Privacy policy

Respecting your Privacy and the law.

The privacy of your personal information has always been important to us at Simpology. We are committed to respecting your right to privacy and protecting your personal information. Our Privacy Policy governs how we collect, handle, use and disclose your personal information. It also deals with how you can access the personal information we hold about you, ask us to correct it, or make a privacy related complaint. We are bound by the National Privacy Principles in the Privacy Act 1988 (Commonwealth), as well as other applicable laws and codes affecting your personal information. Our staff are trained to respect your privacy in accordance with our standards, policies and procedures.


What information do we collect and how do we use it?

When we refer to personal information we mean information from which your identity is reasonably apparent.

The kinds of personal information we may collect about you include your name, date of birth, address, email address, contact details, account details, occupation, and any other information we may need to identify you.


We will collect personal information from you when you become a registered user of our hosted software service for residential mortgage applications. This may include a broad range of information from your name, address and contact details, to other information about your accreditations and relationships within the mortgage industry. When we request your personal information, we will identify which information is necessary and which information may be provided at your option. We will use your personal information:

  • To conduct our business;
  • To manage our business relationships with you and with others, including our Lending and Aggregator partners;
  • To complete a transaction on your behalf, e.g. the collection and submission of customer mortgage applications to Lender partners;
  • To provide you with information about our products and services;
  • For our internal administrative, marketing, planning, product
 

The personal information we collect and hold about you may include credit information. Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services that we rely on. The types of organisations to which we are likely to disclose information about you include mortgage intermediaries, insurance partners, lenders, valuers, aggregators, lenders mortgage insurers, surveyors, accountants, credit reporting bodies, and lawyers.


From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications. We always give you the option of electing not to receive these communications in the future. You can unsubscribe by notifying us and we will no longer send this information to you.


Google Services Integrations

Under some circumstances, Simpology may disclose limited amounts of your personal information as part of our use of Google’s APIs. For example, we may share address information as part of our use of Google’s Maps API, so that we can performs address verification and display personalised mapping information. Similarly, Simpology may disclose your email address or username as part of our use of Google Auth API, so that you can login to our services using your Google account. At all times, Simpology’s use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. More information is available here: https://developers.google.com/terms/api-services-user-data-policy


Do we disclose your personal information?

We may disclose your personal information:

  • To prospective funders and 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 companies that provide information and infrastructure systems to us;
  • To your related Aggregator groups;
  • To anyone, where you have provided us consent;
  • Where we are required to do so by law, such as under the Anti-Money or Laundering and Counter Terrorism Financing Act 2006 (Cth) or in accordance with a subpoena or summons issued by a court.


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

  1. The person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
  2. You have consented to us making the disclosure.

We use cloud storage to store personal information that we hold. The cloud storage, web servers and associated infrastructure are all located within Australia. We do not sell, trade or rent client lists or personal information to any third party.


How do we hold and protect your information?

We strive to maintain the relevance, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

We hold the information we collect from you on our secure database. Our software products are hosted by secure third party service providers, who do not have direct access to the data. We only use storage providers located in Australia who are also regulated by the Privacy Act.


Where appropriate, data is encrypted throughout our software products and services. If applicable our software is deployed with a number of enterprise encryption standards including SSL/TLS encryption, securing web traffic between the workstation and our servers.

We take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or exposure. All Simpology staff are required by the terms of their employment to maintain the confidentiality of customer information. Access to your information is restricted to those employees whose job requires that information. Access to our premises and computer systems is restricted through locks, password protection, internet firewalls and routers. We will take reasonable steps to destroy or de-identify your personal information when your personal information is no longer required for our business functions.


Updating your personal information

It is important to us that the personal information we hold about you in 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 and complete.


Access to your personal and credit information

We will provide you with access to the personal and credit information we hold about you. You may request access to any of the personal information we hold about you at any time. We aim to respond within 30 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 information, for example, if the information relates to existing or anticipating 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.


Using government identifiers

When we collect government identifiers, such as your tax file number, we do not use or disclose this information other than as required by law. We will never use a government identifier to identify you.


What happens if you want to complain?

If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy and would like to make a complaint, please contact out Privacy Officer by email at privacy@simpology.com.au. Your complaint will be considered through our internal complaints resolution process and we will try to respond with a decision within 30 days of you making the complaint.


Your consent

By asking us to assist with your credit or business needs, you consent to the collection and use of the information you have provided to us for the purposes described above.


General information about privacy may be found via http://www.privacy.gov.au and http://www.oaic.gov.au.

We may change this Privacy Policy from time to time and all personal information held by us will be governed by the most recent version of our Privacy Policy. Any updated version of this policy will be posted on the Simpology site www.simpology.com.au