Choice Aggregation Services Privacy Policy

Our commitment to protect your privacy

We understand how important it is to protect your personal information. This policy sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information. 

We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and the Notifiable Data Breach scheme established under the Act.  

Periodically we will update our privacy policy. You can always find the most up-to-date version on our websites. By using our services, you consent to the terms of this Policy and agree to be bound by it. 

About Choice Aggregation Services

Choice Aggregation Services are part of the broader Loan Market Group. 

Choice Aggregation Services collects personal information about borrowers, broker clients or their associates in the course of performing services for mortgage brokers and their associates.

In this policy, “we”, “us” and “our” refers to Choice Aggregation Services and our related businesses. 

What Information do we collect?

We collect most personal information directly from you, whether in person, on the phone, electronically or if you deal with us in some other way. 

When we refer to personal information we mean information or an opinion from which your identity is reasonably apparent. Typically this will refer to:

Credit related information - information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

Identification Information - this may include your name, date of birth, address, account details, occupation, and any other information we may need to identify you.If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

Financial information - information required for making credit-related decisions, such as credit reports from credit reporting bodies (CRBs), bank account information, employment status, income and expenses, assets and liabilities and credit and loan repayment history. We may also collect the ages and number of your dependants and cohabitants as part of any finance application.

Sensitive Information - the personal information we collect may also include sensitive information — such as information about your religion, ethnicity, health or criminal record. The Privacy Act protects your sensitive information and we will generally only collect this information from you if it is reasonably necessary and with your consent.

Why we collect your information

We collect your personal information for the purposes of assessing your application for finance and managing that finance. This allows us to:

  • verify your identity;
  • assist you in obtaining approval or the provision of a product or service;
  • provide the products and services you require and assist in managing these over time;
  • contact you, for example if we need to tell you something important;
  • conduct appropriate checks for credit-worthiness and for fraud;
  • manage our risks and help identify and investigate illegal activity;
  • research and develop our products or services provided
  • help us manage our relationship with you, including, for example, dealing with any feedback, disputes or enquiries or ;
  • conduct and improve our businesses and improve your customer experience;
  • comply with our legal obligations and assist government and law enforcement agencies or regulators
  • provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated (see below for more details)

Direct marketing

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.

If you do not wish to receive this marketing information, you can make us aware at any time by writing to us at compliance@loanmarket.com.au. If the direct marketing is by email you may also use the unsubscribe function. 

How we collect your personal information

We may collect personal information in a number of ways, including:

  • directly from you, such as when you provide information to your broker, in application forms or when you submit your personal details through our website;
  • from your joint applicants, co-applicants or guarantors;
  • when you visit our websites;
  • from third parties such as social media platforms, marketing websites, related companies, or CRBs;
  • from your representatives, e.g. solicitors, accountants, conveyancers, builders, agents;
  • from referral partners, who refer your business to us or;
  • when legally required to do so -- for example, in the provision of specific credit services.

How we disclose your personal information

We may disclose your personal information:

  • Australian Banks, non-bank lenders and providers of credit, financial or insurance services;
  • to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres;
  • to associated businesses that may want to market products to you;
  • to companies that provide information and infrastructure systems to us;
  • to anybody who represents you, such as finance brokers, lawyers and accountants;
  • to anyone, where you have provided us consent;
  • where we are required to do so by law, such as under the Anti-Money  Laundering and Counter Terrorism Financing Act 2006 (Cth);
  • to investors, agents or advisers, or any entity that has an interest in our business; or
  • to your employer, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or

(b) you have consented to us making the disclosure.

Transfer of Information Overseas

We may disclose personal information to our related entities, third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information. 

Further, we will only  transfer personal information we have collected about you overseas, if permitted to do so under the Australian Privacy Principles.

We may disclose your personal information to entities located outside of Australia, including the following:

  • our data hosting and other IT service providers, located in various countries; and
  • other third parties located in various foreign countries, including New Zealand, the Philippines & USA.

Your personal information may also be stored in the cloud in an overseas country. 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.

In the event that a disclosure is made in an overseas country, while they will often be subject to confidentiality or privacy obligations, they will not always follow the particular requirements of Australian privacy laws.  

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Updating, accessing & correcting your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings. An explanation will be provided to you if we deny you access to the personal information we hold about you.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete. If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate, we will correct the personal information. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.

If for any reason we refuse to correct personal information we will provide you with our reasons for not correcting the information.

Business without identifying you

In most circumstances, it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.

How do we protect your 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 include:

  • Confidentiality requirements of our employees; 
  • document storage security policies; 
  • security measures for access to our systems; 
  • only providing access to personal information to a person who is verified to be able to receive that information; 
  • controlled access to our buildings; 
  • and electronic security systems, such as firewalls and data encryption

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 also take reasonable steps to destroy or de-identify your personal information when your personal information is no longer required for our business purposes.

Complaints & Further Information

If you are dissatisfied with how we have dealt with your personal information we want to hear from you. You can contact our complaints officer at compliance@loanmarket.com.au

We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.

If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.

You may also request further information about the way we manage your personal information by contacting us.