Privacy Policy for Front Line Financial Solutions PTY Ltd
In this Privacy Policy, the expressions “we”, “us”, and “our” refer to Front Line Financial Solutions PTY Ltd (ACN 51 102 810 837, Australian Credit Licence 389747) and its related businesses, including Frontline Car Loans, and our aggregator, Australian Finance Group Ltd (ABN 11 066 385 822, Australian Credit Licence 389087) and its subsidiaries.
Our Commitment to Protect Your Privacy
We understand the importance of protecting your personal information. This Privacy Policy outlines our commitment to managing your personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2014 (Credit Reporting Code), and other relevant laws. It applies to all personal information and credit-related information we collect, use, store, and disclose in providing mortgage, car loan, and other financial services. Additional information about how we handle your personal information may be provided in application forms, terms and conditions, or other documents, which you should read carefully.
We are committed to using your personal information only for the purposes for which it was collected or as permitted by law, ensuring your confidence in the protection of your information.
Personal Information
Personal information is information or an opinion about you from which your identity is reasonably apparent. This includes:
– General Information: Name, date of birth, address, email address, phone number, account details, occupation, and transaction history.
– Finance-Related Information: Ages and number of dependants or cohabitants, length of time at your current address, employment details, proof of earnings and expenses, and Tax File Number or tax residency status.
– Car Loan-Specific Information: For Frontline Car Loans, details about the vehicle (e.g., make, model, value), intended use, and financing preferences.
– Credit-Related Information: Information bearing on credit provided to you or applied for, including credit type, terms, amount, repayment history, defaults, payment information, financial hardship arrangements, serious credit infringements, court proceedings, personal insolvency information, and publicly available information.
– Credit Eligibility Information: Credit reporting information supplied by a credit reporting body and any information we derive from it.
– Payment Information: Details required to process payments to or from you.
– Employment Application Information: Work history and referee details if you apply for a role with us.
– Online Interaction Data*: Location information, IP address, mobile device and network information, and third-party sites accessed when you visit our websites or mobile apps (see “Cookies” section below).
Why We Collect Your Personal Information
We collect and receive personal information, including credit-related information, to:
– Assess your eligibility for and manage finance products, including home loans, car loans, commercial loans, and other financial services.
– Compare and recommend loan options from our panel of over 30 lenders.
– Submit and manage loan applications through to settlement.
– Establish your identity and contact you.
– Manage our risks and comply with legal obligations, such as under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
– Provide ongoing support, such as refinancing advice or loan management.
– With your consent, offer direct marketing about our products, services, or promotions.
– Improve our services through data analytics, combining your information with other data sources (e.g., Australian Bureau of Statistics) to enhance customer insights.
– Assess applications for employment or finance broker roles and manage those relationships.
How We Collect Your Personal Information
Where reasonable and practicable, we collect personal information directly from you through:
– Application forms (online, in-person, or over the phone).
– Consultations with our brokers.
– Documents you provide (e.g., payslips, bank statements, identification).
– Interactions via our website, mobile apps, email, or other electronic means.
We may also collect information from:
– Publicly available sources, such as public registers or social media.
– Third parties, including credit reporting bodies (e.g., Equifax, Illion, Experian), finance brokers, accountants, lawyers, referees, or your current or previous employer.
– Lenders, mortgage insurers, or other financial institutions involved in your application.
Do We Disclose Your Personal Information?
We may disclose your personal information to:
– Existing or prospective lenders, funders, or intermediaries for your mortgage or car loan requirements.
– Other guarantors, borrowers, or security providers (if applicable).
– Organisations involved in managing or administering your finance, such as valuers, surveyors, lenders, mortgage insurers, trade insurers, recovery firms, debt collectors, or lawyers.
– Credit reporting bodies to assess your creditworthiness or report credit-related information.
– Agents, contractors, or service providers (e.g., IT support, statement production, mailing services) under strict confidentiality agreements.
– Businesses we collaborate with for marketing purposes, with your consent.
– Companies providing information and infrastructure systems.
– Your representatives, such as finance brokers, lawyers, guardians, or accountants, with your consent.
– Auditors, insurers, reinsurers, or claims-related providers (e.g., assessors, investigators).
– Organisations involved in our funding arrangements, such as trustees, warehouse funders, investors, or rating agencies.
– Government agencies or courts where required by law (e.g., Australian Taxation Office, under subpoena).
– Identity verification services or referees.
We take reasonable steps to ensure that recipients of your personal information have privacy protections at least equivalent to our commitments or that you have consented to the disclosure.
Overseas Disclosure
We may use cloud storage or IT servers located outside Australia to store or process your personal information, including in countries such as the USA, Canada, Malaysia, India, Ireland, the United Kingdom, and the Philippines. We ensure that overseas recipients are subject to privacy protections equivalent to the APPs. You may contact us for more details about these entities. We will not disclose your personal information overseas without your consent or unless permitted by law.
Credit-Related Information
We exchange credit-related information with credit reporting bodies (e.g., Equifax, Illion, Experian) to assess your eligibility for finance, confirm your identity, and manage your finance. This includes:
– Your identification details, loan types, amounts, repayment history, defaults, financial hardship arrangements, serious credit infringements, court proceedings, or personal insolvency information.
– Publicly available information or details of serious credit infringements if you propose to be a guarantor.
We store credit-related information in electronic form on secure servers, which may include cloud storage outside Australia, and in paper form. We ensure appropriate data handling and security arrangements for overseas disclosures. The privacy policies of the credit reporting bodies we use are available at:
– Equifax: [equifax.com.au](https://www.equifax.com.au)
– Illion: [illion.com.au](https://www.illion.com.au)
FINANCIERS
For more information on how the Financiers collect, hold, use and disclose your information, you should see their privacy policies (many of which are accessible via the websites listed in the table below), which include how you can access and correct the information that these Financiers hold about you and how you can complain about their treatment of your information. Financiers on Stratton’s lending panel include, but are not limited to, the entities listed below:
- Macquarie Leasing Pty Limited (ABN 38 002 674 982)
- Pepper Money Limited (ABN 55 094 317 665)
- Metro Finance Pty Limited (ABN 44 600 674 093)
- Volkswagen Financial Services Australia Pty Ltd (ABN 20 097 071 460)
- ANZ (ABN 11 005 357 522)
- Westpac (ABN 33 007 457 141)
- Latitude Finance (ABN 42 008 583 588)
- Bank of Queensland Limited (ABN 32 009 656 740)
- Plenti Australia RE Limited (ABN 571 666 466 35)
- Liberty Financial Pty Limited (ABN 55 077 248 983)
- Firstmac Limited (ABN 59 094 145 963)
- Leasewise Australia Pty Ltd (ABN 73 000 132 436)
- NOW Finance (ACN 158 703 612)
- Yamaha Finance (ABN 29 101 928 670)
- Capital Finance (ABN 23 069 663 136)
- Dynamoney Pty Ltd (ABN 80 613 082 698)
- Moneytech Group Limited (ABN 24 611 393 554)
- Money3 (ABN 63 117 296 143)
- Finance One (ABN 80 139 719 903)
- flexicommercial Pty Limited (ABN 17 644 644 860)
- Specialist Equipment Leasing Finance Company Pty Ltd t/as SELFCO (ACN 099 591 616)
- Resimac Asset Finance (ABN 93 098 034 041)
- Green Light Auto Group Pty Limited (ABN 39 131 507 474)
- ACN 603 303 126 Pty Ltd, trading as Angle Finance (ACN 603 303 126)
- Flexfleet Pty Ltd (ACN 081 785 711)
- Azora Asset Finance Pty Ltd (ABN 120 878 261 59)
- Rapid Loans Pty Ltd (ABN 54 103 660 546)
CREDIT RELATED INFORMATION
We exchange credit related information for the purposes of assisting you with your application for finance. This may include obtaining a credit report about you as an applicant or guarantor as an authorised Access Seeker.
This credit related information may be held by us in electronic form on our secure servers.
When we obtain credit eligibility information about you for a credit reporting body, we may also seek publicly available information and information about any serious credit infringements that you may have committed.
TRANSFER OF INFORMATION OVERSEAS
Personal information (including credit related information) may be held by us in electronic form on our secure servers and in paper form. We may use cloud storage and IT servers to store the personal information we hold about you. These storage solutions may be located outside Australia, including with trusted third-party providers such as Salesforce, based in Australia and the United States.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, understanding that those entities may not be subject to privacy laws which provide the same level of protection as Australia privacy laws
INFORMATION COLLECTED WHEN USING OUR WEBSITE OR THIRD-PARTY WEBSITES
1. Technical and usage data
When you visit our websites or use our mobile apps, we may collect information about your location or activity, including your IP address, telephone number, whether you have accessed third party sites, the date and time of visits, the pages that you viewed, information about the device used, and other user location information. We collect some of this information using cookies.
2. IP Addresses
Your internet protocol address (or ‘IP address’) is the numerical identifier for your device when you are using the internet. It may be necessary for us to collect your IP address for your interaction with some parts of our website.
3. Links to third party websites
Our website may contain links to the websites of third-party providers of goods and services (Third Party websites). If you have accessed Third Party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.
Where you access a Third-Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
4. Advertising and cookies
We use ‘cookies’ to provide you with better and more customised service and with a more effective website.
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser. We use cookies for different purposes such as:
- to allocate a unique number to your internet browsers;
- to customise our website and offers for you;
- for statistical purposes;
- to identify if you have accessed a third party provider’s website for goods and services; and
- for security purposes.
Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.
5. Web beacons
A web beacon is typically a transparent graphic image invisible to the user that is placed on a website. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel.
We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and ‘advertising/ marketing personalisation’. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing Third Party Websites.
We also partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimisation, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
6. E-consent
By providing your email address and then clicking submit on any online form, calculator, tool or query, you consent to receiving notices and other documents from us by email to the email address provided, and you understand that that if you give this consent: we may no longer send you paper copies of notices and other documents; you should regularly check your email account for documents; and you may withdraw your consent to receiving documents by email at any time. You also confirm that you have the facilities to print any notice or document that we send you by email, if required.
DIRECT MARKETING
From time to time, we may use your personal information to let you know about products and services from us and our business partners and affiliates that you might find of interest (such as by way of updates or newsletters), to run competitions or promotions and to communicate other offers or opportunities in which you may be interested. We do not sell your personal information for direct marketing purposes.
We may conduct these marketing activities via mail, email, telephone, messaging such as SMS and MMS, or any other electronic means. We may also market our products and services to you through third-party channels (such as social networking sites).
Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.
If you do not wish to receive marketing information, you may decline, at any time, by telephoning us on 1300 857 130 or by emailing loans@teamfrontline.com.au. If the direct marketing is by email you may also use the unsubscribe function included in these email communications. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity but no later than 5 working days.
UPDATING YOUR PERSONAL INFORMATION
It is important to us that the personal information we hold about you is accurate and up to date. During our relationship with you we will ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION
You may request access to any of the personal information we hold about you at any time. We will respond to you within seven days of receiving your request. We may need to properly investigate your request. We will provide you with the outcome of our investigation within 30 days. We may need to consult with finance providers or credit reporting bodies or entities as part of our investigation
To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you.
If you ask us to correct the personal information we hold about you, if appropriate, we will correct the personal information at the time of the request. Otherwise, we will provide an initial response to you within seven days of receiving your request and will provide you with details about whether we have corrected the personal information within 30 days.
If we refuse to correct personal information, we will provide you with our reasons for not correcting the information.
BUSINESS WITHOUT IDENTIFYING YOU
In most circumstances, it will be necessary for us to identify you to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information – for example, if you make general inquiries about interest rates or current promotional offers.
SECURITY OF YOUR PERSONAL INFORMATION
We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.
If we no longer need to hold your personal information, it is securely destroyed or permanently de-identified.
CONTACTING US AND PROVIDING FEEDBACK
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer on the contact details below.
(08) 6188 0131 / loans@teamfrontline.com.au