OUR COMMITMENT TO PROTECT YOUR PRIVACY
Real Flow Credit Fund Pty Ltd ACN 642 507 926, Real Flow Finance Pty Ltd ACN 164 355 051, Real Flow Distribution ACN 647 180 612 and their affiliates (collectively known as “Real Flow” and also referred to in this Policy as “us,” “we” and “our”) seek to provide the best possible service to its customers by providing the best possible range of financial products and services.
We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy, where we have your consent to do so, or as otherwise required or authorised by law. It is important to us that you are confident that any personal information we collect from you or that is received by us will be treated with appropriate respect ensuring protection of your personal information.
Our commitment in respect of personal information is to abide by the Privacy Act 1988 (Cth) and any other relevant law.
WHO IS REAL FLOW?
Real Flow is an organisation that provides loans and related services to approved customers. We focus on loans to finance the marketing costs associated with the sale of a property as well as loans to real estate agents secured against future receivable commissions. Our loans may be regulated by the National Consumer Credit Protection Act (NCCP) or may be unregulated.
We may also market our products and services.
When we refer to personal information we mean information or an opinion about you, from which you are, or may reasonably be, identified.
This information may include (but is not limited to) your name, date of birth, driver’s licence number, marital status, phone number, email address, address, nationality, employment history, income, assets and liabilities.
Due to the nature of the services provided by us, some of the information we collect may be sensitive information, including details about your health. For example, if you are applying for hardship we may ask you information about pre-existing medical conditions.
It is not common practice for us to collect other sensitive information about you (such as information about your religion, trade union membership, political opinion, sexual preference or criminal record). We will only collect sensitive information about you with your consent.
WHY WE COLLECT YOUR PERSONAL INFORMATION
We collect and receive personal information about you in order to conduct our business, including assessing and obtaining approval for our loans and accepting investments. From time to time we may offer other products and services.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Personal information may be collected by us in a number of circumstances, including when an individual:
- makes an enquiry with us via email or telephone;
- lodges a loan enquiry or requests a quote through our website;
- applies to invest in a product offered by us;
- attends an event hosted by us; or
- applies to work with us.
Where reasonable and practical we will collect your personal information only directly from you. However, we will also collect information about you from third parties such as from our contractors who supply services to us, through our referrers (such as real estate agents), from a publicly maintained record or from other individuals or companies as authorised by you. From time to time we may also purchase lists containing personal information about individuals from organisations offering such lists for marketing purposes.
If you do not provide the information requested by us, we may not be able to provide you with our services.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use your personal information for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your personal information for the following purposes:
- to provide you with the products or services you requested;
- to verify your identity;
- to assess, process and manage your application to be a customer, including to verify your details and assess our risk;
- to assess, process and manage your application to work with us; or
- for complaints handling or data analytics purposes.
TO WHOM WILL WE DISCLOSE YOUR PERSONAL INFORMATION?
To enable us to maintain a successful business relationship with you, we may disclose your personal information to:
- organisations that provide products or services used or marketed by us, including intermediaries (such as financial advisers), trustee companies, financial institutions and securitisers;
- your employer/s or referees, your guarantors, your professional advisors, your bank and any other organisation that may have or is considering having an interest in your loan, or in our business;
- companies and contractors who we retain to provide services for us, such as IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your personal information to provide those services;
- people considering acquiring an interest in our business or assets; and
- other individuals or companies authorised by you.
You also understand that we may disclose your personal information to any co-owner of a property that you nominate as security for any loan that we arrange for you.
By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case by case basis.
Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office.
We may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the Asia, Europe, North America, South America or other countries within the Australasian region. We may also use cloud storage and IT servers that are located offshore.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
If you apply for a loan with us, we may provide your ‘credit information’ to a credit reporting body. The credit reporting body may provide the information that we report about you to other credit providers to assist them to assess your credit worthiness. We may also obtain information that other credit providers have provided to a credit reporting body to use in our assessments of your credit-worthiness.
If you fail to meet your payment obligations in relation to any loan that we have provided to you, or any loan that we have arranged for you, or if you commit a serious credit infringement, we may report this to a credit reporting body
The information that we provide to a credit reporting body may sometimes be used for ‘pre-screening’ of direct marketing offers to be made by another credit provider. You may contact the credit reporting body to request that your ‘credit information’ is not used in this way.
If you think that you have been a victim of fraud or think that the ‘credit information’ a credit reporting body holds about you is incorrect, you may also contact the credit reporting body to ask them not to use or disclose your ‘credit information’. The credit reporting body must not use or disclose your ‘credit information’ for a period of 21 days after receiving your notice. For further information about credit reporting bodies, visit:
You can also contact us to access the ‘credit information’ that we hold about you and correct that information if you think that it is incorrect. See below for more information about this.
From time to time we may use your personal information to provide you with current information about mortgage loans, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Contacts using the contact details below. 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 our relationship that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we will ask you to inform us if any of your personal information has changed.
If you consider that any information we hold about you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
ACCESS TO YOUR PERSONAL INFORMATION
We will provide you with access to the personal information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the personal information we hold about you, including any credit-related personal information we hold about you, at any time.
To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
DENIED ACCESS TO PERSONAL INFORMATION
There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.
An explanation will be provided to you if we deny you access to your personal information we hold.
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. Such a situation would be where you make general inquiries about interest rates or current promotional offers.
HOW SAFE AND SECURE IS YOUR PERSONAL INFORMATION THAT WE HOLD?
We will take reasonable steps to protect your personal information, including your credit-related personal information, by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
FURTHER INFORMATION AND COMPLAINTS
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer(s) on the contact details below.
We will deal with any complaint by investigating the complaint, and providing a response to the complainant within 15 business days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree alternative time frames with you.
You can contact us by calling us on 1800 00 3569 emailing us on firstname.lastname@example.org or by writing to:
The Privacy Officer
Real Flow Credit Fund Pty Ltd
PO Box 33,
SEAFORTH NSW 2092
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 practices.