Circle Finance Pty Ltd ACN 624 683 245 (“Circle Finance”, “we”, “us”) is a Credit Representative (507534) of BLSSA Pty Ltd ACN 117 651 760, Australian Credit Licence 391237. We respect your privacy and handle your personal information in line with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and, where it applies, the credit reporting provisions in Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code.
This policy explains what we collect, why we collect it, who we share it with and how you can access, correct or complain about it.
What information we collect
To help you find and apply for finance, we need to understand your circumstances. Depending on the service, we may collect:
- Identity and contact details: name, date of birth, address, phone number, email and identification documents such as a driver licence or passport.
- Financial information: income, employment, assets, liabilities, living expenses, bank statements, tax returns and business financial statements.
- Credit information: your credit history, credit reports and credit scores, repayment history, defaults and existing credit accounts.
- Property and asset details: information about the property, vehicle or equipment you want to buy or refinance.
- Other information you choose to share: for example details of dependants, residency status or circumstances that affect your ability to repay.
We may also collect sensitive information, such as health information, where it’s relevant to your application (for example if you’re applying for hardship assistance). We only collect sensitive information with your consent.
If you don’t provide the information we ask for, we may not be able to help you, or a lender may not be able to assess your application.
Why we collect it
We collect, hold and use your information to:
- understand your needs and objectives and assess which loans may suit you
- meet our obligations under the National Consumer Credit Protection Act 2009, including our responsible lending and best interests obligations
- prepare and submit applications to lenders on your behalf and manage your loan through to settlement
- verify your identity, including under anti-money laundering and counter-terrorism financing laws
- review your loan over time and contact you about your finance
- handle enquiries and complaints, and meet our legal, regulatory and record-keeping obligations.
We may send you updates or information about our services. You can opt out of marketing at any time by using the unsubscribe link or contacting us.
How we collect it
We collect most information directly from you, for example through our website enquiry forms, by phone, by email, in meetings and through secure document upload tools.
With your consent, we may also collect information from third parties, including lenders, credit reporting bodies, your employer or accountant, valuers, other professional advisers you nominate, and identity verification services. We don’t obtain credit reports ourselves. When you apply, the lender obtains your credit report from a credit reporting body such as Equifax, Experian or illion.
Who we disclose it to
We only disclose your information for the purposes described in this policy, or as otherwise permitted by law. This may include:
- lenders and credit providers on our panel to whom you’ve asked us to submit an application
- our licensee BLSSA Pty Ltd and its aggregator, Plan Australia, which provides our systems and oversees our compliance
- credit reporting bodies, valuers, lenders mortgage insurers and identity verification providers
- service providers who help us run our business, such as IT, cloud storage, CRM and document management providers
- professional advisers you’ve authorised, such as your accountant, solicitor or conveyancer
- professionals we refer you to, such as financial advisers or conveyancers, only where you’ve agreed
- regulators, courts and government agencies where we’re required or authorised by law, and the Australian Financial Complaints Authority (AFCA) if you lodge a complaint.
Overseas disclosure
Some of our back-office administration is carried out by support staff in the Philippines, engaged through an Australian-based talent sourcing business. These staff may access your personal information to help us prepare and manage your application. We take reasonable steps to make sure they handle your information in line with the Australian Privacy Principles, including confidentiality obligations and access only to the systems they need.
Google Analytics data may also be stored outside Australia, as explained below. Otherwise, we don’t disclose your personal information to recipients overseas.
Your information on our website
Our website collects information you submit through enquiry and contact forms. We also use cookies:
- Essential cookies help the site work and remember your cookie choice.
- Analytics cookies (Google Analytics 4) are only used if you accept them through our cookie banner. They help us understand how the site is used, such as which pages are visited. We don’t send your name, email, phone number or other personal details to Google Analytics.
You can change your choice at any time using the “Cookie settings” link in the website footer. See our Cookie notice for more detail.
How we keep it secure
We take reasonable steps to protect your information from misuse, interference, loss and unauthorised access, change or disclosure. These steps include secure, access-controlled systems, encrypted document handling, staff training and restricting access to people who need it.
We keep records for as long as we need them for our services and to meet our legal obligations, which for credit-related records is generally at least seven years. When information is no longer needed, we securely destroy or de-identify it.
If a data breach is likely to cause serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.
Access and correction
You can ask to access the personal information we hold about you, or ask us to correct it if it’s inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details below. We’ll respond within a reasonable time, usually within 30 days. We don’t charge for making a request, though in limited cases we may charge a reasonable fee for providing access. If we refuse a request, we’ll explain why in writing and tell you how to complain.
If your request relates to credit information held by a lender or a credit reporting body, we can help you contact them.
Complaints
If you have a concern about how we’ve handled your information, please contact us first so we can try to fix it. We’ll acknowledge your complaint promptly and aim to resolve it within 30 days. Our Complaints page explains the process.
If you’re not satisfied with our response, you can contact:
- Office of the Australian Information Commissioner (OAIC): oaic.gov.au, phone 1300 363 992, GPO Box 5288, Sydney NSW 2001.
- Australian Financial Complaints Authority (AFCA), for privacy complaints connected to credit assistance: afca.org.au, phone 1800 931 678.
How to contact us
Privacy Officer, Circle Finance Pty Ltd Phone: 0421 066 065 Email: info@circlefinance.com.au
Collection notice for enquiries
When you send us an enquiry through our website, by phone or by email, we collect your name, contact details and the information you choose to share about your finance needs. We use it to respond to your enquiry and, if you go ahead, to provide credit assistance. We won’t share it with a lender or anyone else without your agreement, except where required by law. If you don’t provide your contact details, we won’t be able to reply. You can read how we handle, store and secure your information, and how to access, correct or complain about it, in the sections above.
Changes to this policy
We may update this policy from time to time. The current version will always be on our website, with the date it was last updated.