Privacy

  • Who We Are

    Oreana Financial Services Limited and Oreana Financial Services Pty Ltd (“Oreana Financial Services”) are diversified financial services firms with expertise in the provision of financial advice, and portfolio advisory services across Australia and Asia.

    About This Policy

    This policy describes how we collect, hold, use and disclose your personal information under applicable Privacy Laws. Oreana Financial Services bound by the Privacy Act 1988 (Cth) (‘Privacy Act’) and we manage and protect your personal information in accordance with the Australian Privacy Principles (APPs).

    Respecting Your Privacy

    This notice applies to your dealings as a client with Oreana Financial Services. The confidentiality and privacy of your information is important to us. Depending on the type of client you are, where you reside and how we store and process your information, you may be covered by the Hong Kong Personal Data (Privacy) Ordinance and/or the Australia Privacy Act. Oreana Financial Services in Australia bound by the Privacy Act 1988 (Cth) (‘Privacy Act’) and we manage and protect your personal information in accordance with the Australian Privacy Principles (APPs). If these laws do apply to you, then we comply with the relevant privacy principles those laws have established with respect to you and your personal information or personal data. We recommend you read and understand the following provisions relating to our collection, use and handling of your information.

    Sensitive Information

    The Privacy Act protects your sensitive information — such as information about your religion, ethnicity, health or biometrics (for example, your fingerprints). If we need this type of information, we’ll ask for your permission — except where otherwise allowed by law.

    Your Personal Information

    We and/or our officers, employees, contractors and agents collect, hold, use and disclose information to assist us in our relationship with you. This information is collected from you, from the transactions performed on your behalf and/or from other persons and organisation’s. If you do not provide the information we need we may not be able to provide you with the product or service you have requested. We may also be required by law to collect information from or about you for certain purposes (for example, to identify you).

    The types of information collected include but are not limited to:

    • information which identifies you (your name, date of birth, contact details, residence and citizenship status);
    • information which relates to your financial affairs, business, employment, income or assets;
    • information which arises or is required in connection with the transactions you do with us or through us;
    • information which helps us to process applications made by you for particular products and services; and
    • information relevant to product development or marketing.

    How We Collect Your Personal Information

    We collect your personal information directly from you or from third parties once authorisation has been provided by you. You have the right to refuse us authorisation to collect such information from a third party.

    How We Use Your Personal Information

    We collect, hold, use and disclose personal information so we can provide you with financial and credit products, advice and service relevant to your needs. We may also collect, use and disclose your information for related purposes such as:

    • Complying with our legal obligations, such as verifying your identity
    • Assisting with your questions and complaints
    • Arranging for services to be provided by third parties
    • Internal operations, such as record keeping, data analytics, auditing or training
    • Promotion of other products and services that may be of interest to you

    We collect, use, hold and sometimes disclose personal information about financial advisers, credit representatives and other people who we do business with (including employees) in order to administer and manage our business operations. This information is afforded the same standard of care as that of our clients.

    How We Store and Secure Your Personal Information

    We keep your personal information in your client files or electronically. These files are accessible to authorised personnel only and are appropriately secured and subject to confidentiality requirements. Personal information is treated as confidential information and sensitive information is treated as highly confidential. It is a legislative requirement that we keep all personal information and records for a period of 7 years.

    Sending Information Overseas

    Depending on the nature of the engagement or purpose of collection, we may disclose your personal information to other entities and suppliers overseas in accordance with the Privacy Act. These countries may include (though not limited to) Singapore, Hong Kong and the United States.
    We may store, process or back-up your personal information on servers that are located overseas (including through third party service providers). In some circumstances, Oreana Financial Services Pty Ltd also uses third party service providers located overseas to carry out its functions and provide services. By submitting your personal data to us, you acknowledge and agree with your data being processed on Oreana Financial Services behalf by its suppliers.    While we have made reasonable efforts to secure your information, some of our suppliers may not provide privacy protection at a level consistent with the Australian Privacy Principles.
    We have taken reasonable steps to ensure that the recipient does not breach the Act and the Australian Privacy Principles.
    Accessing and updating personal information

    Any request to do or have done any one or more of the above things (which you may or may not be entitled to do, depending on who you are and in which jurisdiction or country you deal with us) or to raise any concern you have regarding the privacy of your Data and Account Information should be made to us in writing and addressed to the privacy officer named below.

    There may be circumstances where we refuse to provide you with the information you request, for example when the information is commercially sensitive. In these situations, we will inform you and provide an explanation as to why.

    We will deal with requests for access to your personal information as soon as possible and aim to respond within 10 business days. The time we require will depend on the type of information requested.

    It is important that we have your contact details such as your current home and email addresses and phone number, you can update your personal information over the phone, by contacting your adviser or broker or electronically.

    Your Rights

    You may do the following things in respect of any of your Data and Account Information that is protected by the Hong Kong Personal Data Privacy Ordinance and the Code of Practice on Consumer Credit Data issued under that Ordinance and/or the Australia Privacy Act 1988 (Cth) (‘Privacy Act’):

    • check whether we hold personal data about you and the right of access (with some exceptions) to such data;
    • require us to correct any personal data relating to you which you establish is inaccurate;
    • ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us;

    Important

    This document provides an overview of our privacy policies and procedures (in addition to those that may apply in respect of specific Services and transactions), disclosures that we are required to make by law and a summary of certain Regulations. It is not intended to constitute legal advice in relation to your rights under any privacy legislation or any other matter.

    Contact Us About Privacy

    Further information about our privacy policies and procedures can be obtained from our office.
    Please address to:

    Risk & Compliance
    Oreana Financial Services Pty Ltd
    Level 7
    484 St Kilda Road
    Melbourne, Victoria 3004
    Australia
    Tel: (61) 3 9804 7113

    Or

    Risk & Compliance
    Hong Kong
    Oreana Financial Services Limited
    SFC CE No. AHX191
    Suite 1002, 10th Floor
    Cambridge House, Taikoo Place
    979 King’s Road,
    Quarry Bay, Hong Kong
    T +852 3185 0200
    F +852 2110 0736
    E info@oreanafinancial.com

    Complaints About Privacy

    If you are concerned about how your personal information has been collected, used or disclosed and you wish to make a complaint. Please contact us at the details outlined above.
    We will acknowledge receipt of a complaint within 1 business day. We will then investigate the complaint and respond to you within a maximum of 30 days following receipts of your initial complaint.
    The Australian Financial Complaints Authority (AFCA) can consider certain privacy complaints relating to either the provision of credit or credit reporting information in general. The contact details for AFCA are:

    Australian Financial Complaints Authority
    Online: afca.org.au
    Email: info@afca.org.au
    Phone: 1800 931 678 (Freecall)
    Mail: Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001

  • Respecting your privacy

    We respect your personal information, and this Privacy Policy explains how we handle it. The policy covers Willow Lending Services Pty Ltd. ACN 601 598 378 – Corporate Credit Representative 469117.

    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.

    If you are in a country that is a member of the European Economic Area (EEA), the EU General Data Protection Regulation 2016/679 (‘GDPR’) governs the way we collect, use, hold, process and disclose your personal information. Under the GDPR, we are a data controller. We make decisions on how and why your personal information is processed.

    What personal information do we collect and hold?
    General information
    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.

    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. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.

    What do we collect via your website activity?
    If you’re 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 don’t submit an on-line application, we can contact you using any of the contact details you’ve 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’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?

    How we collect and hold your information
    Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s 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’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 details1.

    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 (for example, from public registers or social media) or made available by third parties) 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 in the course of you answering 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 including help, guidance and advice;
    • consider whether you are eligible for a loan or lease or any related service you requested including identifying or verifying you or your authority to act on behalf of a customer;
    • 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 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.

    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:

    • telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
    • identifying opportunities to improve our service to you and improving our service to you;
    • 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.

    What are the grounds which we will deal with your personal information under the GDPR?

    Under the GDPR, we must have a legal ground in order to process your personal information. The legal grounds that we may rely on are:

    • Performance of our contract with you;
    • Compliance with a legal obligation;
    • Where you have provided your consent; and
    • For our legitimate interests: our main legitimate interests for processing your personal information are: fraud, security, due diligence, business operations and direct marketing.

    How long do you keep your information?

    We are required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example.

    We are required to keep your information for 7 years from the closure of accounts, or otherwise as required for our business operations or by applicable laws.

    We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.

    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;
    • valuers;
    • 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 Taxation 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 for purposes including, without limitation, storing or analysing information;
    • 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 may use overseas organisations to help conduct our business. As a result, we may need to share some of your information (including credit information) with such organisations outside Australia. The countries in which those organisations are located are:

    • N/A

    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 we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

    Where we transfer your information from the EEA’ to a recipient outside the EEA we will ensure that an adequate level of protection is in place to protect your personal information such as putting in place contractual protections to ensure the security of your information.

    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’.

    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 and we’ll try to correct it if it’s:

    • 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. We’ll try and help where we can – if we can’t, then we’ll 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’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.

    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, we want to hear from you. You are always welcome to contact us.
    You can contact us by using the details below

    Willow Financial Services
    2 Eleanor Street
    Mount Gambier SA 5290
    Ph: 08 8724 7745
    Fax: 08 8723 0899
    Email: admin@willowfinance.com.au
    Website: www.willowfinance.com.au

    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’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: enquiries@oaic.gov.au
    • Fax: +61 2 9284 9666
    • Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601

    If you are located in the EEA, you can contact the relevant data protection authority (for example in the place you reside or where you believe we breached your rights). For example, the Office of the UK Information Commissioner:

    Office of the UK Information Commissioner

    • Online: www.ico.gov.uk
    • Phone: 0303 123 1113
    • Live chat: https://ico.org.uk/global/contact-us/live-chat

    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 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.

    Your Rights under GDPR
    If you reside in the EEA, you can also:

    • object to the processing or your personal information or ask us to delete, or restrict or stop using your personal information. There may be circumstances where we are required to, or entitled to retain or continue using your information.
    • withdraw your consent to our processing of your information. We may continue to process our information if we have another legitimate ground to do so.
    • ask us to send an electronic copy of your personal information, including to another organisation.

    You can contact us if you wish to exercise these rights. See ‘Contact Us’ for more information If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision.

    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:

    Willow Financial Services
    2 Eleanor Street
    Mount Gambier SA 5290
    Ph: 08 8724 7745
    Fax: 08 8723 0899
    Email: admin@willowfinance.com.au
    Website: www.willowfinance.com.au

    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’re dealing with. In general, we won’t 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. We will let you know of any changes to this Policy by posting a notification on our website, correspondence via post or e-mail or you may contact us for a copy of the most up to date policy at any time.

    1 However we’ll never ask you for your security details in this way – if you are ever unsure, just contact us

  • The privacy of your personal information is important to us at Willow Financial Services Pty Ltd trading as Willow Financial Planning. We are required to comply with the Australian Privacy Principles. We will always seek to comply with the Australian Privacy Principles as well as other applicable laws affecting your personal information.

    This privacy policy outlines our policy on how we manage your personal information. It also sets out generally what sort of personal information we hold, for what purposes and how we collect, hold, use and disclose that information.

    Collecting Your Personal Information

    Your personal information will be collected and held by Willow Financial Services Pty Ltd, who is an authorised representative of GWM Adviser Services Limited trading as MLC Financial Planning, an Australian Financial Services Licensee, for the purposes of:

    • providing you with the advisory services that you have requested;
    • managing our relationship with you, including management and administration tasks such as answering your requests and concerns, conducting market research and taking any required legal action;
    • completing documentation and forms, including identifying you or verifying your authority to act on behalf of a customer;
    • to protect our business and other clients from fraudulent or unlawful activity;
    • to comply with relevant laws, regulations, and other legal obligations;
    • to help us improve the products and services offered to our clients, including contacting you about products and services in which you may be interested; and
    • for any purpose for which you have given your consent.

    You can let us know at any time if you no longer wish to receive direct marketing offers. Contact us at 08 8724 7745.

    We will process your request as soon as practicable. To enable your financial adviser to provide you with financial advice you request that is suitable for your investment objectives, financial situation and particular needs we need to obtain and hold personal information about you. This includes:

    • your name, contact details and date of birth;
    • employment details and history;
    • financial details including information about your financial needs and objectives, your current financial circumstances including your assets and liabilities, income, expenditure, insurance cover and superannuation;
    • details of your investment preferences and risk tolerance;
    • family circumstances and social security eligibility; and
    • any other information that we consider necessary.

    The personal information collected may include sensitive information such as health information and memberships of professional or trade associations.

    If it is reasonable and practicable we will only collect your personal information from you. Generally your personal information will be collected when you meet with your adviser in person, provide your adviser with information over the telephone or with written material. We may need to collect personal information from third parties, such as your accountant.

    We may receive personal information about you when we have taken no active steps to collect that information. We destroy all unsolicited personal information, unless the personal information is relevant to our purposes for collecting personal information.

    How Your Personal Information is Held

    Your personal information is generally held in client files or a computer database. Your personal information may also be held in a secure archiving facility.

    We take reasonable steps to ensure that the personal information that we hold is protected from misuse and loss and from unauthorised access, modification and disclosure. Some of the measures that we have adopted are having facilities for the secure storage of personal information, having secure offices and access controls for our computer systems.

    We will also take reasonable steps to destroy or permanently de-identify personal information that we no longer need for any purpose for which it may be used or disclosed under the Australian Privacy Principles.

    Using and Disclosing Your Personal Information

    Your personal information may be disclosed for purposes related to the provision of the financial advice you have requested. The types of service providers that may be provided with your personal information are:

    • other financial advisers and organisations involved in providing the financial advice you have requested (which may include ongoing service) such as fund managers who assist us in providing financial advice and paraplanners;
    • insurance providers, superannuation trustees and product issuers in connection with the provision to you of the financial advice you have requested;
    • organisations that assist in operating a financial planning business such as those that provide administrative, financial, accounting, insurance, research, legal, computer or other business services;
    • your representatives or service providers such as your accountant, solicitor, tax agent, stockbroker or bank;
    • organisations involved in a business restructure or a transfer of all or part of the assets of our business or the due diligence procedures prior to any such sale or transfer;
    • government authorities and other organisations when required by law; and
    • organisations that you have consented to your personal information being disclosed to.

    In addition to the purposes of collection set out above, your personal information may also be used in connection with such purposes.

    We will seek to ensure that your personal information is not used or disclosed for any purpose other than:

    • the primary purpose for which it was collected or a related secondary purpose;
    • where you have consented to the use or disclosure; or
    • in other circumstances where the Australian Privacy Principles authorise the use or disclosure such as when it is required by or authorised under law.

    We may disclose your personal information to third parties who provide services to us, in which case we will seek to ensure that the personal information is held, used or disclosed consistently with the Australian Privacy Principles.

    Organisations Outside Australia

    Currently, we do not share your information with organisations outside Australia.

    We may store your information in the 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 we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

    We will not send personal information to recipients outside of Australia unless:

    • we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act and the Australian Privacy Principles;
    • the recipient is subject to an information privacy scheme similar to the Privacy Act; or
    • the individual has consented to the disclosure.

    Accessing your Personal Information

    You can gain access to your personal information that we hold. This is subject to exceptions allowed by law such as where providing you with access would have an unreasonable impact upon the privacy of others. If we deny a request for access we will provide you with the reasons for this decision. To request access please contact us (see “Contacting Us and Privacy Issues” below).

    Correcting Your Personal Information

    We take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete and up-to-date. If you believe that any of the personal information that we hold is not accurate, complete or up-to-date please contact us (see “Contacting Us and Privacy Issues” below) and provide us with evidence that it is not accurate, complete and up-to-date.

    If we agree that the personal information requires correcting, we will take reasonable steps to do so. If we do not correct your personal information we will provide you with the reasons for not correcting your personal information. If you request that we associate with the information a statement claiming that the information is not accurate, complete and up-to-date we will take reasonable steps to comply with this request.

    Contacting Us and Privacy Issues

    You can obtain further information on request about the way in which we manage the personal information that we hold or you can raise any privacy issues with us, including a complaint about privacy, by contacting us using the details below. We are committed to resolving your complaint.

    Pauline Hill / Office Manager – 08 8724 7745 or admin@willowfinance.com.au

    If you still feel your issue hasn’t been resolved to your satisfaction, then you can escalate your privacy concerns to:

    Office of the Australian Information Commissioner

    Financial Ombudsman Service – if lodging before 1 November 2018

    Or

    Australian Financial Complaints Authority (AFCA)* – if lodging on or after 1 November 2018

    • Website: www.afca.org.au
    • Email: info@afca.org.au
    • Telephone: 1800 931 678 (free call)
    • In writing to: Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001

    *The Australian Financial Complaints Authority or ‘AFCA’ is a new external dispute resolution (EDR) scheme to deal with complaints from consumers in the financial system. AFCA replaces the three existing EDR schemes of the Financial Ombudsman Service (FOS), the Credit and Investments Ombudsman (CIO) and Superannuation Complaints Tribunal (SCT) so that consumers have access to a single EDR scheme.

  • Respecting your privacy

    We respect your personal information, and this Privacy Policy explains how we handle it. The policy covers Willow Lending Services Pty Ltd. ACN 601 598 378 – Corporate Credit Representative 469117

    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?

    General information
    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.

    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. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.

    What do we collect via your website activity?

    If you’re 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 don’t submit an on-line application, we can contact you using any of the contact details you’ve 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’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?

    How we collect and hold your information
    Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s 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’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 (for example, from public registers or social media) or made available by third parties) 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 in the course of you answering 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 including help, guidance and advice;
    • consider whether you are eligible for a loan or lease or any related service you requested including identifying or verifying you or your authority to act on behalf of a customer;
    • 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 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.

    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:

    • telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
    • identifying opportunities to improve our service to you and improving our service to you;
    • 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;
    • valuers;
    • 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 Taxation 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 for purposes including, without limitation, storing or analysing information;
    • 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’.

    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 and we’ll try to correct it if it’s:

    • 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. We’ll try and help where we can – if we can’t, then we’ll 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’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.

    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, we want to hear from you. You are always welcome to contact us.

    You can contact us by using the details below
    Willow Financial Services
    2 Eleanor Street
    Mount Gambier SA 5290
    Ph: 08 8724 7745
    Fax: 08 8723 0899
    Email: admin@willowfinance.com.au
    Website: willowfinance.com.au

    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’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: 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 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.

    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:
    Willow Financial Services
    2 Eleanor Street
    Mount Gambier SA 5290
    Ph: 08 8724 7745
    Fax: 08 8723 0899
    Email: admin@willowfinance.com.au
    Website: willowfinance.com.au

    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’re dealing with. In general, we won’t 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. We will let you know of any changes to this Policy by posting a notification on our website, correspondence via post or e-mail or you may contact us for a copy of the most up to date policy at any time.
    However, we’ll never ask you for your security details in this way – if you are ever unsure, just contact us.

    Broker Privacy Policy March 2017.

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