AFE Privacy Policy

Commitment to Privacy and Responsible Use of Information

AFE is a member of the Firstfolio Group. AFE’s ultimate owner is Firstfolio Limited, a provider of financial services. This privacy policy applies to information collected by Firstfolio Limited and its related bodies corporate, including AFE.

We understand your concerns about privacy and the security of your personal information. We are committed to protecting all your personal information that is in our possession. This policy sets out how we manage your personal information and protect your privacy.

Privacy

We will not obtain personally-identifying information about you when you visit our sites, unless you choose to provide such information.
In this document we explain the steps we take to keep your information private.

What’s our privacy policy in four sentences?

• We’ve built our sites so that you identify yourself only when you’re ready to learn more about our services, you wish to hear from us, or you wish to receive information from one of our financial services consultants, from other partners and from related companies.
• We keep your personal information secured utilising firewalls, encryption and other secure technologies.
• We don’t share your name with anyone else – you are a customer, not a name in a database we can sell.
• We treat your information the way we’d want our own personal information to be treated.

What information do we collect?

We help you find the product that’s right for you. While we’re doing this, we avoid collecting information that could identify you, until you wish to speak with one of our finance services consultants or learn more about our products and services.

The only personal information which we collect about you when you use our sites is what you tell us about yourself – for example, by completing an online form such as a careers interest or asking for details on a specific product, or by sending us an email. We will record your email address if you send us an email.

This is what we might collect:

• To be matched to a loan, you will need to provide personal information which we call applicant details. These apploicant details include your name, address, phone number, email address and some financial details.
• We also invite you to tick a box to request information on services that we offer or may offer in the future. We call this an offer confirmation.
• We also offer you the opportunity to subscribe to our email bulletins. If you decide to subscribe, we collect your name and email address, which we call subscriber details. Before we start sending you bulletins, we will confirm via email that you have subscribed to the bulletins. This ensures that you are not accidentally or mischievously subscribed by other people.
• We also offer some users a service where they can send messages to friends to let them know about our sites. As part of this service, we store email addresses submitted by users. We call these friend email addresses. As part of this process, we may record the progress of messages sent but we do not record the content of these messages.
• Lastly, we record data on the use of our site from particular Internet addresses and users, which we call usage details.

How do we keep your information safe?

Once your information reaches us, it is physically stored on our computer systems, including at a purpose-designed secure facility. Electronic access to this information is controlled by security processes that include encrypted passwords, firewalls and expert monitoring. Our staff have access to this information only on a need-to-know basis.

We minimise the use of printed material which contains your applicant details and subscriber details. We store such information securely and destroy it thoroughly when it is no longer needed.

Most importantly of all, we make sure that our staff and contractors understand their responsibility to protect all your personal data from misuse, loss, corruption or disclosure. We hire and contract with people who respect our users’ rights, then we train them on the steps they must take to protect users’ personal information. After that, we get them to tell us when they see anything that might jeopardise your personal information.

Can you see, change or remove your data?

Yes.
You may change your applicant details via the Web while you are on our sites, or in conversation with our consultants. You may also update your details at any time before a loan settles by calling our offices or contacting us. We are as keen as you are to ensure that our information about you is accurate.

We can also provide you with a copy of your applicant details at any time, on request, as soon as we confirm your identity.

We can also “de-identify” your applicant details on request if you have not yet requested us to begin the loan approval process with a nominated lender. Once your details are “de-identified”, we will be unable to tell that an application was made by you. Please note that:
• We may need to confirm your identity before de-identifying you.
• We need to retain identity information for users who have requested us to begin the loan approval process with a nominated lender.

Whenever we make an offer to users, we provide a way for you to tell us that you do not want further offers. We will make sure that from that point on, you don’t get any more offers.

Each email bulletin sent contains instructions on how to simply remove your subscriber details from our email database. If this automatic process fails, we will remove your subscriber details manually on request.

You can contact us at any time to talk to us about your data. Click here for contact information.

Do we use “cookies?”
Yes.
Cookies are small text files stored on your computer. They are used by most major Web sites. They cannot read other material on your computer or damage your system. However, there are legitimate concerns that cookies can be misused to gather information surreptitiously. We use cookies openly and honestly, and maximise your privacy in the process.

We uses cookies in two ways:
• To allow our matching process to be completed. The cookies used here are “transient cookies”, sometimes called “session cookies”. These cookies are not stored on your computer’s hard disk, cannot be linked to applicant details or subscriber details, and are discarded when you finish the matching process, or if you have left the loan-matching process alone for more than 30 minutes. We cannot use any information from these cookies to find out anything about you. Without them, we cannot complete the loan-matching process.
• To record usage details – primarily, how many times a visitor has been to our site before. The cookies used here are “persistent cookies” that remain on your hard disk for a year after your visit our sites. They contain no information that could be read by any other user of your computer. These persistent cookies ensure that no user receives an exit survey twice, and help us make our sites easier to use for both new users and those who are familiar with our sites. However, if you disable persistent cookies in your browser, you can still use our sites.

We do not allow any other party to set cookies on the our sites, so no other party can link your visits to our sites to your activity elsewhere on the Web.

How do we use information gathered on our sites?

The applicant details gathered on our sites are used to:
• match your needs with products in our network database;
• inform our telephone consultants and loan managers;
• allow financial institutions to verify eligibility for our services;
• send offers to those users who have asked us to do so; and
• make our process easier and better to use.

Prior to disclosing any of your personal information to another party, we will take all reasonable steps to satisfy ourselves that the other party also has a commitment to protecting your personal information that is at least as strong as ours, and that you consent to us disclosing your information to that party.

We have ensured that lenders in our network have their own strong privacy policies in place. We will release your applicant details to one of our home loan managers and to a lender or lenders in our network only if you give us explicit verbal permission to do so. We will ring you to obtain this permission. With this necessary exception, we will not release your applicant details to any third parties.

With your consent, we may use the details you provide to us to inform you of special offers that may be of interest to you. If you confirm that you wish to receive information on offers and services (by ticking a box on our site), we may send you information about offers and services not specifically related to the services which you have previously contacted us about. We will not send such information to any party who has not explicitly asked for it, and we will cease sending it immediately upon your request. Whenever we make an offer to users, we provide a way for you to tell us that you don’t want further offers. We will not release confirmation details to any third parties.

The subscriber details gathered on our sites are used to correctly address our email bulletins. Again, we will release applicant details if the law or the interests of law enforcement require it. With this one necessary exception, we will not release subscriber details to any third parties.

The usage details gathered on our sites are used to make our sites and processes easier to use. For instance, if we see users coming to our site many times before applying for a loan, we might work to make it easier for users to apply right away. We will not release usage details to any third parties.

We may also share aggregated data with financial institutions in our network, or use it internally to improve the quality of the services we offer. For instance, we might tell a lender that half of our users rated their service as “excellent”. Aggregate data does not include information that can be used to identify any individual user.

As required by law, we will also release information if the law or the interests of law enforcement require it. For example, we may be required to disclose personal information to a Court or Tribunal, in response to a subpoena or to the Australian Taxation Office.

Privacy and the law

Information gathered in our home loan applications is handled in accordance with the Privacy Act 1988 (Commonwealth), including the credit provision in Part IIIA and the National Privacy Principles issued by the Australian Privacy Commissioner in September 2001.

At all times it is our commitment to abide by the National Privacy Principles for the protection of personal information, as set out in the Privacy Act and other relevant laws.

Who should you contact about privacy issues?

If after reading this document you still have queries or concerns about the privacy of the information we hold, or if you want it changed, de-identified, deleted or provided to you, just contact us by email, phone, fax or letter. If you have any queries about this policy or how we handle your information please contact Muneeza Mirza via email to mmirza@firstfolio.com.au