Finance Team Privacy Policy

Who are we

This privacy policy applies to Elephant Financial Pty Ltd (ACN 611 576 240) and Authorised Credit Representative 487962 under Vow Financial Pty Ltd, Australian Credit Licence 390261, Elephant Financial Pty Ltd (ACN 611 576 240) t/a Elephant Advisory, Elephant Property Australia Pty Ltd (634 383 958), KD Advisory Pty Ltd (ACN 626 563 755) t/a Elephant Tax and their related businesses and associated Principals, Credit Advisors, Realestate Advisors, Aggregators, Partners and associations.

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. We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures the protection of your personal information. In handling your personal information, the abovementioned parties are committed to complying with the Privacy Act and Australian Privacy Principles.

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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. The personal information we hold about you may include 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 defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you.

If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings, expenses and other financial information. If you apply for any insurance product through us we may also collect your health information. We will only collect health information from you with your consent.

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Collection of 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.

We generally have very limited need to obtain such information, however, may require some information such as a criminal record. 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.

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Use and disclosure of personal information

We may use or disclose personal information for the primary purpose for which it was collected. We may also use the information for a related purpose and where it would reasonably be expected by you that we use the information in such a way. This information is only disclosed to third parties in the circumstances covered in this policy or as otherwise notified to you at the time of collection of the information.

We may need to disclose aspects of your personal information to:

1. To our Group-wide entities under the Elephant Advisory banner;
2. To prospective funders or other intermediaries in relation to your requirements
3. To other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres;
4. To associated businesses that may want to market products to you;
5. To companies that provide information and infrastructure systems to us;|
6. To anybody who represents you, such as finance brokers, lawyers and accountants;
7. To anyone, where you have provided us consent;
8. Where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth);
9. To investors, agents or advisers, or any entity that has an interest in our business; or
10. To your employer, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

1. the person or organisation has a commitment to protecting your personal information at least equal to our commitment; or
2. you have consented to us making the disclosure.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia. We may disclose your personal information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.

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Direct marketing

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.

If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on 03 9069 8688. If direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

As you browse www.elephantadvisory.com.au, advertising cookies will be placed on your computer so that we can understand what you are interested in. 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.

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Security, storage and access

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
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Access and correction to your personal information

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 contacting an Elephant Advisory representative and its’ associated partners. 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. We may be required by law or by good business practice to retain your 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. We are 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. If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information. At the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.

If we refuse to correct the personal information we will provide you with our reasons for not correcting the information.
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Using government identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

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Collection of information

We collect personal information from you when you apply for or use our products and services. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other 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. We will only collect such personal information if it is necessary to provide our products and services.

Where possible we collect your personal information directly from you. You provide this information to us when you work the listed parties, request products and services or make an enquiry. We may also collect your personal information from credit reporting bodies, finance brokers and other people such as accountants and lawyers.

In most cases, we will request your consent to any collection and take reasonable steps to ensure that you are made aware of who we are, the purpose of the collection, how you can access your information and who we may disclose your information to. It will typically be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information. For example, if you make general inquiries about interest rates or current promotional offers.

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Credit Guide

About this credit guide

This is the Credit Guide of Vow Financial Pty Limited ACN 138 789 161, Australian Credit Licence 390261 of which Elephant Financial Pty Ltd is an authorised credit representative of. We are licensed to arrange loans and leases under the National Consumer Credit Protection Act 2009 (NCCP Act).  The NCCP Act regulates the activity of lending, leasing and finance broking. This Credit Guide is designed to assist you in deciding whether to use the services we offer.
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Services we provide

We will provide you with information on a range of lenders and products.  Once you have chosen a loan or lease that is suitable for you, we will help you to obtain approval.
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Our Associations and Relationships

All our advisers are accredited with Vow Financial Pty Limited which is a wholly-owned subsidiary of Yellow Brick Road Group Limited, however, we source finance from a panel of lenders.

The lenders named below are the eight lenders with whom we conduct the most business: Commonwealth Bank, ANZ, NAB, Bank of Melbourne, ING, ME Bank, Macquarie and AMP.

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Our responsible lending obligations to you

We are obliged to ensure that any loan, or principal increase to a loan, we help you to obtain, or any lease we help you enter, is not unsuitable for you. To decide this, we may need to ask you some questions in order to assess whether the loan or lease is not unsuitable. The law requires us to (a) make reasonable enquiries about your requirements and objectives (b) make reasonable enquiries about your financial situation, and (c) take reasonable steps to verify that financial.

Credit will be unsuitable for you if, at the time of the assessment, it is likely that the following would apply at the time credit is provided; you could not pay or could only pay with substantial hardship; or the credit will not meet your requirements or for example, if you can only repay by selling your principal place of residence, it is presumed that the loan will cause substantial hardship unless the contrary is proved. For this reason, we must ask you to provide a significant amount of information. It is important that the information you provide is accurate, complete and up-to-date. We will provide you with a copy of our preliminary assessment of your application, if you ask within seven years of when we provided assistance to you. This requirement is only triggered if we give you credit assistance. If we arrange a loan for you to purchase or refinance real estate, remember you must make your own enquiries about the value of the real estate and its potential for future growth.  Although we may obtain a valuation, that is for our own use and you should not rely on it.

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Our finance remuneration

Generally, no fees or charges are payable by you to us for our credit assistance. In some instances, a fee for service may be required for complex scenarios. Details of these fees will be set out in a Credit Quote and discussed during the process.

However, you may be charged a lender’s application fee, valuation fees and other fees associated with the loan.  These fees are not charged by us and will be disclosed to you prior to submission of the credit application. Please note, however, that if a valuation is conducted and you ultimately choose not to proceed with the loan, you may be liable for the valuation fees.

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Commissions

We may receive commissions from the lenders and lessors who provide finance for you as our customers. These fees are not payable by you. You may obtain information relating to reasonable estimates of those commissions and how they are calculated.

When we provide you with credit assistance, you may ask us for a reasonable estimate of the commission likely to be received, directly or indirectly by Vow Financial and its credit representatives.

From time to time, we may receive financial or non-financial benefits from Vow, lenders, lessors or others. Some or all of a commission received by Vow may be paid to your Credit Representatives.

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Referral Commissions

Vow may pay referral commissions to our credit representatives for referring to our Diversification Partners such as Vow Conveyancing. Referral Commissions may vary between 20% and 25% of professional fees charged by the Diversification Partner. These fees are not payable by you.

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Referral Fees

We may pay a referral fee (i.e. commission) for third party referrals. An example of a referrer would be a real estate agent or solicitor. This fee is not payable by you. This fee will be disclosed in the Credit Proposal Disclosure Document. You may on request obtain a reasonable estimate of the amount of commission and how it is calculated. Vow Financial and your representative may also receive a benefit for referring you to other specialist service providers.

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Our dispute resolution procedure

If you are unhappy with our services, there are a number of contact points to assist with this.

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1) Elephant Complaints Officer

Email – info@elephantadvisory.com.au

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2) Vow Complaints Officer

Telephone – (02) 8226 8327
Email – complaints@vow.com.au
Post – PO Box H265, Australia Square, NSW 1215
Website – www.vow.com.au

We will endeavour to resolve your complaint quickly and fairly.

If your complaint has not been resolved to your satisfaction, you may contact the Australian Financial Complaints Authority (AFCA), which is an independent dispute resolution scheme for financial services complaints.

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3) Australian Financial Complaints Authority (AFCA)

Telephone – 1800 931 678
Email – info@afca.org.au
Post – GPO Box 3, Melbourne, VIC, 3001
Website – www.afca.org.au

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Things you should know

You should ensure that you have approved finance, in writing from the lender, before entering a binding contract to purchase.

It is important you understand your legal obligations under the loan, and the financial consequences. If you have any concerns, you should obtain independent legal and financial advice before you enter into a loan contract.

We do not make any promises about the value or future prospects of any property you finance with us. You should always rely on your own enquiries.

Before you accept your loan offer, make sure you read the credit contract carefully to understand full details of the loan. If you have any doubts, you should obtain independent legal and financial advice before you enter into any loan contract.

We represent lenders and have obligations to them, and in particular, to not provide any information we know is misleading or deceptive. We also have obligations under the law to report any fraud, forgery, or other illegal activities. Before using our services, it is important that you understand that we have these obligations to lenders, and under the law.

Vow Financial is required to have adequate arrangements in place to ensure you are not disadvantaged by any conflict of interest.

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Your credit advisors

Australian Credit License – Vow Financial Pty Ltd
Australian Credit Licence Number – 390261

Shehan Wijayasinghe
Authorised Credit Representative Number – 483390
Mortgage Industry Association of Australia ID – 848024
Australian Financial Complaints Authority ID – 49428