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Privacy Statement

1 Introduction

Elders Home Loans Pty Limited (ACN 118 064 654) (“us”, “we”, “our”) is committed to safeguarding your privacy by ensuring your personal information is protected in a way that observes our own corporate values, as well as complying with the requirements of the National Privacy Principles, which are part of the Privacy Act 1988 (Cth) (the “Act”).

2 Scope of Statement

This statement applies to Elders Home Loans Pty Ltd. It lets you know what we will do to comply with the 10 National Privacy Principles. The objective of the Act is to set a standard for protecting the privacy of all individuals.

2.1 The Company’s Corporate Relationship

We are a company that is jointly owned by the Elders Mortgage Brokers Pty Ltd (ACN 118 064 645), a wholly owned subsidiary of Futuris Corporation Limited (ACN 004 336 636), and Combined Financial Management Pty Ltd (ACN 115 420 918).

3 Definitions

3.1 Personal Information

Personal information is a term defined by the Act. Your personal information includes details such as your name, address, date of birth, contact details (such as phone and fax numbers, e-mail addresses).

3.2 Sensitive Information

Sensitive information, which is also defined by the Act, is a subset of personal information and by its "sensitive" nature has the potential to be used for discriminatory purposes. Recording and use of sensitive information have stricter requirements than other types of personal information.

Examples of sensitive information include but are not limited to personal information or opinions on your health, criminal records, sexual preferences, religion etc. Sensitive information can only be recorded if it is relevant to do so and with your consent. Generally, sensitive information is not relevant to the assessment of home loan applications.

4 Our Privacy Principles

4.1.1 Collection of Personal Information (National Privacy Principle 1)

Where you have requested a product or service, we collect your personal information (where necessary) primarily to identify you or your business entity and to assess and establish the product or service you have requested.

4.1.2 Your Rights and the Disclosure of Personal Information

You need not give personal information about yourself that is requested by us to supply our products and services. However, without that information, we may not be able to provide you with the products or services you requested.

4.1.3 Use of Information (National Privacy Principle 2)

We collect your personal information and use the information to provide products and services requested by you. We may use your personal information for related purposes, such as a credit agency references, in accordance with the National Privacy Principles. Your personal information may also be used to complete internal business functions such as auditing, management reporting, research, product development and planning.

4.1.4 Disclosure of Information (National Privacy Principle 2)

In providing products and services we may disclose your personal information to organisations that carry out functions on our behalf. This may include (but is not limited to) home loan lenders, sales agents and franchisees, credit reference agencies, our shareholders (and their related entities), mailing houses and other services providers we use in the provision of secondary services. These secondary services might include external auditors, computer and information technology service providers for computer, internet, network distribution and related functions.

Although we will use our best endeavours to ensure your personal information is safeguarded in a manner consistent with our privacy policy, we cannot accept liability for any misuse of your personal information by those third party organisations or individuals to whom we disclose your personal information.

We may also use and disclose your personal information to complete business functions within our business (and that of our shareholders and their related entities) such as auditing, management reporting, research, product development and planning.

4.1.5 Marketing

In accordance with the National Privacy Principles we and the Futuris Group of Companies may also use and disclose your personal information to send direct marketing material about other products and services from the Futuris Group of Companies that may be of interest to you. If you do not want to receive information about these products and services please tell us by contacting our Privacy Officer at the contact details set out in section 6. You will continue to be provided with information about terms and conditions, statements and other information specific to your existing accounts or services if you request us to stop sending marketing materials.

4.1.6 Data Quality (National Privacy Principle 3)

We are required to ensure your personal information collected, used or disclosed is, at all times, accurate, complete and up to date. You should advise us immediately you become aware that any information we hold about you is incorrect or out of date. We undertake to amend our records as soon as practical after you advise us subject to the validity of the request being confirmed.

4.1.7 Data Security (National Privacy Principle 4)

We will take all reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification and disclosure. Your information may be stored in paper or electronic format. Security measures implemented on our IT systems will take account of internal and external recommendations, general industry practice and technological development in the provision of IT security services. Our IT security measures include state of the art firewall technology, encryption of internet and phone services. We may use “cookies” on our website to ascertain your product preferences and tailor your future visits to the site to suit you. Most web browsers can be configured to not accept cookies; however the site functionality may be restricted as a result. Other than statistical information we do not collect information about you through our website other than that information you deliberately provide us.

4.1.8 Openness to Our Practices (National Privacy Principle 5)

We have developed this statement to outline information handling practices. Information in this statement gives you some insight into how we manage your personal information and your rights in relation to our use and handling of your personal information.

4.1.9 Access (National Privacy Principle 6)

You are entitled to access personal information we hold about you. The type of information that you may request is your personal information as well as any comments, opinions and file notes that we hold about you. We will process your request within a reasonable time, generally 14 days for a straight forward request. However, additional time may be needed depending on the nature of the request. There is no fee for lodging a request for personal information. However, we reserve the right to recover reasonable costs associated with processing the request. You will be advised the cost, if any, before we proceed.

We are not required to provide you with access to your information where the law allows us to deny access. If we deny you access to your information we will provide reasons for that denial.

A request to access your personal information should be directed to the Elders Home Loans Privacy Officer. The contact details are set out in section 6 below.

4.1.10 Correction (National Privacy Principle 6)

You may ask us at any time to correct personal information we hold about you. We undertake to correct the information within a reasonable time of your request provided we are satisfied as to the validity of the request being confirmed. If the validity of your request cannot be confirmed by us you will be advised that we have not acted on it and the reason why. If we disagree with your request to correct information we hold, you have the right to request that we place a statement with that information noting your disagreement.

4.1.11 Identifiers (National Privacy Principle 7)

Identifiers are unique numbers that a Commonwealth Government agency has assigned to you. These include tax file numbers and Medicare numbers. There are special rules in the Act governing use of identifiers. We undertake to comply with those rules.

4.1.12 Anonymity (National Privacy Principle 8)

Elders will allow you to interact anonymously wherever it is lawful and practical to do so.

4.1.13 Trans Border (overseas) Data Flows (National Privacy Principle 9)

A request for a transaction or service that requires your personal information to be transferred to another country might result in a transfer to a country that does not have the same privacy laws as Australia. This may occur, for example, where a lender selected by you is resident overseas.

4.2.14 Sensitive Information (National Privacy Principle 10)

If it is necessary to record sensitive information, we must obtain your specific consent to collect that information. Sensitive information is generally not required for most of our products and services. You are entitled to access any information that we record.

5.0 Information required for Statutory Compliance Purposes

In addition to questions that we may ask to ensure general statutory compliance there may be special circumstances where the company or its agents are required to seek additional information about you to provide to government.

6.0 Further Information or Questions

You may contact our Privacy Officer to make any inquiries about your personal information, make a complaint about our dealings with your personal information or make access and correction requests. All inquiries will be managed consistent with the National Privacy Principles and our general procedures. The Privacy Officer will also provide you with contact details for the Privacy Commissioner if we are unable to resolve a complaint to your satisfaction. Our Privacy Officer can be contacted between 8am and 6pm Monday to Friday (excluding national and South Australian public holidays) by:

Telephone:1300 555 927
Fax:08 8425 4111
Post:GPO Box 551 Adelaide South Australia 5001
Email:privacy@elders.com.au