Privacy Policy

At The Brixwell Group we take your privacy and personal information seriously. Our Privacy Policy is designed to provide you with general information about how we collect, store, use and disclose your personal information. We will collect, use and disclose your personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Act) and this Privacy Policy.

This Privacy Policy applies to The Brixwell Group Pty Limited (ABN 24 6315 0660), Tailored Finance T/A Home Equities (90 604 762 370).

If you require further information concerning privacy and the ways we handle your personal information, please contact us using the contact details set out towards the end of this policy.

1. What information do we collect and hold?

We may ask you for a range of personal information because of the nature of the products and services we provide as well as government regulations and taxation laws. The type of personal information that we collect may include (but is not limited to) name, gender, marital status, mailing address, telephone and fax numbers, email address, date of birth, income, assets and liabilities, account balances, tax and financial statements, tax file number, account details, employment details, financial information, credit history, transaction history and whether a client is an Australian citizen.

Sometimes we need to collect sensitive information about you. The type of information may include (but is not limited to) name, marital status, date of birth, relationship to you, occupation and financial dependency. Unless required by law, we will only collect sensitive information with your consent.

We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth anti-money laundering law.

We may also be required to collect information relating to your tax residency status to comply with information sharing agreements that the Australian Government has entered into with other countries, such as our obligations under the Foreign Account Tax Compliance Act (FATCA) in the U.S.

If you provide personal information to use about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Policy.

2. How do we collect your personal information?

We normally obtain personal information directly from our clients completing or reviewing “fact find” forms, calls, emails and making and maintaining records of information provided in the course of providing our clients with products or services. We may also collect personal information from you in the course of your use of our website if you input any personal information. In addition, we also access cookies on your computer, which enables us to tell when you use the website and also to help customise your website experience (see Internet Privacy below).

Occasionally we may also ask for additional information (for example, through market research, surveys or special offers) to enable us to improve our service or consider the wider needs of our clients or potential clients. When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

There may be occasions when we need to source personal information about you from a third party. In some cases, we may be provided with your personal information from other sources, such as accountants, mortgage brokers, agents or by family members or friends. We will take reasonable steps to let you know that we have your personal information unless it is obvious from the circumstances that you know or would expect us to have the information. Reasonable steps may include asking the person who gave us your information to let you know that we have that information.

You may also choose not to provide certain personal information. However, if you choose not to provide the information requested for the purposes of fulfilling your request for a specific product or service, we may not be able to provide you with the requested product or service, or the product or service which we do provide might not fully meet your needs.

How do we take care of your personal information?

We take appropriate steps to protect the personal information we hold about you from interference, misuse, loss, unauthorised access, modification or disclosure. Specifically, our security measures include:

  • educating our staff about their obligations with regard to your personal information and taking appropriate disciplinary action where there is a breach
  • confidentiality requirements of our employees
  • only giving access to personal information to a person who is verified to be able to receive that information
  • electronic security systems, such as firewalls and data encryption on our websites
  • appropriate security access to our office premises
  • providing secure storage for physical records
  • the use of passwords to access database information
  • the use of document disposal services for written information.

Our website uses a Secure Sockets Layer (SSL) protocol that was developed to protect confidential information such as financial data from interception and hacking. We cannot be held responsible for lapses in security caused by third-party access to information as a result of your failure to keep your personal information private. We reserve the right to gather more extensive information about any attempted access to our website that raises security issues and, if appropriate, make disclosures to the relevant authorities.

What happens when we no longer need your information?

Subject to relevant laws, where we hold personal information about you and that information is no longer needed for any purpose, we will take reasonable steps to destroy or permanently de-identify the relevant information. Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we handle other information we seek from you. If not, we will take reasonable steps to destroy or permanently de-identify the relevant information.

3. How we use your personal information

The purpose of collecting personal information is to provide you with the products and services you’ve asked for. The types of products and services provided by us include (but are not limited to) property investment and lending-related services.

We may also use and disclose your personal information:

  • to give you information about a product or service and/or consider whether you are eligible for a product or service
  • to process your application for a product or service and/or administer the product or service we provide you
  • to allow us to run our business and perform administrative and operational tasks
  • to identify you and prevent or investigate any fraud or crime, or any suspected fraud or crime
  • as required by law and regulation or codes binding us, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006
  • for any purpose for which you have provided express (verbal or written) or implied consent.

To make sure we can meet your specific needs, and for the purposes described above, we sometimes need to share your personal information with others including:

  • those involved in providing, managing or administering your product or service
  • external third party service providers who help us operate our business and who have been contracted to provide The Brixwell Group with administrative, banking, financial, insurance, research, tax, legal or other services, including, without limitation
  • those who assist us in providing products and services to you and in managing your personal information.
  • government or regulatory bodies (including ASIC and the Australian Tax Office) as required or authorised by law
  • any other individuals, bodies or agencies that you would reasonably expect, or you have been told, that information of that kind is usually passed to.

Our marketing activities

We may use information we have obtained about you to directly market our insights, or other products or services that may be of interest to you. If you no longer wish to receive direct marketing offers from us, you can unsubscribe from particular marketing material electronically or by contacting us directly. We will process your request as soon as practicable.

We may also share anonymised or aggregated information with marketing or technology related service providers to assist us to communicate with you and similar customer audiences.

If you’d prefer that we didn’t use your information for any of the marketing activities listed above, please let us know by emailing or writing to us.

Disclosure of information overseas

We are unlikely to disclose personal information to overseas recipients. In some circumstances, we may need to obtain your consent before this occurs.

4. Access to and correction of personal information

We aim to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. This way we can provide you with a better service. If you believe your personal information is not accurate, complete or up to date, please contact us. We can generally update your client information over the telephone or via email. We may also take steps to update personal information, for example, an address, by collecting personal information from publicly available sources, for example, telephone directories or electoral rolls.

You may request access to your personal information; however, access is subject to some exceptions allowed by law. Factors affecting a right to access include:

  • access would pose a serious threat to the life or health of any individual
  • access would have an unreasonable impact on the privacy of others
  • a frivolous request
  • the information relates to a commercially sensitive decision-making process
  • access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you
  • legal dispute resolution proceedings where a third party has given us health information about you in confidence
  • denying access is required or authorised by or under law.

Requests for access to limited amounts of personal information, such as checking to see what address or telephone number we have recorded, can generally be handled over the telephone. Requests for access to more substantial amounts of personal information, such as details of what is recorded in your file should be made by contacting The Brixwell Group at the contact address below. A reasonable fee may be charged to recover the cost of retrieving the information and providing it to you.

5. Internet privacy

With the help of our service partners, we may collect information from you when you use any of our online services (such as our website and other online communications).

We may collect information through the use of cookies and other tracking technologies. Cookies generally do not identify you, but rather allow us to track use of our online services so that we can understand user habits. We do this so that we can improve your experience and communicate effectively with you and similar customer audiences. In some instances, you may receive cookies which collect personal information. You can often choose to accept cookies which collects personal information in order to enhance your online experience (e.g. where you request for your browser to remember your username when logging into our website). If you prefer not to receive cookies, you can configure your browser to reject them or to notify you when they are being used.

You have control over any personal information we collect from you through online forms, “contact us” messages, including chat transcripts, emails to us or email newsletter subscription information, and any information collected will be used:

  • for the purposes for which the information was requested and other related purposes
  • when required or authorised by or under law to disclose the information or with your consent.

You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.

6. Other important items

Interacting anonymously

If you have general enquiry type questions, you can choose to submit these anonymously or use a pseudonym. However, we may not always be able to interact with you this way because we are governed by strict regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:

  • it is impracticable
  • we are required or authorised by or under law, such as the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or a court/tribunal order to deal with you personally.

TFNs and other government identifiers

We will not use your tax file number (TFN), pension number or any other government agency identifier as your file, policy or application number. We only use and disclose these numbers for the purposes required by law, such as disclosing your TFN to the Australian Taxation Office. You may use a government identifier, for example, a pension number or Medicare number, to prove your identity when you deal with us.

7. Complaints

If you have a complaint about the handling, use or disclosure of your personal information, write to The Brixwell Group at the contact address below. We will investigate your complaint and advise you of the outcome as soon as possible. If the matter is not resolved to your satisfaction, you can then refer your complaint to the Office of the Australian Information Commissioner, who can be contacted at:

Office of the Australian Information Commissioner
Level 3, 175 Pitt Street
Sydney NSW 2000
Website: oaic.gov.au/privacy

8. Company Contact Details

If you have any questions or would like further information on these privacy and information handling practices, please use the following contact details:

The Brixwell Group
Suite 3
655A Darling Street
Rozelle NSW 2039

or email The Brixwell Group at: info@brixwell.com.au

Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy.