Privacy Policy
Freshstart Mortgage solutions ABN 56 109 384 410
At Freshstart Mortgage Solutions Pty Ltd (ABN 56 109 384 410) we want to provide the best possible service to our clients and members by making the most efficient use of your personal information. However, it is of utmost importance to us that you are confident that any personal information provided to us is treated with an appropriate degree of privacy.
Freshstart Mortgage Solutions is a Canberra based organisation providing both residential and commercial finance products, loan tracking and loan processing services to our clients and members.
Freshstart Mortgage Solutions Head Office
95 Anthony Rolfe Ave
Gungahlin ACT 2912
Phone: 02 62011700
Fax: 02 62011799
DEFINITIONS
Personal Information:
Personal Information is information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Sensitive Information:
Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record or health information about an individual.
COLLECTION OF PERSONAL INFORMATION
It is essential for Freshstart to collect personal information to complete its standard business activities of providing both residential and commercial finance products, loan tracking and loan processing services to our clients.
When collecting information we:
- Establish and maintain a database for tracking loan stages to ensure prompt and efficient service from lenders
- Establish and maintain a database for tracking lead stages to ensure prompt and efficient service from our contractors
- Establish and maintain a database for commission processing and follow-up
- Assess clients’ current situation, so as to provide information enabling the client to choose the most appropriate financial product for their needs.
Collection and usage of personal information is essential for us to complete our business with clients. Where reasonable and practicable, Freshstart collect personal information directly from clients. This may occur for example when completing an application form for a product or request a product or service over the telephone or Internet.
Where not reasonable or practicable to collect personal information directly, Freshstart rely on third parties.
Below are examples of situations where we may receive personal information from another source, and why this would happen:
- Application for a service through a Freshstart business alliance
- Processing of online enquiries for service provision
- A Mortgage Originator who provides Freshstart the information to meet legislative requirements
CONSENT
In the majority of circumstances Freshstart will require your specific consent before we collect, use or disclose personal information. Consent will be obtained in writing; however, there may be some situations where your verbal consent is accepted.
DISCLOSURE
Freshstart does not generally disclose personal information to any other party, unless required or authorised by law, consent is given, or is required to complete a business transaction.
There are times when Freshstart is required or authorised by law to disclose personal information. Personal information may be required in accordance with taxation law to be provided to the taxation office, or under subpoena to a Court of Law.
Personal information may also be disclosed where consent has been obtained. Consent may be received directly from a client, as set out above, or may be implied from a client’s conduct.
Personal information is only disclosed to parties outside Freshstart where it is required to complete business activities.
Some examples where this may occur are:
- Lenders for the completion of finance applications
- The Mortgage Originator who originally serviced your finance needs
ACCURACY
It is essential to Freshstart that personal information is complete and up-to-date at all times to effectively conduct standard business activities.
When using personal information we will contact a client to determine if any personal details have changed. Freshstart can also be contacted at any time to update personal information, or to advise that information held is inaccurate or incomplete.
ACCESS
Individuals can request access to their personal information by contacting the Freshstart Head Office. A summary of personal information (E.g. name, address, phone number) is freely accessible.
In some situations, where the information requested goes beyond a basic summary, a fee may be charged for access. This fee is used to cover the cost to Freshstart for retrieving and supplying the information.
Freshstart will endeavor to handle all requests for personal information within 30 days of having received the request. Some requests may take longer than 30 days, depending on the information sought, in which case the individual will be notified of the expected time frame as soon as is practicable.
There are some circumstances where requests for access to information may be denied by Freshstart, such as where the information may relate to existing or anticipated legal proceedings, where denying access is required or authorised by law, or where the request for access is regarded as frivolous and vexatious.
If a request to access or change personal information is denied, we will offer a formal explanation for our actions.
SECURITY
It is of utmost importance to Freshstart that personal information is protected from unauthorised access, loss, modification, misuse or disclosure.
Freshstart employs the following means to ensure that personal information is protected at all times:
- All staff are required to sign confidentiality agreements as a condition of employment
- Security key access
- Username and Password required for access to the local intranet
- Restricted access to databases containing personal information
- Defined levels of access to databases containing personal information
- Backup and Disaster recovery plans to handle major business interruptions
- Regular maintenance and updating of technology products and security systems to prevent unauthorised computer access
When information is no longer required we ensure that it is deleted from our systems, destroyed in a secure manner, or permanently de-identified.
FRESHSTART ON-LINE SERVICES
FRESHSTART understands the importance of privacy to the users of the Freshstart On-line website (http://www.freshstart.net.au). The following statement outlines how in the context of the Freshstart On-line web site information is used, protected and recorded. By using the site visitors consent to the uses below mentioned.
Information Logged
Our server records the information provided by browsers when visiting the Freshstart On-line web site. This includes the date and time of visits, the pages accessed and documents downloaded. It also includes servers IP addresses and if referred from another site, the address of the referring site. Freshstart mostly use the information to make this web site more user-friendly and useful to visitors, and to monitor site use.
Cookies
In common with most other web sites, our web site uses Cookies to enhance the functionality, keep track of visits and provide personalised features. Browser’s can generally be configured not to accept Cookies, however some functionality of our site, and other sites will be lost. The use of on-line services creates the need for us to be able to identify the visitor and cookies are used for this purpose.
About Information Provided
The type of information Freshstart collect is dependent on what products and services accessed on the website. Where specific terms and conditions for a product or service apply they will supersede this general statement to the extent they are inconsistent with it.
Freshstart may use information and contact details, gathered through use of the Freshstart On-line site, or linked or embedded sites for answering queries; identifying products and services which we consider may be of interest, tailoring the site content presented so it fits expected requirements and for marketing purposes within Freshstart.
We may also use your information for other purposes permitted by law, or which a visitor would reasonably expect, such as up-dating our records, contact, or for statistical purposes.
Where applying for a particular product or service through this site the application form may contain special consents concerning the use of information. If consent is provided, which will usually be required before the application can proceed, we may use information as permitted and also for the above purposes.
In common with other financial service providers we use agents and other third parties to provide some services to Freshstart and for this purpose we sometimes need to provide them with relevant parts of the information, which we have obtained from clients under their contracts. These third parties are required to keep your information confidential and use it only for the purposes for which we are permitted.
We may offer through this site products or services that are supplied by or through other organisations. If a client enquires about the service we will need to pass to them relevant details about the client and their enquiry, to complete the transaction.
If provided information to sites linked to or embedded in the Freshstart On-line web site we may see that information but any use of it by us will be subject to this privacy statement.
Information Security
Freshstart takes all reasonable steps to protect clients’ security when using our web site but they should be aware that no transmission of information to and from web sites is ever totally secure.
IDENTIFIERS
In some circumstances certain Commonwealth identifiers (e.g. Tax File Numbers) may be collected as proof of identity when carrying out standard business activities. These identifiers are securely destroyed, and are not used by Freshstart in any way to identify an individual.
Wherever it is lawful and practicable to do so, Freshstart will endeavor to deal with clients anonymously. For example: when a client requests information regarding the services offered by Freshstart.
SENSITIVE INFORMATION
Sensitive information (as defined above) is only collected by Freshstart where consent has been obtained, it is allowed by law, or the collection is necessary for the establishment, exercise or defence of a legal claim.
TRANS-BORDER DATA FLOWS
Freshstart does not send any personal information outside of Australia unless we are authorised to, or required to by law.
COMPLAINTS
Any complaints with regard to the handling of your personal information in breach of this Privacy Policy can be directed to:
Privacy Officer
FRESHSTART MORTGAGE SOLUTIONS PTY LTD
95 Anthony Rolfe Ave
Gungahlin ACT 2912
Ph: 02 62011700
Any complaints that have not been handled satisfactorily by Freshstart Mortgage Solutions Pty Ltd can be referred to the Federal Privacy Commissioner:
Telephone: 1300 363 992, or mail to:
Director of Complaints
Office of the Federal Privacy Commissioner
GPO Box 5218
Sydney NSW 1042
