PRIVACY POLICY
  We are committed to protecting the privacy and the confidentiality of our clients and any personal information that we collect from you, whether that information is provided verbally, in written or electronic form.

We collect and secure all client information in accordance with the Privacy Act 1988 and Australian Privacy Principles established under the Privacy Amendment (Enhancing Privacy Protection) Act 2012. Information about the Privacy Principles and your rights under the legislation can be accessed at the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

We respect your personal information, and this Privacy Policy aims to describe how we will treat your personal information. This policy covers Flair 4 Finance Pty Ltd ABN 88 118 504 322 and all affiliates of the Flair 4 Finance service network including Lifestyle Investment Planning Pty Ltd ABN 94 069 277 943.

This Policy also includes our policy on the handling of credit reports and 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.

Why do we collect personal information?
Prudent financial and credit advice stems from an objective assessment of an individual’s needs, objectives and attitudes to investment and risks and a detailed analysis of the clients current situation. These items can only be determined by collecting personal information. Similarly, your advisor needs some of your personal details in order to properly execute your financial transaction in a timely, efficient manner.

What personal information do we collect and hold?

General information

Our ability to provide you with comprehensive advice and administration depends on our ready access to certain personal information. The types of information that we collect and hold about you could include:

 
  • Identification information such as your name, residential, postal or email address, telephone numbers, date of birth, number and age of dependants;
  • other contact details such as social media channels;
  • health condition and family plans;
  • past, current and future employment;
  • financial needs and objectives;
  • current financial circumstances, including your assets and liabilities, (actual and potential) income and expenditure, insurance cover and superannuation;
  • family commitments, social security details;
  • financial details such as your tax file number; and
  • other information we think is necessary.

    Credit Information
    Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any judgments or defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

    Credit References and Reports
    Access to some credit providers and products is subject to the provision of a complete credit report. If you applying for such products and/or services, then we may be required to obtain a formal credit report, subject to the conditions of your engagement authority.

    When the law authorises or requires us to collect information
    We may collect information about you because we are required or authorised by law to collect it, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth).

    What do we collect via your website activity?
    If you are an internet customer of ours, we monitor your use of 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 do not submit an on-line application, we can contact you using any of the contact details you have supplied to offer help 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 will 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.

    Cookies
    Occasionally our web site uses cookies to allow the site to identify technical components of your browser while you are using our site. These cookies simply aid the technology and its developers to enhance the site to improve your browsing experience. Despite their harmlessness, you may wish to configure your browser settings to bar all cookies or to issue warning messages when cookies are encountered. That can afford you an opportunity to refuse their download individually. Refer to your internet browser ’help’ function or user manual for details of these settings.

    How do we collect your personal information?

    How we collect and hold your information
    Unless it is unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ’solicited information’). For this reason, it is important that you help us to do this and keep your contact details up-to-date.

    There are a number of ways in which we may seek information from you. We might collect your information when you fill out a form with us, when you have 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 is 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 cannot 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 do not want to provide us with your personal information?
    If you do not provide your information to us, it may not be possible:
    • for us to give you the financial advice services or 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 financial and credit information
    We will collect your financial and credit information in the course of you answering the enquiries we make of you relating to the financial advice and credit assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting financial and credit information are:
     
    • your co-loan applicants or co-borrowers;
    • your spouse or de-facto;
    • 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;
    • our service providers involved in helping us to process any application you make for any other financial products or services through us.
    What do we do when we get information we did not ask for?
    Sometimes, people share information with us we have not 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 will handle this information the same way we do with other information we seek from you. If not, we will 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 will 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 will 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 will 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 have 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;
    • administer payments we receive, or any payments we make, relating to your loan or lease;
    • facilitate application for financial products and services;
    • develop a financial strategy/plan;
    • provide appropriate advice to you;
    • implement recommendations;
    • review your financial plan; and monitor your portfolio.

    Can we use your information for marketing our products and services?
    We may use or disclose your personal information to let you know about 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 for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We will not 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. You may at any time decline to receive such information by phoning us on 1300 202012 or by writing to us at loans@flair4finance.com. We will process your request as soon as practicable.

    What are the other ways we use your information?
    We have just told you some of the main reasons why we collect your information, so here are some more insights 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.

    All our staff and representatives are obliged to adhere to this Privacy Policy.

    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 ou mortgage aggregator’s panel;
    • the Australian Credit Licence holder that authorises us to engage in credit activities;
    • The Australian Financial Services Licence holder that authorises us to engage in financial advice services;
    • referrers that referred your business to us;
    • persons acting on your behalf, for example, guardians and persons holding power of attorney;
    • valuers;
    • lenders, lessors, lender’s mortgage insurers and other loan or lease intermediaries;
    • nominated product/service providers that you have explicitly nominated as recipients of particular information, including financiers, insurers and credit reporting agencies;
    • 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;
    • product issuers, suppliers and administrators for the purpose of establishing and maintaining the elements of any recommendations accepted by you, or explicitly selected by you;
    • claims-related providers, such as assessors and investigators, who help us with claims;
    • auditors, insurers and re-insurers;
    • 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 is 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 will always give you access to your personal information unless there are certain legal reasons why we cannot. 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 is reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we will always inform you of the charge at the time of request.

    We are not always required to give you access to your personal information. Some of the situations where we do not 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 would not 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 cannot provide your information in the way you have requested, we will tell you why in writing. If you have concerns, you should contact your advisor and lodge a formal request.

    How do you correct your personal information?

    How we correct your information
    It is important to us that the personal information we hold about you is accurate and up to date. When providing advice and assistance during the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

    Contact us if you think there is something wrong with the information we hold about you and we will try to correct it if it is:
     
    • inaccurate;
    • out-of-date;
    • incomplete;
    • irrelevant; or
    • misleading.

    If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. Well try and help where we can - if we cannot, then we will let you know in writing.

    What additional things do we have to do to correct your credit information? If you ask us to correct credit information, we will help you with this in the following way.

    Helping you manage corrections
    Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.

    Where we correct information
    If we are able to correct the information, we will let you know within five business days of deciding to do this. We will also let the relevant third parties know as well as any others you tell us about. If there are any instances where we cannot do this, then we will let you know in writing.

    Where we cannot correct information
    If we are unable to correct your information, we will 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 will do so within 30 days from when you asked us, or a longer period that has been agreed by you.

    If we cannot 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.

    How do you make a complaint?

    How do you generally make a complaint?
    If you have a complaint about how we handle your personal information, you should contact your designated advisor and lodge a formal complaint.

    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.

    Need more help?
    If you still feel your issue hasn not 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: enquiries@oaic.gov.au
    • Fax: +61 2 9284 9666
    • Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601

    What additional things do we have to do to manage your complaints about credit 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 credit information
    If you make a complaint about things (other than an access request or correction request) in relation to your credit information, we will let you know how we will deal with it within seven days.

    Ask for more time if we cannot fix things in 30 days
    If we cannot fix things within 30 days, we will 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 will 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.

    Contact Us
    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:
    Business Name: Flair 4 Finance Pty Ltd
    Phone: 1300 202 012

    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 regulations that require us to know who we are dealing with. In general, we will not be able to deal with you anonymously or where you are using a pseudonym when:
     
    • it is impracticable; or
    • we are required or authorised by law or a court/tribunal order to deal with you personally.

    What do we do with government-related identifiers?
    In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.

    Changes to this Privacy Policy
    This Policy may change. Policy changes will be posted on our website however you may contact us for a copy of the most up to date policy at any time.
    However we will never ask you for your security details in this way.
    If you are ever unsure then please just contact us.

    ---- Flair 4 Finance & Lifestyle Investment Planning   Privacy Policy 12 March 2014
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