Respecting your privacy
Central to the success of Spotter Finance (who act as an authorised representative for Crown Wealth Group Pty Ltd) is our commitment to our clients.
We honour without reservation our obligation to respect and protect the privacy of the personal information of individuals with whom we deal.
The information we collect and hold
Whenever it is reasonable and practical to do so, we collect information about you directly from you. In some cases, we collect personal information from third parties including public sources, our related companies, referrers, brokers, agents, your adviser(s) and our service providers including credit reporting bodies and information service providers.
We may also collect information about you because we are required or authorised by law to collect it. There are laws that which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.
As we offer a diverse suite of services ranging from Life Insurance, Income Protection, Home Loans & Credit Cards, it is important that you understand your rights and our obligations with respect to our core offerings and the requirements we adhere to under each service we offer.
Insurance Product Application
We collect personal information about you which is reasonably necessary to:
- provide you with quality products or services
- consider applications and approaches you make to us
- maintain your contact details
- fulfil our legal obligations under applicable laws and rules, such as those relating to taxation and Anti-Money Laundering and Counter-Terrorism Financing.
We generally hold personal information relating to:
- the products and services we provide or have provided to you
- your financial interests and sometimes your financial position, if you are a customer or potential customer of ours
- your name, contact details and identification information (including government-issued tax numbers)
- records of our interactions with you, including by telephone, email and online
- your enquiries or complaints.
We only collect sensitive information about you when required by applicable laws or rules. Sensitive information includes information relating to:
- political or religious beliefs
- sexual preferences
- criminal convictions
- membership of professional or trade associations or unions
- health information.
We collect health information where we offer products with an insurance component to our clients. We do not use or share that information for any purpose other than the underwriting or administration of a client's policy or account, or as otherwise disclosed to the customer when the information was collected.
We may collect information about your affiliation with certain organisations such as professional associations. We also collect personal information from people who submit applications or register interest with Spotter Finance Pty Ltd
How this information may be used
We only use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would be reasonably expected without your permission. For example, we may use and disclose personal information to process applications, administer and manage our products and services including monitoring, auditing, and evaluating those products and services, model and test data, communicate with you and deal with any complaints or enquiries.
We may also use and disclose your personal information (on a confidential basis) about acquisitions, mergers or changes in control of our business or assets.
We may from time to time also use your personal information to provide information about products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this. We do not sell personal information to other organisations to allow them to do this.
We may share personal information inside Spotter Finance Pty Ltd or with our license holder (Crown Wealth Group Pty Ltd) and may disclose personal information outside Spotter Finance Pty Ltd:
- as required by relevant laws or rules, such as those relating to Anti-Money Laundering and Counter-Terrorism Financing
- to service providers who provide services including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, trustee, securitisation, website and technology services
In some circumstances the parties with whom we share personal information may operate outside of Australia. Where this occurs, we take steps to protect personal information against misuse or loss.
Credit Card & Credit Facility Application - The information 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;
- other contact details such as social media handles;
- financial details such as your tax file number; and
- other information we think is necessary.
What do we collect via your website activity?
If you’re an internet customer of ours, we monitor your use of our 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.
If you start but don’t submit an on-line application, we may contact you using any of the contact details you’ve supplied to offer help in 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 web applications is secure.
How do we collect your personal information?
There are several ways in which we may 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 website. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.
How we collect your information from other sources
Sometimes, we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:
- we collect information from third parties about the loan or lease made available to you arising out of the services we provide you;
- we can’t get hold of you and we rely on public information to update your contact details; or
- we exchange information with your legal or financial advisers or other representatives.
What if you don’t want to provide us with your personal information?
If you don’t provide your information to us, it may not be possible:
- for us to give you the credit assistance you seek from us;
- to assist in finding a loan or lease relevant to your circumstances;
- verify your identity or protect against fraud; or
- to let you know about other products or services that might be suitable for your financial needs.
How we collect and hold your credit information
We will collect your credit information you have answered the enquiries we make of you relating to the credit assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
- your co-loan applicants or co-borrowers;
- your guarantors/proposed guarantors;
- your employer, accountant, real estate agent or other referees;
- your agents and other representatives like the person who referred your business to us, your solicitors, conveyancers and settlement agents;
- organisations that help us to process credit applications;
- organisations that check the security you are offering such as valuers;
- bodies that issue identification documents to help us check your identity; and
- our service providers involved in helping us to process any application you make for credit through us.
What do we do when we get information we didn’t ask for?
Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, 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 directly, 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.
Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
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:
- document storage security policies;
- security measures for access to our systems; and
- only giving access to personal information to a person who is verified to be able to receive that information
We may 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 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:
- give you credit assistance;
- give you information about loan products or related services;
- consider whether you are eligible for a loan or lease or any related service you requested;
- assist you to prepare an application for a lease or a loan;
- administer services we provide, for example, to answer requests or deal with complaints; and
- administer payments we receive, or any payments we make, relating to your loan or lease.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about other products or services we or a third party make available and that may be of interest to you. We will always let you know that you can opt out from receiving marketing offers.
With your consent, we may disclose your personal information to third parties to connect 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.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.
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:
- identifying you;
- telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
- allowing us to run our business efficiently and perform general administrative tasks;
- preventing any fraud or crime or any suspected fraud or crime;
- as required by law, regulation or codes binding us; and
- any purpose to which you have consented.
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 Your Information
We may use and share your information with other organisations for any purpose described above.
Sharing with your representatives and referees
We may share your information with:
- your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); and
- your referees, like your employer, to confirm details about you.
Sharing with third parties
We may share your information with third parties in relation to services we provide to you. Those third parties may include:
- the mortgage aggregator through whom we may submit loan or lease applications to lenders or lessors on the mortgage aggregator’s panel;
- the Australian Credit Licence holder that authorises us to engage in credit activities;
- referrers that referred your business to us;
- lenders, lessors, lender’s mortgage insurers and other loan or lease intermediaries;
- organisations, like fraud reporting agencies, that may identify, investigate and/or prevent fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
- government or regulatory bodies (including ASIC and the Australian Tax Office) as required or authorised by law. In some instances, these bodies may share the information with relevant foreign authorities;
- guarantors and prospective guarantors of your loan or lease;
- service providers, agents, contractors and advisers that assist us to conduct our business;
- any organisation that wishes to take an interest in our business or assets; and
- any third party to which you consent to us sharing your information.
Sharing outside of Australia
We are not likely to disclose your information to organisations overseas. However, 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.
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.
We will give you access to your information in the form you want it where it’s reasonable and practical. 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:
- we believe there is a threat to life or public safety;
- there is an unreasonable impact on other individuals;
- the request is frivolous;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- it would be unlawful;
- it would jeopardise taking action against serious misconduct by you;
- it would be likely to harm the activities of an enforcement body (e.g. the police); or
- it would harm the confidentiality of our commercial information.
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’.
Keeping information accurate and up to date
We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
Keeping information secure
We use security procedures and technology to protect the information we hold. Access to and use of personal information within Spotter Finance Pty Ltd seeks to prevent misuse or unlawful disclosure of the information. If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
How you can access or correct your information
You can contact us as set out below to request access to or correction of your personal information. In normal circumstances, we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
Where we correct information
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.
Where we can’t correct information
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.
Time frame for correcting information
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.
If we can’t make corrections within a 30-day time frame or the agreed time frame, we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
What additional things do we have to do to manage your complaints about information?
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.
For all other complaints relating to information
If you make a complaint about things (other than an access request or correction request) in relation to your information, we will let you know how we will deal with it within seven days.
Ask for more time if we can’t fix things in 30 days
If we can’t fix things within 30 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.
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Dealing with Spotter Finance online
If you are an anonymous visitor, the information we collect is not capable of personally identifying you.
Once you have accessed our websites from an e-mail or other personalised communication sent to you or provided us with personal information by completing a form online, we may be able to identify you. If we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our websites, irrespective of how you access our sites (e.g. by clicking a link in an advertisement or from a third-party website). In addition, we may combine that information about your use of our websites with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information. If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).
A 'cookie' is a packet of information placed on a user's computer by a website for record keeping purposes. Cookies are generally used on Spotter Finance’s websites to:
- manage advertising - we use advertising companies to deliver our online advertising. When you see one of our ads on a third-party website, cookies are sometimes used to collect anonymous information about what pages you visit and the type of software you are using
- monitor traffic - we use tracking companies to gather anonymous information about how people are using our websites, this information includes time of visit, pages visited, and some system information about the type of computer you are using. We use this information to enhance the content and services offered on the site
- collect identifiable information about your use of our websites - if we have identified you as a result of you accessing our website from an e-mail or other personalised communication sent to you or providing us with personal information by completing a form online.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences).
Contact Us / How do you make a complaint?
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.
Alternatively, 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.
You can contact us by using the details below:
- Phone: 1300 793 143
- Email: firstname.lastname@example.org
- Fax: (03) 8672 3561 or 03 8677 6591
- Mail: Part 1, First Floor/240 Chapel Street, Prahran, VIC 3181
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.
Making a complaint regarding personal insurance.
Spotter Finance is an authorised Representative of Crown Wealth Group Pty Ltd for personal insurance. Crown Wealth Group is committed to providing a high standard of client service and to maintaining their reputation for honesty and integrity. If our level of service has failed to meet your expectations, we would like you to tell us about your concerns. Crown Wealth Group's complaint handling process is designed to ensure that your concerns are treated seriously and that your complaint is addressed promptly and fairly. Your complaint may be lodged either verbally or in writing and will be dealt with in strict confidence.
If you have a complaint about the service provided to you, you should take the following steps:
- Contact your adviser and discuss your concerns
- Contact our Client Service Team on 1800 696 654, or
- Contact the Compliance Manager, Crown Wealth Group, at PO Box 427, Fortitude Valley, Queensland, 4006 or via email: email@example.com
If you are not satisfied with how your complaint is handled you may direct your concerns to:
Financial Ombudsman Service (FOS)
GPO Box 3,
Melbourne VIC 3001
Tel 1300 780 808
Fax (03) 9613 6399
Making a complaint regarding a credit facility.
Rate Detective is the holder of an Australian Credit Licence. We are committed to providing a high standard of client service and to maintaining a reputation for honesty and integrity. If our level of service has failed to meet your expectations, we would like you to tell us about your concerns. Our complaint handling process is designed to ensure that your concerns are treated seriously and that your complaint is addressed promptly and fairly. Your complaint may be lodged either verbally or in writing and will be dealt with in strict confidence.
We have an Internal Dispute Resolution process and are also a member of an External Dispute Resolution Scheme.
Our complaints officer is:
- Contact: Phil Aldridge
- Telephone: 038 568 6000
- Email: firstname.lastname@example.org
- Fax: 03 8672 3561
- Mail: Phil Aldridge, Rate Detective Pty Ltd, Level 1, 240 Chapel Street, Prahran VIC 3181
In many cases, we will be able to resolve your complaint using our internal dispute resolution process. However, if we are unable to resolve your complaint to your satisfaction then you may refer the matter to our external dispute resolution scheme provider. This is a free service designed to provide you with an independent mechanism to resolve specific complaints.
Our external dispute resolution scheme provider is Australian Financial Complaints Authority. They may be contacted at:
- Telephone: 1800 931 678
- Email: email@example.com
- Website: http://www.afca.org.au/
- Mail: GPO Box 3, Melbourne VIC 3001
Need more help?
If you still feel your issue hasn't been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:
- Online: www.oaic.gov.au/privacy
- Phone: 1300 363 992
- Email: firstname.lastname@example.org
- Fax: +61 2 9284 9666
- Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
Policy updated 20 March 2014
Central to the success of Spotter Finance (who act as an authorised representative for Crown Wealth Group Pty Ltd) is our commitment to our clients.