Privacy Policy

CAPE TO CAPE FINANCE PTY LTD's Privacy and Credit Reporting Policy

When you trust CAPE TO CAPE FINANCE PTY LTD with your personal and credit related information, we know you expect us to protect it and keep it safe.

We are committed to protecting your privacy and will comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Privacy (Credit Reporting) Code 2014. They govern how we collect, use, hold and disclose your personal information and how we ensure it is accurate and secure. This Privacy policy applies to all CAPE TO CAPE FINANCE PTY LTD companies.

What is personal and credit related information?

Any information or opinions about you are personal information. Credit related information includes identification information as well as information about your financial and credit situation and history, e.g. the types and amounts of loans and loan applications, repayment history, requests for information about you from credit providers and mortgage insurers, credit defaults, court proceedings and personal insolvency as well as information that has been derived about you by credit reporting bodies such as a credit report.

What kinds of personal information do we collect and hold?

The information we seek to collect about you depends on whether you are an investor or borrower with us. We will always collect your name, address, contact details, date of birth and nominated bank account. We also collect credit related information about our borrowers.

If you do not provide us with the information we ask for, we may not be able to deliver our services effectively or at all.

How do we use your information?

We use your personal information to provide our products and services to you including the following:

• Establish your identity and assess your applications for our products and services
• Price and design our products and services
• Tell you about products and services offered by 

CAPE TO CAPE FINANCE PTY LTD our preferred suppliers that we believe may interest you - unless you ask us not to

• Administer our products and services and manage our relationship with you
• Manage our risks and help identify and investigate illegal activity, such as fraud
• Conduct and improve our businesses and improve our customer's experience
• Comply with our legal obligations and assist government and law enforcement agencies or regulators.

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What laws require or authorise us to collect personal information?

We are required by law to collect the following information:

• Certain identification information about you - by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• Your Tax File Number, if you choose to provide it - by the Income Tax Assessment Act 1936 (Cth);
• If you have applied for credit or provide a guarantee, certain information about your financial position under the National Consumer Credit Protection Act 2009 (Cth).

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How do we collect personal information?

We collect most personal information directly from you. For example, when you apply for or use a product or service or talk to us in person or on the phone. We ask borrowers to allow us to collect information from their service providers such as banks and we also collect information about borrowers from credit reporting bodies.

We collect information about you from others, such as your service providers, adviser or broker. We will generally only do this with your consent.

‍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.

‍If we need to obtain sensitive information about you, we will ask for your consent where required by law.

‍We also collect information from you electronically. If you log into the CAPE TO CAPE FINANCE PTY LTD website we may collect information from you to confirm your identity. So that we can better tailor information and products to your needs, when we send you email messages, we may use technology to identify you so that we can know when you have opened the email or clicked on a particular link in the email.

‍When you use our website, tablet or mobile applications, we may collect information about your location or activity including the date of and time of visits, which pages are viewed, how you as the user navigate through the website and interact with the web pages (including fields completed in form and applications), IP address, telephone number, information about the device used to visit our website and whether you've accessed third party sites. Some of this information is collected using cookies.

How do we hold and manage personal information?

Much of the information we hold about you will be stored electronically in secure data centres located in Australia owned by either CAPE TO CAPE FINANCE PTY LTD or our external service providers. Some of your information may be stored in paper files.

We use a range of physical and electronic security measures to protect the security of the personal information we hold. For example:

• Access to information systems is controlled through identity and      access management.
• Employees are bound by internal information security policies and are required to keep information secure.
• All employees are required to complete training about information security.

Disclosure of personal information

We may disclose your personal information to other CAPE TO CAPE FINANCE PTY LTD companies.

We may also disclose your personal information to organisations external to CAPE TO CAPE FINANCE PTY LTD. This includes:

• Your advisers, agents and service providers and anyone to whom you have agreed we may provide your information
• Other organisations who provide products or services to you jointly with us
• Other organisations who we believe may be able to offer services that are of interest to you. These organisations may contact you directly in relation to such services.
• Our collection agencies, legal advisers, accountants, auditors and external dispute resolution scheme and any other agents, contractors or external service providers
• Our investors, but all information provided to investors is de-identified
• Where we are required or permitted to do so by law.

We require all our service providers to comply with the privacy laws.

Do we disclose personal information overseas?

We may disclose your personal information to recipients located outside Australia

• CAPE TO CAPE FINANCE PTY LTD service providers which are likely to be located in New Zealand, the United States, United Kingdom, Ireland, Germany and Singapore.
• For international transactions to the corresponding international party in order to process the transaction. The countries we disclose your information to will depend on the details of the transaction you ask us to carry out.

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Credit related information

Credit reports - When you apply for credit or propose to be a guarantor, we need to know if you're able to meet payments under your agreement with us. We also want to avoid giving you further credit if this would put you in financial difficulty. One of our checks involves obtaining a credit report about you.

Credit reports contain information about your credit history which helps credit providers assess your credit applications, verify your identity and manage accounts you hold with them. Credit reporting bodies collect and exchange this information with credit providers like CAPE TO CAPE FINANCE PTY LTD and other service providers such as phone companies.

The Privacy Act limits the information that credit providers can disclose about you to credit reporting bodies, as well as the ways in which credit providers can use credit reports.

What information can we exchange with credit reporting bodies?  

The information we can exchange includes your identification details, what type of loans you have, how much you've borrowed, whether you've met your loan payments and if you have committed a serious credit infringement (such as fraud). We also ask the credit reporting body to give us an overall assessment of your creditworthiness.

We use the following credit reporting bodies:

• Equifax Pty Ltd - www.equifax.com.au
• Experian Australia Credit Services Pty Ltd -www.experian.com.au/credit-services
• Illion Australia- illion.com.au

What do we do with credit-related information?

We use this information to confirm your identity, assess your creditworthiness and application for credit under our criteria, manage our relationship with you and collect overdue payments.

Credit reporting bodies with whom we exchange information may include the information in reports they provide to other credit providers to assist them to assess your creditworthiness. You can obtain a copy of the credit reporting body's policy about the management of credit-related information by contacting them or from their website.

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Other credit providers may ask credit reporting bodies to use your credit-related information to pre-screen you for direct marketing. You can ask a credit reporting body not to do this. Also, if you've been, or have reason to believe that you're likely to become, a victim of fraud (including identity fraud), you can ask the credit reporting body not to use or disclose the credit-related information it holds about you.

Accessing, updating and correcting your information

You can ask for access to the personal and credit-related information we hold about you. You can also ask for corrections to be made.

We may charge you for any reasonable costs incurred by us to access your personal information which is not credit related. You will be charged our reasonable costs of accessing your credit-related information if you have already sought access to it in the past 12 months.

There is no fee for correcting your personal information. If we disagree that your information should be corrected, we will tell you why in writing.

We can deny or limit access to your personal information if we cannot identify you, the information relates to commercially sensitive of privileged material, or if your request is vexatious. Whatever the outcome, we'll write to you explaining our decision.

Complaints

If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Privacy Act, the Code or the APPs, you can contact our Privacy Officer on:

Customer Care: (08) 6103 5112

Telephone: (08) 6103 5112

Email: info@capetocapefinance.com

PO BOX 556 BUSSELTON WA 6280

If you are not satisfied with the way we handled your complaint, you may complain to the Office of the Australian Information Commissioner:

GPO Box 5218

Email: enquiries@oaic,gov.au, Web: www.oaic,gov.au