Privacy Policy

Who are we?

​‘We’, ‘us’ and ‘our’ refer to ORDE Financial Pty Ltd ACN 634 779 990
Australian Credit Licence 522079, ORDE Capital Management Limited ACN 636
165 378 Australian Financial Services Licence 523150 and Australian Credit
Licence 523150 and our related bodies corporate.

Our commitment to protect your privacy

We understand how important it is to protect your personal information.
This document sets out our privacy policy commitment in respect of the
personal information (including credit-related information) we hold about
you and what we do with that information.

We recognise that any personal information we collect about you will only
be used for the purposes we have collected it or as allowed under the law.
It is important to us that you are confident that any personal information
we hold about you will be treated in a way which ensures protection of your
personal information.

Our commitment in respect of personal information is to abide by the
Australian Privacy Principles (APPs) and Part IIIA of the Privacy Act, the
Privacy (Credit Reporting) Code 2014 and any other relevant law.

Personal information

When we refer to personal information we mean information from which your
identity is reasonably apparent. This information may include information
or an opinion about you. The personal information we hold about you may
also include credit-related information.

Credit-related information means:

· Credit information, which includes your identity: the type, terms and
maximum amount of credit provided to you, including when that credit was
provided and when it was repaid; repayment history information; default
information (including overdue payments); payment information; new
arrangement information; details of any serious credit infringements; court
proceedings information; personal insolvency information and publicly
available information; and;

· Credit eligibility information, which is credit reporting information
supplied to us by a credit reporting body, and any information that we
derive from it.

We use your credit-related information to assess your eligibility to be
provided with any finance. Usually, credit-related information is exchanged
between credit and finance providers and credit reporting bodies.

The kinds of personal information we may collect about you include your
name, date of birth, address, account details, occupation, and any other
information we made need to identify you. When you use our website or
mobile applications, we may collect information about your location or
activity including IP address, telephone number and whether you have
accessed third party sites, the date and time of visits, the pages that are
viewed, information about the device used and other user location
information. We collect some of this information using cookies (for more
information please see the Website Terms of Use/Policy at

www.orde.com.au/terms-of-use

If you are applying for finance or provide a guarantee we may also collect
the number and ages of your dependants and cohabitants, the length of time
at your current address, your employment details and proof of earnings and
expenses. If you apply for any insurance product through us we may collect
information about what is being insured, the beneficiaries and your health
information including medical and lifestyle information from you or your
health professionals. We will only collect health information from you with
your consent.

Why we collect your personal information

We collect personal information for the purposes of assessing your
application for finance and managing that finance, establishing your
identity, contacting you, managing our risk and to comply with our legal
obligations. We may also collect your personal information for the purposes
of direct marketing and managing our relationship with you. Improvements in
technology also enable organisations like ours to collect and use
information to get a more integrated view of our customers. From time to
time we may offer you other products and services.

How do we collect your personal information?

Where reasonable and practical we will collect your personal information
directly from you. We may collect information about you that is publicly
available, for example from public registers or social media, or made
available by third parties. We may also collect your personal information
from credit reporting bodies, mortgage and finance brokers, employers and
other people such as accountants and lawyers.

We will not ask you to supply personal information publicly over Facebook,
Twitter, or any other social media platform that we use.

Do we disclose your personal information?

We may disclose your personal information:

· to prospective funders or other intermediaries in relation to your
finance requirements;

· to other organisations that are involved in managing or administering
your finance such as third party suppliers, printing and postal services,
call centres, lenders mortgage insurers, trade insurers and credit
reporting bodies;

· to associated businesses that may want to market products to you;

· to companies that provide information and infrastructure systems to us;

· to our agents, contractors, external service providers to outsource
certain functions, for example, statement production, debt recovery and
information technology support;

· to any person or entity who represents you, including finance brokers,
lawyers, mortgage brokers, guardians, persons holding power of attorney and
accountants;

· to any person or entity, where you have provided us consent;

· other guarantors or borrowers (if more than one) or prospective borrowers
including in relation to any credit you guarantee or propose to guarantee;

· to our auditors, insurers, re-insurers and health care providers;

· to claims related providers, such as assessors and investigators who help
us with claims;

· where we are authorised to do so by law, such as under the Anti-Money
Laundering and Counter Terrorism Financing Act 2006 (Cth), government and
law enforcement agencies or regulators;

· to investors, agents or advisers, trustees, rating agencies or any entity
that has an interest in your finance or our business;

· to other financial institutions, for example to process a claim for
mistaken payment;

· organisations that provide products or services used or marketed by us;
or

· to your employer, former employer, referees or identity verification
services.

Prior to disclosing any of your personal information to another person or
organisation, we will take all reasonable steps to satisfy ourselves that:

(a) the person or organisation has a commitment to protecting your personal
information at least equal to our commitment, or

(b) you have consented to us making the disclosure.

Credit related information

We exchange credit-related information for the purposes of assessing your
application for finance and managing that finance. If you propose to be a
guarantor, one of our checks may involve obtaining a credit report about
you.

This credit-related information may be held by us in electronic form on our
secure servers and may also be held in paper form. We may use cloud storage
to store the credit-related information we hold about you. The cloud
storage and the IT servers may be located outside Australia.

When we obtain credit eligibility information from a credit reporting body
about you, we may also seek publicly available information and information
about any serious credit infringement that you may have committed.

Notifiable matters

The law requires us to advise you of ‘notifiable matters’ in relation to
how we may use your credit-related information. You may request to have
these notifiable matters (and this policy) provided to you in an
alternative form.

We exchange your credit-related information with credit reporting bodies.
We use the credit-related information that we exchange with the credit
reporting body to confirm your identity, assess your creditworthiness,
assess your application for finance or your capacity to be a guarantor and
manage your finance.

The information we can exchange includes your identification details, what
types of loans you have or have had, how much you have borrowed, whether or
not you have met your loan payment obligations and if you have committed a
serious credit infringement (such as fraud).

If you fail to meet your payment obligations in relation to any finance
that we have provided or arranged or you have committed a serious credit
infringement then we may disclose this information to a credit reporting
body.

You have the right to request access to the credit-related information that
we hold about you and make a request for us to correct that credit-related
information if needed. Please see the heading Access and correction to your
personal and credit-related information, below.

Sometimes your credit information will be used by credit reporting bodies
for the purposes of ‘pre-screening’ credit offers on the request of other
credit providers. You can contact the credit reporting body at any time to
request that your credit information is not used in this way.

You may contact the credit reporting body to advise them that you believe
that you may have been a victim of fraud. For a period of 21 days after the
credit reporting body receives your notification the credit reporting body
must not use or disclose that credit information. You can contact any of
the following credit reporting bodies for more information:

Direct marketing

From time to time we may use your personal information to provide you with
current information about finance, offers you may find of interest, changes
to our organisation, or new products or services being offered by us or any
company with whom we are associated.

If you do not wish to receive marketing information, you may at any time
decline to receive such information by telephoning us on 13 ORDE or by
writing to us at

enquiry@orde.com.au

. If the direct marketing is by email you may also use the unsubscribe
function. 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.

Updating your personal information

It is important to us that the personal information we hold about you is
accurate and up to date. During the course of our relationship with you we
may 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 ensure the information we hold
about you is accurate or complete.

Access and correction to your personal and credit information

We will provide you with access to the personal and credit-related
information we hold about you. You may request access to any of the
personal information we hold about you at any time. We may charge a fee for
our costs of retrieving and supplying the information to you.

Depending on the type of request that you make we may respond to your
request immediately, otherwise we usually respond to you within seven days
of receiving your request. We may need to contact other entities to
properly investigate your request.

There may be situations where we are not required to provide you with
access to your personal or credit-related information, for example, if the
information relates to existing or anticipated legal proceedings, if your
request is vexatious or if the information is commercially sensitive.

An explanation will be provided to you if we deny you access to the
personal or credit-related information we hold about you.

If any of the personal or credit-related information we hold about you is
incorrect, inaccurate or out of date you may request that we correct the
information by telephoning us on 13 ORDE or by writing to us at

enquiry@orde.com.au

.

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. Where reasonable, and after our
investigation, we will provide you with details about whether we have
corrected the personal or credit-related information within 30 days.

We may need to consult with other finance providers or credit reporting
bodies or entities as part of our investigation.

If we refuse to correct personal or credit-related 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 in order
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.

Sensitive information

We will only collect sensitive information about you with your consent.
Sensitive information is personal information that includes information
relating to your racial or ethnic origin, political persuasion, memberships
in trade or professional associations or trade unions, sexual preferences,
criminal record, or health.


How safe and secure is your personal information that we hold?

We will take a range of measures and reasonable steps to protect your
personal information. Your personal information will always be stored in a
secure environment. We may store your personal information in paper and
electronic form. We will also take reasonable steps to protect any personal
information from misuse, loss and unauthorised access, modification or
disclosure.

Complaints

If you are dissatisfied with how we have dealt with your personal
information, or you have a complaint about our compliance with the Privacy
Act and the Credit Reporting Code, you may contact our complaints officer
on 13 ORDE.

We will acknowledge your complaint within seven days and aim to resolve the
complaint as quickly as possible. We will provide you with a decision on
your complaint within 30 days.

If you are dissatisfied with the response of our complaints officer you may
make a complaint to our External Dispute Resolution Scheme, Australian
Financial Complaints Authority (AFCA) which can be contacted on 1800 931
678 or at or the Privacy Commissioner which can be contacted at www.oaic.gov.au or 1300 363 992.

Further information

You may request further information about the way we manage your personal
or credit-related information by contacting us.

We are constantly reviewing all of our policies and attempt to keep up to
date with market expectations. Technology is constantly changing, as is the
law and market place practices.

As a consequence we may change this policy from time to time or as the need
arises. We will post any changes to this policy on our website.

You may request this policy in an alternative form by telephoning us on 13
ORDE or by writing to us at

enquiry@orde.com.au

.

This privacy and credit reporting policy came into existence on 22 November
2019.