting body to say that you don’t want your information used in pre-screening assessments. If you do this, the credit reporting body must not use your information for that purpose.
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:
The Privacy Officer
Brighten Home Loans
BOX H338, Australia Square, NSW 1215
Phone (61) 2 8880 6633
[email protected]
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. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
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.
Cookies
When you visit the website, our server places small pieces of data known as ‘cookies’ on your hard drive. Cookies are pieces of information that are transferred to your computer when you visit a website for record-keeping purposes. Most Web browsers are set to accept cookies. However, if you do not wish to receive any cookies you may set your Web browser to refuse cookies. We use cookies to provide us with aggregate (anonymous) information on how people use our website and to help us know what our customers find interesting and useful in our website. We do not link this information back to other information that you have provided to us.
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.
