Privacy Commitment, respecting your
privacy
This Privacy Policy is relevant to The Bottom Line
Business Advisory
We understand how important it is to protect your
personal information. This document sets out our privacy policy commitment
in respect of personal information that you may provide to us.
Our Privacy Policy ensures your right to privacy as
we recognise that any personal information we may collect about you will
only be used for the purposes indicated in our policy. It is important to
us that you are confident that any personal information we collect from you
or is received by us, will be treated with appropriate respect ensuring
protection of your personal information.
By providing personal information to
us, you consent to the collection, use and disclosure of your information
in accordance with this Policy and any other arrangements that apply
between us.
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.
The Bottom Line Business Advisory is
committed to complying with the Privacy Act 1988 (Cth), the Australian
Privacy Principles and any other relevant laws when handling your personal
information. A copy of the Australian Privacy Principles may be obtained
from the website of The Office of the Australian Information Commissioner
at www.aoic.gov.au.
Who is The
Bottom Line Business Advisory?
The Bottom Line Business Advisory assists
Small to Medium Size Businesses in their Journey to success. We see the
role of an accountant as a Business Partner that creates and shares stories
of success with their clients as their own.
We also look after individuals so they
will not be burdened with their tax obligations. We will make sure that individuals
will get the maximum possible refund and we provide them with a
step-by-step guide and a checklist to make their lives less stressful when
it is tax time.
Most recently, we have also obtained
accreditation with a reputable panel of lenders (including the big 4
banks), to be able to further assist our clients when it comes to one of
the most important decisions they will need to make, whether it is drawing
a loan to purchase their first house or buying an investment property.
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;
·
Loan
account numbers and loan account balances;
·
other
contact details such as social media handles; and
·
other
information we think is necessary relating to the services we provide.
Over the course of our relationship with
you, we may collect and hold additional personal information about you,
including transactional information, complaint or enquiries about products
or services.
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.
We also collect de-identified information if you use
one of our calculators or other programs. Although the information
collected does not identify an individual, it does provide us with useful
statistics so that we can analyse and improve our online services.
We also collect de-identified information from the
online interactions of users who are not customers that use our web
services. Much of this data collection is done through the use of cookies
and used to improve our services and enhance users web experience with us
e.g. website statistics and does not identify individual customers but does
identify internet browser. Where we do identify you (such as where
customers are supplying us with information), we treat any use or
disclosure in accordance with this policy.
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 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.
Sensitive Information
Sensitive information is any information about a
person’s racial or ethnic origin, membership of a political association,
religious beliefs or affiliations, philosophical benefits, membership of a
professional or trade association, membership of a trade union, sexual
preferences or practices, criminal record or health information.
We will not ask you to disclose sensitive
information, but if you elect to provide sensitive information it will be
captured and stored.
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;
·
consider
whether you are eligible for a loan or lease or any related service you
requested;
·
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:
·
identifying
you;
·
telling
you about other products or services we make available and that may be of
interest to you, unless you tell us not to;
·
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 and asset finance aggregators through whom we may
submit loan or lease applications to lenders or lessors our licensees
panel;
·
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 Tax 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;
·
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.
We receive services to support the broking services
we provide you. We receive mortgage aggregation and asset finance
aggregation services from several aggregators, these include:
·
National
Lending Group (the holder of an Australian Credit Licence and who we are
authorised under);
·
Choice
Aggregation Services;
·
National
Finance Choice; and
·
College
Capital Australia.
Sometimes they collect personal
information about customers to manage customer enquiries or complaints,
commissions payment or file reviews
If you want to find out about how they manage your
personal information, please visit their respective websites at the
addresses detailed below:
http://www.choiceaggregationservices.com.au/privacy
https://www.mmsg.com.au/wp-content/uploads/2017/08/privacy-policy-mmsg-november
http://www.collegecapital.com.au/privacy
Sharing outside of Australia
Some of the recipients to whom we disclose your
personal information may be based overseas, including India and the
Philippines. Where we may be transferring personal information overseas, we
will either inform you and seek your consent to the arrangement or ensure
that appropriate contractual measures are in place to ensure that the
overseas entity protects the personal information to the same level as
required by National Lending Group Pty Ltd under the Privacy Act.
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.
Cookies
We may collect personal information about you through
the use of cookies. When you access our website, we may send a “cookie”
(which is a small summary file containing a unique ID number) to your
computer. This enables us to recognize your computer and greet you each
time you visit our website without bothering you with a request to
register. It also enables us to keep track of products or services you view
so that we can send you news about those produces or services. We also use
cookies to measure traffic patterns, to determine which area of our website
have been visited and to measure transaction patterns in the aggregate. We
use this to research our users’ habits to that we can improve our online
products and services. Our cookies do not collect personal information. If
you do not wish to receive cookies, you can set your browser so that your
computer does not accept them. We
may log IP addresses (that is, the electronic addresses of computers
connected to the internet) to analyse trends, administer the website, track
user movements, and gather broad demographic 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’.
What happens if
there is a Data Breach?
In the unlikely event that we
suspect that there has been a data breach that may cause you serious harm,
we will take all reasonable steps to assess if your data has been accessed
or lost, and if this information being accessed or lost may cause you serious
harm. This assessment will always be completed expeditiously and within 30
days.
If we find that there has been a
data breach that has the potential to cause you serious harm, this will be
reported to the Office of the Information Commissioner and you directly.
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:
The Bottom Line Business Advisory
Waterman Business Centre, Suite 87, Level 2 UL40/1341 Dandenong Road,
Chadstone VIC 3148
+61 3 9013 3773
admin@thebottomline.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:
The Bottom Line Business Advisory
Waterman Business Centre, Suite 87, Level
2 UL40/1341 Dandenong Road, Chadstone VIC 3148
+61 3 9013 3773
admin@thebottomline.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 using
your preferred communication method and by updating our website. Should you
require a copy of our Privacy Policy please specify the manner in which you
would like to receive it and a copy will be sent to you.
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