Privacy Policy - Australian Capital Home Loans Pty Ltd ("ACHL ")

At ACHL we want you to be confident that the personal information you provide to us is treated with the highest degree of integrity and privacy.

However it is equally important to us that we provide the best possible service across our wide range of products and services. To achieve this aim we need to make the most efficient use of your personal information.

Who is Australian Capital Home Loans (ACHL)?

Australian Capital Home Loans Pty Ltd is a specialist Mortgage Originator for the Adelaide Bank. Through accreditations with other lenders and networks A CHL has access to most lenders in Australia .

A CHL also provides services to borrowers to assist them with using credit products and managing debt.

A CHL is continuing to experience extraordinary growth through its network of Personal Bankers, and Franchisees and is now expanding interstate.

Australian Capital Home Loans Pty Ltd ACN 111 924 586 is an Australian company based at Rocklea, Brisbane in Queensland .

What is "personal information"?

Personal information is any information or opinion about you in which you are identified, or in which your identity can reasonably be ascertained from the information or opinion. It does not matter whether the information or opinion is true or not, or whether it is recorded in a material form or not. It can be information in a database.

Why we collect your personal information?

Collecting your personal information, either from you directly or from other sources, is essential to enable us to:

• provide products and services to you;
• submit loan applications to lenders and mortgage managers on your behalf; and
• if you are to provide services to us - assess the service contract or arrangement, and fulfil our obligations under it.

We also collect your personal information, so that we can constantly to improve our products and services.

Collecting your personal information also allows us to identify and protect your personal information, including account information and services, from unauthorised access.

How do we collect your personal information?

Where possible we collect your personal information directly from you. You provide this information to us when you complete an application form for a product or request a product or service over the telephone or internet.

Personal information is also collected during the course of our relationship with you. For example, when you contact us to discuss your existing loans, extensions to the loans, repayments and restructuring your loans. .

Sometimes it is necessary for us to collect your personal information from other sources. For example:

• we may approach your employer to confirm your employment details to support your application; and/or
• we may approach your landlord or a real estate agent to confirm your residence and rent payments to support your application.

In most cases we will request your consent to any collection, use or disclosure of your personal information by us. Your consent will usually be required to be in writing but we may accept your verbal or implied consent in certain circumstances.

How we use your personal information?

We use the personal information that we collect so that we can provide you with our products and services and administer and enhance the relationship we have with you.

We may also share the information with Australian Capital Home Loans related entities and with other credit providers, mortgage managers and mortgage insurers.

Direct Marketing?

From time to time we may use your personal information to provide you with information about our extensive range of products and services. Our contact with you will usually be by mail, telephone or email.

If you do not want to receive any of this information please contact our Compliance Officer at ACHL 's head office on 1300 797 338. Once you have told us you no longer wish to receive information about our products and services, we will not send you any further material, unless we are required by law to send such information to you.

You can, however, change your mind about receiving information about our products and services at any time - either way, you just need to let us know.

ACHL does not disclose your personal information to a party outside ACHL for the purposes of allowing them to direct market their products or services to you, unless you have specifically agreed to our doing so.

We will not call personally at your residence or place of work unless you specifically agree to this and we arrange an appointment beforehand.

Do we disclose your personal information to anyone?

Handling your application

We need to pass your personal information on to the credit providers, mortgage managers and mortgage insurers we approach on your behalf.

As part of the application and pre-application process, we may also need to disclose aspects of your personal information to:

• your referees, employers, landlords and others for the purpose of identifying you correctly when we seek confirmations from them regarding the details you have provided to us;
• mail service providers for purpose of mailing material to you;
• the guarantors you offer on loan applications for the purpose of allowing them to fully understand their obligations; and
• our advisors including, mortgage managers, mortgage insurers, originators, financial consultants, accountants, lawyers and any other advisor acting in connection with any financing provided or proposed to be provided to you for the purpose of providing our services to you.

As required by law

We may also disclose your personal information if we are required or authorised to do so by law. For example, to a Court in response to a subpoena or to the Australian Taxation Office following a direction issued under taxation laws.

With your consent

With you consent, we will disclose your personal information to other parties. Your consent may be given explicitly such as in writing or verbally, or may be implied from your conduct such as if you publicly discuss details of the relationship you have with us.

ACHL contracted entities

Where an ACHL contracted entity is dealing with you then we may need to pass information to the entity in the course of handling your loan application. Each contractor is bound to comply with the provisions of this policy.

How do Credit Providers and Insurers deal with the information we give them?

Prior to actually entering into the finance agreement or insurance policy, you will be asked to give your written consent to allow those organisations to use your personal information. They will provide full details of how they intend to use and store the information at that time.

Ensuring your personal information is up-to-date?

We rely on the personal information we hold about you to efficiently conduct our business of providing or arranging products and services.

For this reason, it is very important that the personal information we collect from you is accurate, complete and up-to-date.

During the course of our relationship with you we may ask you to tell us of any changes to your personal information. We also invite you to contact us at any time to update or correct your personal information.

Is my personal information secure?

The protection of your personal information is a priority for ACHL.

This is why we take all reasonable precautions to safeguard your personal information from loss, misuse, unauthorised access, modification or disclosure.

We employ a number of means to protect your personal information including:

• appropriate premises security;
• executing confidentiality agreements with all employees, contractors and third party organisations;
• password protecting our computer based information to prevent unauthorised computer access;
• providing appropriate protection against "hackers" within our computer systems
• securely destroying and/or deleting any personal information that is no longer required from our systems; and
• requiring any contractors to ACHL adopt the same levels of security as ourselves.

Can I access the personal information ACHL holds about me?

You may request access to any of the personal information we hold about you.

In most cases, details of the personal information we hold about you is available by calling our Compliance Officer (07) 3274 0900, or visiting our head office.

If the information you seek is not readily available, for example, archived data, then we will endeavour to provide this to you within 30 days of your request. We reserve the right to charge you a fee for this retrieval.

ACHL may be required by law or by good business practice to retain you personal information for a period of time after you have ceased your relationship with us. After the required time has passed we attend to the secure destruction or deletion of your personal information.

Can my request for access to my personal information be denied?

ACHL is not always required to provide you with access to your personal information upon your request.

We may refuse you access to personal information in a number of circumstances, such as where the information may relate to existing or anticipated legal proceedings with you, where denying access is required or authorised by law, or where the request for access is regarded as frivolous or vexatious.

If we deny your request for access to, or refuse your request to correct your personal information, we will explain why and will keep a record of your request on our file.

Do I have to be identified?

Generally it is not possible for us to do business with you unless we have identified you. This is necessary as standard business practice and also protects you against someone using your name fraudulently to obtain finance or insurance. We will usually ask you for photographic evidence such as a drivers licence or passport.

We will not use any Commonwealth Identifiers such as Tax File Numbers, Medicare cards or the like and if these are provided in any information you give us we will not record them in our files and will remove any reference to them from documents you provide to us.

Wherever it is lawful and practicable to do so, we may offer you the opportunity to deal with us anonymously, if you request it. For example, when making an enquiry about current interest rates applicable or the type of products or services we offer.

Does my personal information leave Australia?

ACHL does not send personal information outside Australia unless it is authorised to do so by law.

Does ACHL collect "Sensitive Information"?

Personal information concerning particular topics is regarded as sensitive information.

Sensitive information includes information about your:

• racial or ethnic origin;
• political opinions;
• membership of a political association;
• religious beliefs or affiliations;
• philosophical beliefs;
• membership of a professional or trade association;
• membership of a trade union;
• sexual preferences or practices;
• criminal record; and
• health.

ACHL generally has very limited need to obtain such information, however may require some information such as criminal record or health to arrange certain insurance facilities. If such information is needed then it will only be obtained and/or used with your consent. If, in the course of arranging your application or facilities, such information does come into our possession from a third party, we will seek your consent to collect, store and use this should we consider such use necessary in your application.

Access to our services via the Internet

ACHL receives referrals through its website. ACHL is committed to ensuring that any personal information we collect online is treated with the same level of care as if it was received via personal contact.

Our policies provide:

• If you make a general email enquiry (usually this involves providing only your name, contact details and type of facility required), we will always ask you for your written consent before we commence any application activity on your behalf.
• If you make a full online application, your details will be encrypted via our web technology to provide high level protection from unauthorised access to your personal information. We will also ensure that we hold your written consent before commencing any application activity.

What are 'Cookies' and how do they work?

Cookies are small data files that are downloaded from our web servers, and stored on your hard drive.

A cookie is a string of letters and numbers that uniquely identify the computer you are using, and the customer number and access code you may have used to register at the site.

Cookies are used on the ACHL website.

We track a visitor's journey through our site. This allows us to see at a glance which pages and information is of most interest to visitors. This type of cookie contains no personal information. It is simply a record of your journey through the site and no attempt will be made to identify users.

Most browsers can be configured to refuse to accept cookies. You can also delete cookies from your hard drive. However, doing so may hinder your access to valuable areas of information within our site.

Our websites may contain links to other websites. ACHL is not responsible for the privacy practices of these websites.

Our Privacy Policy may change from time to time

ACHL constantly reviews all its policies and procedures to keep up to date with changes in the law, technology and market practice.

As a result we may change this Privacy Policy from time to time.

This Privacy Policy was last amended July 2005.

Want to know more?

More information is available at The Office of the Federal Privacy Commissioner at http://www.privacy.gov.au/ .

The National Privacy Principles Guidelines can be viewed at http://www.privacy.gov.au/publications/nppgl_01.html

Concerns or requests for access?

If you have a question about this Privacy Policy or wish to lodge a request to access you personal information you can contact us in any of the following ways:

By Visiting	}	Our head office at Block D Garden Square 643 Kessells Rd Upper Mt Gravatt
By Telephoning	}	1300 797 338 (Compliance Officer)
By Writing to	}	Australian Capital Home Loans Pty Ltd Compliance Officer PO Box 6719 UPPER MT GRAVATT QLD 4122
If you believe that ACHL has not protected your personal information as set out in this Privacy Policy you may lodge a complaint with us in any of the following ways:
By Telephoning	}	1300 797 338 (Compliance Officer)
By Writing to	}	Australian Capital Home Loans Pty Ltd Compliance Officer PO Box 6719 UPPER MT GRAVATT QLD 4122

What if I am not satisfied with ACHL's response?

If you are not satisfied with the result of your complaint to ACHL, you can refer your complaint to the Federal Privacy Commissioner.

You can contact the Federal Privacy Commissioner:

By Telephoning	}	1300 363 992
By Writing to	}	Director of Complaints Office of the Federal Privacy Commissioner GPO Box 5218, Sydney NSW 2001

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