Privacy Policy

About this page

This page has two parts:

• Part 1 is Hunter Galloway’s Privacy Policy. It explains how we handle personal information.

• Part 2 is Connective Credit Services Pty Ltd’s Privacy Disclosure Statement and Consent. It applies when you ask us to assist with finance.

Read both parts together. Part 1 provides additional information about Hunter Galloway and does not change Part 2. Part 2 applies to the consents you give for your finance application.

On this page, "CRS" means a credit reporting service listed in Schedule 1 to Part 2.

We comply with the Privacy Act 1988 (Cth), including the Australian Privacy Principles and the credit reporting rules in Part IIIA. Part 1 is also our credit reporting policy.

This policy applies to current and prospective applicants, co-applicants, guarantors, company directors, referrers, enquirers and clients, whether or not an application proceeds.

Part 1 — Hunter Galloway Privacy Policy

1. Who we are and how to contact us

Our Privacy Officer

2. The information we collect

Part 2 describes the kinds of personal information we collect, including sensitive information. This section covers information not described there.

Credit information

Credit information may include credit you hold or have applied for, your repayment history, defaults, serious credit infringements, hardship information, publicly available insolvency information, credit scores, and information exchanged between credit providers and credit reporting services.

Government identifiers

We may collect government identifiers, such as your driver licence, passport, Medicare number or tax file number. We only collect them where reasonably necessary to verify your identity, assess an application or comply with the law.

We do not use a government identifier as our own identifier. We only use or disclose it where authorised or required.

Information collected automatically

When you use our website or online forms, we may collect your IP address, device and browser details, pages visited, timestamps, security logs, submission records and related technical information.

Transcription

We record and transcribe our conversations with you, including phone calls and video calls, so we can keep accurate notes of what was discussed. Those notes help us confirm your instructions, keep your file complete, support and train our team, and meet our compliance obligations.

Recordings and transcripts are personal information and are handled under this policy. Where a conversation covers health, hardship or vulnerability, that content is sensitive information and is handled accordingly. If you would prefer not to be recorded, tell us and we will arrange another way to speak with you.

3. How and from whom we collect information

Where possible we collect information directly from you. We may also collect information from:

• your co-applicant, spouse or partner, and any guarantor or potential guarantor;

• a company of which you are a director, and its officers or advisers;

• your accountant, financial adviser, solicitor, conveyancer, real estate agent or buyer’s agent;

• your employer, payroll provider or another source used to verify employment and income;

• anyone who referred you to us;

• credit providers, lenders, lessors and insurers, including about the progress of an application;

• credit reporting services, where you have authorised us to obtain a report;

• valuers and lenders mortgage insurers;

• bank statement, open banking, identity and fraud prevention providers that you use or authorise, including Frollo; and

• public sources, including government, company and property databases.

If we collect information about you from someone else, we take reasonable steps to make you aware of it, unless you would reasonably expect it, you gave us authority to do so, or an exception in the Privacy Act applies.

If you give us information about another person, including a co-applicant, guarantor, dependant or company officer, you must have their permission and should direct them to this page.

4. The systems and service providers we use

We may disclose information to organisations that provide services to us. The table below lists our main systems and service providers. It is a guide rather than a complete list — we use other systems as well, and the systems we use change over time. Information may be stored in these systems or pass through them, and they are located in Australia and overseas.

This list is not exhaustive and we are not limited to the systems named above. We use other services from time to time — for example a new tool we adopt, a short-term provider, a particular lender’s own system, or a specialist service needed for one application. Where that happens we apply the same standards described in this policy.

We keep an internal vendor register and review it at least annually, and whenever a system is added, changed or removed. You can ask our Privacy Officer for more detail about a system, the information it handles, where it is held, or anything we use that is not listed above.

5. Sending information overseas

Part 2 identifies the Philippines, India and Nepal as possible overseas locations.

Hunter Galloway’s offshore support team is located only in the Philippines. We do not have employees or support teams in India or Nepal.

Some technology providers may process information in the United States or other countries. Connective, credit providers and other service providers may also use overseas personnel, infrastructure or subcontractors.

Before disclosing personal information to an overseas recipient, we take the reasonable steps required by the Privacy Act to ensure the recipient does not breach the Australian Privacy Principles in relation to that information, unless an exception applies. We generally remain accountable for how the recipient handles it.

You can ask our Privacy Officer where information held in a particular system is located.

6. Artificial intelligence tools

Part 2 explains that we may use artificial intelligence, machine learning and automated systems. This section explains how we use these tools.

We use artificial intelligence in two ways.

First, we use AI services directly to help with administrative work — preparing meeting notes, summarising conversations, extracting or organising information, and drafting or reviewing documents.

Second, some of the broker systems listed in section 4 have artificial intelligence features built into them. Quickli, which we use to work out borrowing capacity, is one of these. Where we use those features, your information is handled under that provider’s own terms and privacy policy as well as this policy.

In both cases our staff check the output and remain responsible for every recommendation or decision we give you.

For the AI services we use directly, we use paid accounts, not free or personal ones. Where possible we use a business-grade plan. Where a business plan is not available or practical, we use a paid plan set up so that your information is not used to train the provider’s models.

We limit use to approved accounts, control what our staff may enter, and apply human review. Artificial intelligence is never the sole decision-maker for your application.

The AI services we use directly are based in the United States, as set out in section 5. You can ask our Privacy Officer for more information, or ask us not to use an AI tool for your file. We will consider the request and explain any practical effect on the service.

7. Computer-assisted and automated decision support

We use computer programs to support assessments and manage our workflow. The main one is Quickli, which brings together servicing calculators from a large number of lenders so we can compare your borrowing capacity across them.

These programs may use:

• identity and contact information

• residency information

• employment and income

• expenses, assets and liabilities

• bank transaction and credit information

• property and security details

• application history

• documents and verification results.

They may help us:

• calculate indicative borrowing capacity

• compare lender or product eligibility

• identify missing or inconsistent information

• support identity and fraud checks

• manage workflow

• prepare an assessment or recommendation.

These activities can substantially support decisions about whether an application is suitable to progress, or which providers we consider.

We do not make a recommendation to you solely through an automated process. A broker reviews your circumstances, the available information and the program output. A credit provider may apply its own automated processes under its own privacy policy. You can contact our Privacy Officer to ask how an assessment was reached, or to request human review of an outcome produced using our systems.

8. Our online client form

Information entered into our online client form is encrypted while being sent, and stored using approved infrastructure. Once transferred to our client systems, it is handled under this policy and the retention rules in section 9.

The form has a documented deletion schedule covering submitted forms, saved drafts, abandoned forms, logs, attachments and backups.

Service providers may assist with authentication, security, hosting and backups. They may process information in the countries identified in section 5.

9. How long we keep information

We keep information for as long as we reasonably need it for the purposes described on this page, and for as long as the law, our professional obligations, dispute management needs and Connective’s record retention requirements require.

Credit law requires us to keep certain records, including preliminary assessments, and to give you copies on request for up to seven years after the credit assistance or settlement. Anti-money laundering law has its own record keeping requirements. This means we cannot always delete your whole file on request.

For identity verification, we keep the minimum records needed to show the checks we performed. We do not keep full copies of identity documents only for record keeping where the law and our approved procedure do not require it. Where a copy is reasonably necessary, we protect it and destroy or de-identify it when it is no longer needed.

When information is no longer needed for any permitted purpose, we take reasonable steps to securely destroy it, or to de-identify it — that is, remove the details that would let someone identify you.

10. Data breaches

If we suspect a data breach involving personal information, we contain and assess it promptly under our data breach response plan. Where a breach is likely to cause serious harm, we notify the people affected and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme, and explain what they can do to reduce the harm.

11. Accessing and correcting your information

Part 2 sets out your right to ask for the information we hold, to have it corrected, and to get copies of our privacy documents. To make a request, contact our Privacy Officer. We generally respond within 30 days and do not charge for a correction.

We may refuse access where the Privacy Act permits or requires it. If we do, we will explain why in writing, subject to any legal restrictions, and tell you how to complain.

12. Direct marketing

We only send marketing where you have agreed, or where the law otherwise permits it. Marketing may include information about our services, loan and interest rate news, and relevant offers.

You can opt out at any time — email your broker, use the unsubscribe link in any email, reply to any message, or email us at hello@huntergalloway.com.au. We process opt-out requests promptly and at no cost, and you do not need to give a reason.

Messages about your enquiry, application, settlement, existing loan or a review you asked for are service messages, not marketing.

13. Changing or withdrawing your consent

You can change or withdraw any consent at any time — just email your broker, or email us at hello@huntergalloway.com.au. You do not need to complete a form or give a reason. We process your request promptly and at no cost.

Withdrawing consent does not affect anything we have already done in reliance on it. If you withdraw a consent we need in order to act for you, we may be unable to continue, and we will explain the effect before we stop.

14. Complaints

Tell us if you are concerned about how we have handled your information. We aim to acknowledge a complaint within 7 days and give you a written outcome within 30 days, unless the law requires a different period. We will tell you if we need more time, and why.

Time limits may apply to AFCA complaints. Act promptly, or check AFCA’s current rules.

15. Changes to this policy

We review this policy at least annually, and whenever our systems, service providers, business practices, the Connective template or the law change significantly. The current approved version is on our website.

Part 2 — Privacy Disclosure Statement and Consent

Part A

Overview

In handling your personal information, Hunter Galloway Finance Pty Ltd ABN 20 605 252 926 and its individual representatives ("the Broker") are committed to complying with the Privacy Act 1988 and the Australian Privacy Principles.

The Brokers are authorised credit representatives of Connective Credit Services Pty Ltd Australian Credit Licence 389328 (‘we, us, our’). Any reference to "we, us, our" are to the Broker and will include reference to our aggregator, Connective Broker Services Pty Ltd and any of its related companies ("Connective").

We collect information about you for the purposes you agree to in this Privacy Disclosure Statement and Consent ("Consent"). When you ask us to assist, you agree we can, consistent with Australia’s privacy and credit reporting laws, collect, use and exchange consumer and/or commercial credit and personal information ("information") about you for those purposes.

We are collecting information about you, as applicable:

• To source for you, or a company of which you are a director:

  • Consumer credit for personal, household, domestic or residential investment purposes; or

  • Commercial credit for business purposes; or

  • Other services stated in this Consent; or

• To support a guarantor application, you will provide.

As your broker, we require the information we collect from you to assess your credit or guarantor application or the credit application of a company of which you are a director, to source a suitable credit provider and any required insurances and to manage the application process, where required. If you do not provide the information sought, we may be unable to process your application, or the company’s application, or we may be limited in the other services we can offer you or the company.

Your information - Collection and Disclosure

The personal information we collect may include a broad range of information from your name, address, and contact details to other information about your qualifications, employment history and financial information.

"Personal information" may include any sensitive information (including health information) and may include any information you tell us about any vulnerability you may have. We may use that information to assess your application and, where appropriate, to source a suitable credit provider or lessor and / or insurance provider. We may, as appropriate:

• Disclose your identification information to a consumer credit reporting service ("Consumer CRS") and/or a commercial credit reporting service ("Commercial CRS"), where we hold your consent, (refer Schedule 1).

• Use any information a CRS provides in its report to assist us to preliminarily assess your credit or guarantor application (references to a "CRS" could be to either a Consumer CRS or a Commercial CRS).

• Disclose your information to an insurer or insurers to source any insurances you wish to obtain; and

• Disclose your information to our advisers, aggregators, licensees and other financial intermediaries, a credit provider or credit providers to apply for finance on your behalf.

We may use artificial intelligence (AI), machine learning tools, and automated systems to assist us in providing our services. These tools may be used to extracting data from bank statements, creating summaries of documents, and matching your information with lender policies.

Your personal and credit information may be processed using AI systems operated by us or by trusted third-party service providers. Where AI tools are provided by third parties (including cloud-based services), we take reasonable steps to ensure your information is handled securely and in accordance with Australian privacy laws.

Some of the recipients to whom we disclose your personal information may be based overseas. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include the Philippines, India and Nepal.

How we protect your information

We take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or exposure. All Connective staff are required by the terms of their employment to maintain the confidentiality of customer information. Access to your information is restricted to those employees whose job requires that information. Access to our premises and computer systems is restricted through locks, password protection, internet firewalls and routers.

We will take reasonable steps to destroy or de-identify your personal information when your personal information is no longer required for our business functions.

Credit Providers

As part of providing our services to you, we may undertake tasks for a credit provider which are reasonably necessary to manage the application process. When doing so, we are acting as agent for the credit provider, with the same privacy law requirements applying to both of us.

We may submit your application to one or more credit providers. A full list of the lenders (credit providers) we have access to can be found at:

• www.connective.com.au/lender-panel, and

• www.connective.com.au/caf/lender-panel

A credit provider, to whom we submit an application, may disclose information about you to, and collect information about you from, one or more CRS.

The website of each credit provider contains details of each CRS with which it deals and other details about information held about you, including whether that information may be held or disclosed overseas and, if so, in which countries. The websites also describe your key rights. These details may be described on the credit providers’ websites as ‘notifiable matters’, ‘privacy policy’, ‘credit reporting policy’ or ‘privacy disclosure statement and consent’, or similar.

For each Consumer CRS a credit provider uses, the website details will include the following specific information:

• That the CRS may include information the credit provider discloses about you to other credit providers to assess your credit worthiness.

• That, if you become overdue in making consumer credit payments or commit a serious credit infringement, the credit provider may disclose that information to the CRS.

• How you can obtain the credit provider’s and/or the CRS’s policies about managing your information.

• Your right to access and/or correct information held about you and to complain about conduct that may breach the privacy and credit reporting laws.

• Your right to request a CRS not to undertake pre-screening for purposes of direct marketing by a credit provider.

• Your right to request a CRS not to release information about you if you believe you are a victim of fraud.

This detail will also be included by the credit provider who approves your application in the privacy disclosure statement and consent document it will provide to you.

Each credit provider website includes information on how to contact it and how to obtain a copy of its privacy documents in a form that suits you (e.g. hardcopy or email).

You agree we may:

• Use your information:

  • To assess your consumer or commercial credit and/or guarantee application and/or to assess a credit application by a company of which you are a director.

  • To source any finances you require.

  • To source any insurances you require.

  • As the law authorises or requires.

• Disclose to, and obtain from, any prospective credit provider or insurer, information about you that is reasonably necessary to obtain the finance and insurances you require.

• Obtain from, and disclose to, any third party, information about you, the applicant(s) or guarantor(s) that is reasonably necessary to assist you obtain the finance and insurances required.

• Provide your information, including your credit report(s), to one or more of the credit providers so they can assess your application, or the application of a company of which you are a director, or your suitability as a guarantor.

• Provide information about you to a guarantor, or prospective guarantor.

• Disclose your information to the extent permitted by law to other organisations that provide us with services, such as contractors, agents, printers, mail houses, lawyers, document custodians, securitisers and computer systems consultants or providers, so they can perform those services for us. Some of which may be located overseas.

• Disclose your information to any other organisation that may wish to acquire, or has acquired, an interest in our business or any rights under your contract with us, or the contract with us of a company of which you are a director.

• Use AI tools and artificial intelligence systems to assist in analysing your information for the purposes outlined above, subject to human oversight.

Your rights

You have the right to ask:

• Us to provide you with all the information we hold about you.

• Us to correct the information we hold if it is incorrect.

• Us for copies of our privacy policy and this Privacy Disclosure Statement and Consent, in a form that suits you (e.g. hardcopy or email).

• A CRS not to use your information for direct marketing assessment purposes, including pre-screening.

• A CRS to provide you with a copy of any information it holds about you.

You can gain access to the information we hold about you by contacting our Privacy Officer at the following address:

PO Box 12780, George Street, Brisbane QLD 4003

In some cases, an administration fee may be charged to cover the cost of providing the information. Our Privacy Policy also deals with our complaints process and is available on our website or we will provide you with a copy if you ask us. Schedule 1 at the end of this page sets out the contact details for each CRS.

Extended Effectiveness for Commercial Credit

Your agreement and consent to the disclosures and consents in this Privacy Disclosure Statement and Consent will be effective for a period of 12 months, but only in relation to commercial credit. Your agreement to this ceases when you either withdraw it by contacting us using our details above or 12 months after you provide that consent through our application process, whichever first occurs. This will allow us to continue to provide our services to you without the need to ask you to provide a new privacy statement and consent each time you require commercial credit within a 12-month period. The extended effectiveness does not apply in relation to consumer credit.

Where the applicant, or guarantor, is a company of which you are a director, you consent to the disclosure and use of your information, in addition to the company’s information, in each of the ways specified in this Privacy Disclosure Statement and Consent.

Your consent to collect and disclose

By asking us to assist, you consent to the collection and use of the information you have provided to us for the purposes described above.

For more information on your privacy rights please visit www.oaic.gov.au

Part B

Your consent to provide your personal information to a credit reporting body (CRS)

We can act as your agent to obtain a report or information about your consumer or commercial credit worthiness from a (CRS). To do so, we may disclose personal information such as your name, date of birth and address to the CRS to obtain an assessment of whether that personal information matches information held by it.

If you provide this consent through our application process, you authorise the Broker or Connective to obtain a credit report on your behalf.

You also agree and consent to, as appropriate:

• A CRS specified in Schedule 1 disclosing information to a credit provider for the purpose of assessing your application for consumer or commercial credit or your guarantor application, and/or assessing a credit application by a company of which you are a director.

• When you are a prospective guarantor, a credit provider using that information to assess your suitability as a guarantor.

• A credit provider disclosing your information (including information obtained by it from a CRS) to a guarantor, or a prospective guarantor.

• A credit provider disclosing to another credit provider, to your agent, such as us as your broker, or to a servicer, for a particular purpose, information it holds about you.

If you provide this consent through our application process, you consent to us making a request on your behalf to obtain information about you from one or more credit reporting service(s) and credit provider(s). That information will assist us in providing our services to you.

Schedule 1 - CREDIT REPORTING SERVICES

CONSUMER/COMMERCIAL CREDIT REPORTING SERVICES