By providing personal information to us, you consent to the collection, use and disclosure of your information in accordance with this Policy and any other arrangements that apply between us. As some of our related companies may have specific legal requirements, they may have separate, but consistent policies. Please view these if they are more relevant to your relationship with the Group.
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.
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
ID information such as your name, postal or email address, telephone numbers, and date of birth (this may also include voice biometrics, where permitted); and
other information we think is necessary.
Over the course of our relationship with you, we may collect and hold additional personal information about you, including transactional information, complaint or enquiries about your product or service.
What do we collect via your website activity?
If you’re an internet customer of ours, we monitor your use of internet services. This is done to ensure we can verify you and can receive information from us, to identify ways we can improve our services for you and to understand you better.
If you start but don’t submit an on-line application, we can contact you using any of the contact details you’ve supplied or other contact details we have for you to offer help (unless the application states your use is anonymous). 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 calculators or other programs. Although the information collected does not identify an individual, it does provide us with useful statistics so that we can analyse and improve our online services.
How do we collect your personal information?
How we collect and hold your information
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. In addition, when you use our website or mobile applications we may collect information about your IP address, location or activity. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details1, including doing e-verification of identity (e-Know Your Customer). However, we’ll never ask you for your security details in this way – if you are ever unsure, just contact us.
We will try to collect personal information directly from you unless it’s unreasonable or impracticable. For this reason, it’s important that you keep your contact details up-to-date.
How we collect your information from other sources
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:
we collect information from Choice Home Loan brokers about the credit or lease made available to you arising out of the services we provide you; and
at your request, we exchange information with your legal or financial advisers or other representatives.
We may collect information about you that is publicly available, for example from public registers, social media or made available by third parties. We do this where:
we distribute or arrange products on behalf of others, including our trusted partners;
we can’t get hold of you and need to update your contact details;
we need information from third parties about an application you make through us;
we are checking the security you are offering;
we can learn insight about your financial needs, such as through property information;
you have consented to third parties sharing it with us, such as:
organisations we sponsor or have loyalty programs with; or
media organisations, and social networking sites.
We may use or disclose information about you in order to combine the information that we hold about you with information about you collected from or held by external sources. We do this in order to enable the development of consumer insights about you so that we can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services that may be of interest to you. Where those insights are provided to others, such insights are based on aggregated information and do not contain any information that identifies you. We may also use service providers to undertake the process of creating these consumer insights.
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
provide you with the product or service you want;
personalise your experience with us;
verify your identity or protect against fraud; or
let you know about other products or services from across the Group that might better meet your financial, e-commerce and lifestyle needs.
How we collect and hold your credit information
We will collect your credit information from details included in any form you complete on our website and from any Choice Home Loans broker to whom we refer your enquiry.
What do we do when we get information we didn’t ask for?
Sometimes, people share information with us we haven’t sought out. Where this happens, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
When will we notify you that we have received your information?
When we receive personal information from you, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Where we collect your personal information from third parties (and you’re not necessarily aware), if that information can be used to identify you, we will take reasonable steps to notify you of the circumstances of that collection. We recommend our customers regularly review our website to review updates to this policy and our Privacy Notice www.choicehomeloans.com.au/privacy-policy.
How do we take care of your personal 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 are:
confidentiality requirements of our employees;
document storage security policies;
security measures for access to our systems;
only giving access to personal information to a person who is verified to be able to receive that information;
control of access to our buildings; and
electronic security systems, such as firewalls and data encryption on our websites.
We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We’re may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
How we use your personal information
What are the main reasons we collect, hold and use your information?
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:
provide you with information about products and services, including financial help, guidance and advice;
consider your request for products and services;
process your request for products and services; and
administer products and services which includes answering your requests and complaints and conducting market research.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about products and services from across the Group that might be of interest to you. We will not do this if you tell us not to. Unless you tell us not to, we may disclose your personal information to our related companies or to our trusted partners so they can tell you about their products and services.
We may conduct these marketing activities via email, telephone, SMS, iM, mail, or any other electronic means, including targeted advertising through NAB Group or non-Group websites. We may also market our products to you through third party channels (such as social networking sites) or via companies who assist us to market our products and services. If you don’t want to receive marketing offers in this way, please contact us.
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.
We may disclose your personal information to Choice Home Loans finance brokers that may be able to assist you with applying for credit. Also, with your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation outside of the Group.
Yes, You Can Opt-Out
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 know that you may prefer to receive some types of messages over others, so where possible we will offer you a choice. You can always change your mind or update these choices too.
Where you have subscribed to something specific (like to hear from one of our sponsored organisations) then these subscriptions will be managed separately. If you no longer wish to receive these emails click the unsubscribe link included in the footer of our emails.
What are the other ways we use your information?
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:
giving you information about a product or service;
processing your request for a product or service;
administering the product or service we provide you, which includes answering your requests and dealing with your complaints;
telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, iM, mail, or any other electronic means including via social networking forums), unless you tell us not to;
allowing us to run our business and perform administrative and operational tasks (such as training staff, risk management; developing and marketing products and services, undertaking planning, research and statistical analysis; and systems development and testing);
preventing or investigating any fraud or crime, or any suspected fraud or crime;
as required by law, regulation or codes binding us; and
for any purpose for which you have given your consent.
Who do we share your personal information with
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.
Sharing with the Group
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, but will not differ from those purposes outlined above. Where appropriate we may integrate the information we hold across the NAB Group to provide us with a complete understanding of your product holdings and your needs.
Sharing at your request
We may need to share your personal information with your representative or any person acting on your behalf.
Sharing with third parties
We may disclose your personal information to third parties outside of the Group, including:
those involved in providing, managing or administering your product or service;
Choice Home Loans brokers that may be able to assist with your enquiry;
authorised representatives of the Group;
fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
government or regulatory bodies (including the Australian Securities and Investments Commission and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
media or social networking sites that provide us with opportunities to place messages in front of you;
our accountants, auditors or lawyers and other external advisers;
organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
our joint venture partners that conduct business with us;
organisations involved in a corporate re-organisation or transfer of Group assets or business;
organisations that assist with our product planning, analytics, research and development;
mailing houses and telemarketing agencies and media organisations who assist us to communicate with you;
other organisations involved in our normal business practices, including our agents and contractors as well as our accountants, auditors or lawyers and other external advisers; and
where you’ve given your consent.
Sharing outside of Australia
The Group runs its business in Australia and overseas.
We do not share information about you with organisations outside Australia.
A Group member may need to share some of your information it collects from us about you with organisations outside Australia. Sometimes, they may need to ask you before this happens. You can view a list of the countries in which those overseas organisations are located at www.nab.com.au/overseas-countries-list/
We may store your information in cloud or other types of networked or electronic storage. 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 a Group member shares with them under a foreign law. In those instances, that Group member will not be responsible for that disclosure.
How do you access your personal information?
How you can generally access your 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 in a branch.
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.
If we can’t give you access, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
How do you correct your personal information?
How we correct your information
Contact us if you think there is something wrong with the information we hold about you.
Our contact details are at the end of this policy. 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.
How do you make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us. 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.
You can contact us by using the details below:
The Privacy Officer
Advantedge Financial Services
Level 10, 101 Collins Street
Melbourne Vic 3000
Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
What if you want to interact with us anonymously or use a pseudonym?
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.
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website. Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement. In addition, over the course of our relationship with you, we may tell you more about how we handle your information. We recommend that you review these statements too as they may have more specific detail for your particular product.
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
Advantedge Financial Services
Level 10, 101 Collins Street
Melbourne Vic 3000
1 However we’ll never ask you for your security details in this way – if you are ever unsure, just contact us.
Choice Home Loans website privacy notice
Pennley may collect personal information from a Choice HL website user’s use of that website. Wherever the CHL website invites a user to disclose that user’s or any third party’s personal information by completing a field on the CHL website, the CHL website must include text inviting that user to click through a link, within that text, to the CHL privacy notice.