Who are we?
‘We’, ‘us’ and ‘our’ refer to In Properties (Australia) Pty Ltd ATF In Properties Trust trading as In Properties for Investors ABN 57 261 984 283 and our related businesses. Our related businesses include but are not limited to Hunter Valley Home Loans Pty Ltd ATF Sirrah Business Trust trading as In Financial Services ACN 100 223970, Australian Credit Licence 494107.
Our commitment to protect your privacy
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 (APPs) and Part IIIA of the Privacy Act 1988, the Privacy (Credit Reporting) Code 2014 and any other relevant law.
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 personal information we hold about you may also include credit-related information.
Credit-related information means:
Credit information, which includes your identity: the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information; default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and;
Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.
We use your credit-related information to assess your eligibility to be provided with any finance. Usually, credit-related information is exchanged between credit and finance providers and credit reporting bodies.
The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you. When you use our website or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used and other user location information. We collect some of this information using ‘cookies’. We use ‘cookies’ to provide you with better and more customised service and with a more effective website.
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.
- to allocate a unique number to your internet browsers;
- to customise our website for you;
- for statistical purposes;
- to identify if you have accessed a Third Party Website; and for security purposes.
If you are applying for finance or provide a guarantee we may also collect the number and ages of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses. If you apply for any insurance product through us we may collect information about what is being insured, the beneficiaries and your health information including medical and lifestyle information from you or your health professionals. We will only collect health information from you with your consent.
Collection and use of information
We may collect personal information from you directly or via your use of our services. We will only collect personal information which is reasonably necessary for, or directly related to, our functions or activities. We collect personal information for the purposes of assessing your application for finance and managing that finance, establishing your identity, contacting you, managing our risk and to comply with our legal obligations. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. Improvements in technology also enable organisations like ours to collect and use information to get a more integrated view of our customers. From time to time we may offer you other products and services.
How do we collect your personal information?
Where reasonable and practical we will collect your personal information directly from you. Our other main sources for collecting your personal information are your loan co-applicants and guarantors or proposed guarantors. We may collect your personal information from credit reporting bodies, mortgage and finance brokers, employers and other people such as accountants, real estate agents and solicitors. We may also collect information about you that is publicly available, for example from public registers or social media, or made available by third parties.
Do we disclose your personal information?
We may disclose your personal information:
- to relevant lawyers, solicitors, vendors and builders in relation to your investment property
- to prospective funders or other intermediaries in relation to your finance requirements;
- to other organisations that are involved in managing or administering your property acquisition and relevant finance such as third party suppliers, printing and postal services, call centres, lenders mortgage insurers, trade insurers and credit reporting bodies;
- to associated businesses that may want to market products to you;
- to companies that provide information and infrastructure systems to us;
- to our agents, contractors, external service providers to outsource certain functions, for example, statement production, debt recovery and information technology support;
- to any person or entity who represents you, including finance brokers, lawyers, mortgage brokers, guardians, persons holding power of attorney and accountants;
- to any person or entity, where you have provided us consent;
- other guarantors or borrowers (if more than one) or prospective borrowers including in relation to any credit you guarantee or propose to guarantee;
- to our auditors, insurers, re-insurers and health care providers;
- to claims related providers, such as assessors and investigators who help us with claims;
- where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), government and law enforcement agencies or regulators;
- to investors, agents or advisers, trustees, rating agencies or any entity that has an interest in your finance or our business;
- to financial institutions, for example to process a claim for mistaken payment;
- to organisations that provide products or services used or marketed by us; or
- to your employer, former 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:
- the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
- you have consented to us making the disclosure.
Sensitive information is any information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information.
We will not ask you to disclose sensitive information, but if you elect to provide sensitive information it will also be captured and stored.
Credit related information
We exchange credit-related information for the purposes of assessing your application for finance and managing that finance. If you propose to be a guarantor, one of our checks may involve obtaining a credit report about you.
This credit-related information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit-related information we hold about you. The cloud storage and the IT servers may be located outside Australia.
When we obtain credit eligibility information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.
We may disclose your credit-related information to overseas entities that provide support functions to us, including our support staff located in the Philippines. You may obtain more information about these entities by contacting us. Where we do this, we make sure appropriate data handling and security arrangements are in place.
Security of information
The security of your information is very important to us.
We will take a range of measures and reasonable steps to protect your personal information. Your personal information will always be stored in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure. We regularly review developments in security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as totally secure.
If we no longer require your information, and we are legally permitted to, we will take all reasonable steps to destroy or de-identify the information.
We take reasonable steps to preserve the security of cookie and personal information in accordance with this policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).
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 marketing information, you may at any time decline to receive such information by telephoning us on (02) 4934 8550 or by emailing us at email@example.com. 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.
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.
Access and correction to your personal and credit information
We will provide you with access to the personal and credit-related information we hold about you. You may request access to any of the personal information we hold about you at any time.
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 or credit-related information, for example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious or if the information is commercially sensitive.
An explanation will be provided to you if we deny you access to the personal or credit-related information we hold about you.
If any of the personal or credit-related information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information by telephoning us on (02) 4934 8550 or by emailing us at firstname.lastname@example.org.
Where reasonable, we will correct the personal information at the time it is received. When appropriate, we will provide you with details about whether we have corrected the personal or credit-related information within 30 days.
We may need to consult with other finance providers or credit reporting bodies or entities as part of our investigation.
If we refuse to correct personal or credit-related information we will provide you with our reasons for not correcting the information.
Disclosure to overseas entities
We do not generally disclose personal information obtained from cookies to overseas entities in the course of our activities, with the exception of our support staff in the Philippines, who will only be using your personal information for purposes relating to our functions and activities as a property investment firm.
Please contact us on (02) 4934 8550 if you would like further information.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act and the Credit Reporting Code, you may contact our complaints officer on (02) 4934 8550.
We will acknowledge your complaint within seven days where reasonable and aim to resolve the complaint as quickly as possible. If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted at www.oaic.gov.au or 1300 363 992.
Change in our privacy and credit reporting 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 marketplace practices.
As a consequence we may change this policy from time to time or as the need arises. We will post any changes to this policy on our website.
You may request this policy in an alternative form by telephoning us on (02) 4934 8550 or by emailing us at email@example.com.
This privacy and credit reporting policy came into existence on 26th July 2017.