Privacy Policy

Scope

This Privacy Statement applies to information collected by Equity-One™ and its related bodies corporate.

It outlines how we manage your personal information and safeguard your privacy.

Equity-One™ is committed to providing only the best service which includes the protection of your privacy. We understand how important it is to protect your personal information. Our privacy policy ensures your right to privacy as we recognise that any personal information we may collect will only be used for the purpose of servicing your needs. Be confident that any personal information we collect will be treated with appropriate respect, ensuring protection of your personal information.

Our commitment is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act 1988 and any other relevant law.

What personal information is collected?

Equity-One™ only collects personal and sensitive information (with your consent) that is reasonably necessary for us to perform our functions and required or authorised by or under an Australian law or a court/tribunal order. The kind of personal or sensitive information we collect and hold will depend upon the type of products and services that you request from us and may include:

• information you give us when you request a product or service from us. This information may include your name, address, contact details, employment details/history, social security eligibility, family commitments and relevant identification documents;
• details about your financial needs/objectives, investment preferences/aversion to risk;
• financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;
• communications between us and your financial adviser or mortgage broker; and
• transactional information about the use of a product if you have or had a product with us.

How personal information is collected?

Equity-One™ collects your personal information in a number of ways including:

• directly from you, such as when you provide the information by phone, email, online or paper application form or face-to-face interview and
• from third parties such as credit reporting agencies, other credit providers or from your broker / representative.

Notification of the collection of personal information

Should Equity-One™ collect your personal details from someone other than yourself then, we will notify you as soon as practicable and advise you of the collection in accordance with the requirements under Australian law.

We will ensure that the information pertaining to this policy will be made available to you at the earliest opportunity so that you are aware of the information in relation to the collection, retention, use and disclosure of personal information.

Use and disclosure of your personal information

Equity-One™ may use your personal information in a number of ways including:

• to verify your identity or transactions which you may enter into with us;
• to provide the product and services that you request
• to administer and manage the provision of our products and services;
• to respond to queries, complaints or to provide you with our general customer services;
• to make and review financial information including securities and investment recommendations;
• to assess credit which you seek from Equity-One™ loan programmes and to administer any credit assessments Equity-One™ loan programme provides;
• to comply with laws and regulatory requirements such as the Corporations Act, ASIC and industry standards. This includes complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
• to train our staff; or
• direct marketing*.

We may use your personal information for additional purposes related to the purposes listed above. We will not, however, use your personal information other than for:

• a purpose made known to you;
• a purpose you would reasonably expect;
• a purpose required or permitted by law; or
• a purpose otherwise authorised by you.

In the event that the collection of personal information has not been solicited by us and does not meet the above requirements, the personal information will be destroyed or de-identified.

*We will provide you with the option to opt out of any direct marketing communications.

Third party access to personal information

We may contract out some of our functions such as mailing, settlement services, banking / transaction functions or identification verification to external service providers from time to time and only in those instances will we disclose personal information to those providers. Only information pertinent to these products or services will be provided and confidentiality clauses feature in our service agreements with third party providers and suppliers.

We may also disclose your information to investors in the Equity-One™ Mortgage Fund so that products and services may be offered.

In the event that we disclose information to enforcement agency in relation to an enforcement activity we will make a written note of the use or disclosure.

Where we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations, such information will be held in confidence and not disclosed or used by the potential purchasers. In the event that the business is sold, we may transfer your personal information to the purchaser in which you will be notified accordingly.

Where we have obtained your approval to conduct credit checks, we may obtain personal information from or disclose personal information to credit reporting agencies.

Cross-border disclosure of personal information

We are likely to disclose personal information about you overseas. For instance, our related bodies corporate, third party service providers or other recipients may be based overseas or may use infrastructure outside Australia, including in Philippines.

Should Equity-One™ disclose personal information about you to a person overseas in accordance with our Privacy Statement, we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles.

Government Identifiers

The use and/or adoption of government identifiers will only be used or disclosed if we consider it is reasonably necessary for identification and is in accordance with Australian law.

Quality of the personal information

We will take reasonable steps to ensure that personal information we retain about you is accurate, complete and up to date. However, the accuracy of that information depends to a large extent on the information you provide.

During the course of our relationship with you we request that you inform us of any changes to your personal information.

Storage and security of information

Equity-One™ stores personal information in a combination of computer storage facilities, paper based files and other records for a period of 7 years from the date of when you cease to be a client of Equity-One™. After 7 years, we will destroy your information. We will treat your personal information as confidential and sensitive information as highly confidential and take reasonable steps to protect personal information from loss, misuse, interference, unauthorised access, modification or disclosure.

Access to your personal information

You may request access to the personal information that we hold about you or request correction to personal information that we hold. Subject to the limited circumstances set out below, we will endeavour to process your request in a reasonable time. In order for us to process your request we will need to verify your identity and, in some circumstances, we may need to charge an administrative fee, of which we will inform you in advance.

In the event that we refuse you access to your personal information, we will provide you with an explanation for that refusal. These reasons may include:

• an unreasonable impact on the privacy of other individuals;
• a serious threat to life or health of individuals;
• the request is frivolous or vexatious;
• the request causes prejudice to certain operations in relation to an enforcement agency;
• the information relates to legal proceedings between Equity-One™ and you, and would not be accessible by the process of discovery in those proceedings;
• giving access would be unlawful;
• the information would reveal our commercially-sensitive decision-making process; or
• if we have reason to suspect that unlawful activity, or misconduct of a serious nature is being engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter.

Use of our web site

We will collect some information from you when you apply online through the Equity-One™ website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. We may utilise cookies to identify your browser while you are using our site which does not identify you, but allows us to track usage patterns to measure the level of interest in various areas of our site. All browsers allow you to be notified when you receive a cookie and elect to either accept it or not which if required, your Internet Service Provider can assist you to manage your preferences.

The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email. We will record your email address if you send us an email.

Other company websites

Our website and e-mail messages may contain links to websites operated by other companies. You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this policy.

Anonymity and pseudonymity

Where practicable, Equity-One™ will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, we will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek further information as identified in this privacy policy.

Changes to our Privacy Policy

Equity-One™ may make changes to this Privacy Statement from time to time for any reason and will make concerted efforts to update the website in a timely manner.