Our commitment to protect your privacy
We understand how important it is to protect your personal information. This document 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 any other relevant law.
What information do we collect and how do we use it?
We will ask you for personal information when we assist you with your finance. When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The type of personal information we may collect can include (but is not limited to) name, address, date of birth, contact details, income, expenses, assets and liabilities, account balances, tax, bank and financial statements, social security details, identification documents, insurance, employment details and any other information we consider necessary.
If you are applying for finance the personal information we hold about you may also include credit information. Credit information is information which is used to assess your eligibility to be provided with finance and may include the ages and number of your dependants and cohabitants, as well as the length of time at your current address, 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.
Personal information may include any sensitive information (including health information) and may include any information you tell us about any vulnerability you may have. We use the information you provide to advise about and assist with your credit needs.
The way we use tax file numbers (TFN) and information received from a credit reporting agency about an individual is also restricted by law.
The Privacy (Tax File Number) Rule 2015 (TFN Rule) states that TFN information must only be collected, retained or disclosed by TFN recipients for a purpose authorised by taxation law, personal assistance law or superannuation law. A breach of the TFN Rule is an interference with privacy under the Privacy Act.
Our business is to understand and meet our customer’s need over their lifetime for a wide range of financial and other services. By law, we cannot provide advice without fully knowing and understanding your personal and financial circumstances. To do this effectively, we need to collect your personal information. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services.
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. We also use your information to send you requested product information and to enable us to manage your ongoing relationship with us e.g. invoicing, client surveys etc.
If you would rather not receive this information, email or write to us. If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
We may also use your information internally to help us improve our services and help resolve any problems.
What if you don’t provide some information to us?
If you don’t provide us with full information, we can’t properly advise or assist you with your credit needs.
How do we hold and protect your information?
We strive to maintain the reliability, accuracy, completeness, and currency of the personal information we hold and to protect its privacy and security. 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 hold the information we collect from you securely on our aggregators software
We ensure that your information is safe by encrypted security processes. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our credit licensee e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, re-organisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.
We may disclose your personal information as follows:
- Financial institutions, funders or other intermediaries for the provision of financial products such as mortgages, deposit bonds, investments, superannuation and life insurance
- To any of our associates, service providers, aggregators, licensees, technology providers, related entities or contractors, specialist advisers who have been contracted to provide us with administrative, financial, insurance, accounting, legal, information technology, research or other services;
- To companies that provide information and infrastructure systems to us;
- any person or entity who represents you including financial consultants, accountants, lawyers, mortgage brokers, persons holding power of attorney, guardians and advisers;
- To anyone, where you have provided us consent;
- To other insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
- Other guarantors or borrowers (if more than one) or borrowers or prospective borrowers of any credit you guarantee or propose to guarantee;
- Your referees, such as your employer, to verify information you have provided;
- To credit reporting or reference or identity verification agencies or insurance investigators or your employer;
- Where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), to government and law enforcement agencies or regulators.
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.
What we collect via your online activity
We collect most personal information directly from you. We may also collect information from you electronically, for instance, when you visit our website. If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you. Your internet protocol address (or “IP address”) is the numerical identifier from your device when you are using the internet. It may be necessary to collect your IP address for your interaction with some parts of our website.
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.
Credit reporting information
We may, on your authority, request a Credit Report from one of the Credit Reporting Agencies on your behalf. Credit Reports provide information on your previous Credit history and may prove useful in determining the lender more suited to your circumstances. A credit report gives us information about your credit history. Credit reports are provided by credit reporting bodies who collect and share credit information with credit providers and other service businesses like phone companies. The Privacy Act limits the information we can give to credit reporting bodies, and that they can give us.
The credit reporting body we use is Equifax Pty Ltd. You can download a copy of their privacy policy at Equifax.com.au/privacy
We use information from credit reporting bodies to confirm your identity, assess your ability to manage credit, and manage our relationship with you. A copy of the Credit Report will be made available on your request.
How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.
If you wish to access or correct your personal information please write to Katie Dickson, Director Napoleon Finance E: katie@napoleonfinance.com.au
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
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, or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you. If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct or update the information. If appropriate we will correct or update the personal information at the time of the request; otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected or updated the personal information within 30 days.
We may need to consult with other entities as part of our investigation. If we refuse to correct or update personal information we will provide you with our reasons for not correcting the information.
We do not charge for receiving a request for access to personal information or for complying with a correction request. We do not charge for providing access to personal information.
Your consent
By asking us to assist with your credit needs, you consent to the collection and use of the information you have provided to us for the purposes described above.
Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact Katie Dickson, Director Napoleon Finance E: katie@napoleonfinance.com.au
Complaints
Internal Dispute Resolution
If you do have a complaint, please let us know by email, because if we don’t know about it we can’t fix it. You may also contact us by email addressed to; The Complaints Officer at Katie Dickson, Director Napoleon Finance PH: 0408951092 E: katie@napoleonfinance.com.au, please make sure you include as much information as you can.
You should explain the details of your complaint as clearly as you can. You must do this in writing. When we receive a complaint, we will attempt to resolve it promptly.
Change in our Privacy Policy
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.
As a consequence we may change this privacy policy from time to time or as the need arises.
For more information on your privacy rights please visit www.privacy.gov.au
