1. Who we are
1.1 We are Deposit Release Fund Pty Ltd (ABN 54 396 480 510) ATF the First Fund PD Trust and the First Fund SJ Trust and our registered office is located at level 5, 46 Market Street, Sydney CBD, NSW 2000 (“Deposit Release”, “our”, “us” or “we”).
2. Our Values
2.1 We value and respect your privacy and want to be accountable and transparent with you in the way that we collect and use your personal information.
2.2 We appreciate that individuals are concerned about the security of their Personal Information, as such, we are committed to protecting any Personal Information in our custody or control.
2.3 Deposit Release is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”).
3. Application of this Policy
3.1 This policy applies to:
(a) Agents; and
(b) Our Clients.
3.2 Depending on our relationship with you, we may collect and use your information in different ways.
4. Collection of your Personal Information and how we use it
4.1 How we collect your information
We collect personal information (including credit information) received from:
(a) you, voluntarily, when you complete our application form and part-take in the approval process;
(b) third parties, such as, marketing agencies, credit reference agencies, market research companies, public websites and public agencies, refer to as either “third party sources” or “suppliers” throughout this policy;
(c) our website, mobile application, Agent portal, via telephone, email or by any other means through which you communicate with us. This includes, for example, any circumstance where you provide your personal information to us in order to receive information or services from us.
4.2 What information we collect
We, or third parties on our behalf, may collect, hold and use any of the following information (including credit information and credit eligibility information) about you:
(a) Your Contact Information:
(i). your name;
(ii). your postal address;
(iii). your email address;
(iv). your telephone number;
(b) Your Detailed Personal Information:
(i). your date of birth;
(ii). your gender;
(iii). any updates to information (personal or otherwise) provided to us;
(iv). your Australian Medicare information;
(v). your Australian passport information;
(vi). your Australian driver’s license,
(c) Your Financial Information:
(i). your credit file from third parties based on data given to us by you;
(ii). information about your application for credit with us including the type and amount;
(iii). any default information, including when the default has been paid and any new arrangement with us because of a default;
(iv). any serious credit infringements;
(v). credit reporting information we obtain from credit reporting bodies including your credit score;
(vi). any information about you which we derive from credit reports we obtain about you;
(vii). payment history with third parties,
(d) Customer Service Information:
(i). information needed to provide the services to you;
(ii). customer services information;
(iii). customer relationship management and marketing information;
(iv). information you provide to help us provide you with improved service for example if we ask you to fill in a survey or questionnaire; and
(e) Other Information:
(i). information provided when you correspond with us;
(ii). publicly available information;
(iii). information that we require to identify customers, including as required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, which may include details or copies of passports or driver’s licences or utility bills or other documentary evidence of applicants’ identities.
4.3 How we use your information
(a) Your personal information (including credit information and credit eligibility information) may be used, stored and/or accessed or otherwise shared within Deposit Release (and our related companies), to our business partners (Partners) or with third parties, for the purpose of:
(i). recognising you, your preferences, and allows us to customise your experience according to your individual interests;
(ii). taking enquiries, questions or issues from you in relation to our business or services and dealing with such enquiries or issues you may have;
(iii). verifying your identity;
(iv). evaluating your eligibility, including whether it is age appropriate for you to make use of our services;
(v). assessing your credit risk to determine your whether it is appropriate to agree to advance you the funds requested by you
(vi). evaluating your use of the services provided by us and prepare reports or compile statistics to understand the type of people who use our services, how they use our services and to make our service more intuitive;
(vii). sending you communications (including SMS, email or post) in relation to our or our supplier’s products or services (including administration messages) and
(viii). ensuring that the services we provide are secure.
(b) For the avoidance of doubt, third parties may include:
(i). Financial institutions;
(ii). Credit reporting bodies and collection agencies (including report account information, as permitted by law). Please note when we provide information to credit reporting bodies, we authorise them to use that information for the purpose of providing credit reporting services;
(iii). Law enforcement, government agencies, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Deposit Release; and
(iv). Other third parties with your consent or direction to do so.
(c) Third parties may include parties located in jurisdictions with privacy laws that are not comparable to Australia. Where we disclose your Personal Information to an overseas party, we will take all reasonable precautions to ensure that your information is held, managed and accessed in accordance with appropriate standard for the handling of Personal Information. However, if that overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
5.1 We will, from time to time, send marketing materials to those who have provided Deposit Release with Personal Information about product and services offered by us or our Partners.
5.2 If you wish to stop receiving marketing materials from us, you can contact us by email, or unsubscribe using the link at the bottom of any marketing emails.
5.3 Please allow us sufficient time to process your marketing preference. Unless otherwise required by law, it may take between 5-10 days to process any email or SMS op-out preferences, and up to 30 days for all other marketing related requests.
5.4 Even after you opt-out, we may still contact you for transactional or informational purposes. These include, customer service issues, product-related inquiries, payment inquiries, surveys, or any questions regarding a specific transaction.
6. Protecting Personal Information
6.1 We will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorised access, use, modification, and disclosure. Such reasonable steps include the use of physical, technical, and administrative security measures.
6.2 We periodically review our security procedures and consider whether it is appropriate to employ new technology and updated methods.
6.3 Only authorised people, who require your Personal Information to perform their job, will be able to see or use that information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.
7. Your Rights
7.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us at any time.
7.2 Your rights include:
(a) Right to access: subject to any exceptions in the APPs, you have a right to access any personal information (including credit eligibility information) we hold about you. To obtain access to your information, please contact us on the contact information provided;
(b) Right to update your information: you may request an update and or correction to any of your personal information (including credit information and/or credit eligibility information) which we hold. To update your information, please contact us on the contact information provided;
(c) Right to stop marketing: you may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
7.3 We will consider all such requests and provide our response within a reasonable period and in accordance with applicable laws. Please note, however, that we may refuse requests in certain circumstances, for example if giving access would be unlawful or giving access would have an unreasonable impact on the privacy of other individuals. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make. All requests must be made in writing and addressed to the Privacy Officer at email@example.com.
8. Complaint Handling
8.1 Resolutions by Deposit Release (Step 1)
If you have a complaint regarding the management of your Personal Information (including a complaint relating to any failure by us to comply with our obligations under the credit reporting provisions of the Privacy Act 1988 (Cth) or under the Credit Reporting Privacy Code).
Telephone: 1300 001 731
We will provide you with written acknowledgement of your complaint within seven (7) days of receipt. Within 30 days from the receipt of your complaint, we will investigate the circumstances surrounding the complaint and advise you of the steps we have taken to resolve your complaint.
8.2 Resolutions by the Office of the Australian Information Commissioner (Step 2)
If you are dissatisfied with the handling of your complaint, you may contact Australian Financial Complaints Authority (AFCA).
Australian Financial Complaints Authority
Address: GPO Box 5218, Sydney NSW 2001
Telephone: 1800 931 678; or
Online: email firstname.lastname@example.org