Campaign Agent Pty Ltd (ACN 608 962 812 ‘CampaignAgent’, ‘Our’, ‘Us’ and ‘We’), our authorised agents, our Related Companies, and third parties who provide services to us or on our behalf collect your personal information to provide and offer you our products and services, or otherwise as permitted by law. Without this information, we may not be able to provide you with our products or services. This policy sets out the reasons why CampaignAgent collects your information and importantly how we protect your privacy and the confidentiality of your personal information.

Definitions

In this Privacy Policy:

‘Personal Information’ and ‘Sensitive Information’ have the same meaning as “personal information” and “sensitive information” respectively, under section 6 of the Privacy Act 1988 (Cth).

‘Related Companies’ has the same meaning as “related bodies corporate” under section 50 of the Corporations Act 2001 (Cth).

‘You’ refers to our customers and prospective customers. It also refers to users of our web site.

Our Commitment

We will be fair and open about the way we collect information about you and what we intend to do with the information.
We recognise that your privacy is very important to you. We are committed to protecting the privacy of your Personal Information in accordance with the Privacy Act 1988 (Cth) (Privacy Act).

The Privacy Act details the Australian Privacy Principles (APPs) that set minimum standards for how government agencies and private sector organisations may collect, use, disclose, store, provide access to and correct Personal Information. We are committed to complying with the APPs.

Currency and Status of our Privacy Policy

Our current privacy policy is detailed below. It is current as of and from 22 July 2024. We suggest that you read it thoroughly. This policy may change from time to time and all changes will be posted on our website so please check it periodically. Alternatively, you can contact the Privacy Officer by sending an email to privacy@campaignagent.com.au and request a copy of our most recent policy.

Personal Information we collect

The Personal Information we collect depends on the products and services we offer you or you use or apply for. Typically, the details we collect and hold may include the following:

• contact and identification information, such as your name, address, email address, telephone number, gender and date of birth;
• financial and transaction information, including information about your assets, occupation and income, account balances, account activities, and transactions with us or third parties;
• government identifiers and related information, such as your driver’s licence, passport and visa particulars (for example, which we have collected to verify your identity or eligibility at the time you request a product or service);
• if you are a customer (prospective or existing), information about your preferences and requirements in relation to the type of product or service you ask us to provide or that we do provide and such other information as may be required in order to provide your products and services to you;
• if you are a supplier and/or supplier personnel (prospective or existing), information about your business skills, audio visual data (if you attend our premises) and such other information as we may require in order to obtain your products and services from you;
• sensitive information, which includes information about racial, religious or ethnic origin (we may ask you what your preferred language to communicate with is) and biometric information (such as your face or your signature for the purpose of verifying your identity and completing a credit check);
• information about your personal circumstances (such as information about significant life events or details of illness, injury or addiction) so we may support you during financial difficulties;
• statistical information regarding views, navigation paths, purchasing behaviour, your location when accessing/using our online services, your access and use of our online services;
• your device’s internet protocol address and information that helps us learn about your browser and operating system;
• information about your employment history; and
• any such other personal information which you choose to provide us.

Unless it is impracticable, you have the option of interacting with us anonymously or by using a pseudonym. For example, you may visit and browse our website and use some of our online facilities without having to reveal any Personal Information.

How we collect your Personal Information

We collect your personal information in various ways, including via telephone, our website, hard copy forms or email and from real estate agencies that you are a customer of.

Whenever you deal with us we will collect this information directly from you unless it is unreasonable or impracticable for us to do so. In some instances, we may collect your information from someone else. This may include our authorised representatives, our distributors or referrers, agents or related entities, anyone you have authorised to deal with us on your behalf, and/or our legal or other advisers (including credit-reporting bodies, to derive assessments, evaluations, scores, ratings, and summaries relating to your creditworthiness that we use in our decision-making processes).

If you provide Personal Information to us about another person, we rely on you to have made or make them aware that you will, or may, provide their information to us and the types of third parties we may provide it to, the relevant purposes we and any of the third parties will use it for and how they can access it. If you have not done, or will not do, so, you must tell us before you provide the relevant Personal Information.

From time to time we may request Personal Information from you through competitions or surveys. Participation in these competitions or surveys is completely voluntary and you, therefore, have the choice of whether or not you disclose the Personal Information requested.

Why we collect and how we use Personal Information

We collect Personal Information to provide or offer you the various products and services we administer, or otherwise as permitted by law. Such purposes include to identify you, assessing and processing your application, executing your instructions, responding to your enquiries, providing you with assistance you request of us, to comply with legislative or regulatory requirements (such as to confirm your identity for the purposes of anti-money laundering and counter-terrorism laws to assess your suitability for our products), maintaining and administering our products and services; processing your survey or questionnaire responses; market research and the collection of general statistical information using common internet technologies such as cookies; (unless you tell us not to) providing you with marketing information regarding other products and services (of ours or a third party); quality assurance and training purposes; performing administrative operations (including accounting and risk management) and any other purpose identified at the time of collecting your information.

If you do not consent to us collecting and using all or some of the Personal Information we request, we may not be able to provide you with our products or services such as processing and approving your application for our products or services. It may also prevent us from the provision of information regarding our products or services or those of any third party.

We use Personal Information we may collect through competitions to determine prize winners, award prizes and notify winners. We use Personal Information we may collect through surveys or questionnaires to assess your satisfaction with our products and services and to determine how we may better service your needs. We, and our Related Companies, may also use Personal Information you provide for research and statistical analysis.

Cookies and the collection of information through our website

We may use a cookie that collects anonymous traffic data. A cookie is a message given to a web browser by a web server and which is then stored in a text file. Each time the browser requests a page from the server this message is sent back which enables the user’s computer address (IP address) to be identified.

We may use the information provided by cookies and IP addresses to analyse trends, administer the site, or for research and marketing purposes to help us better serve our clients. No information which personally identifies you will be collected through the cookies. You can set your browser to notify you before you receive a cookie so you have the chance to accept it and can set your browser to turn off cookies. No information which personally identifies you will be collected as part of these cookies.

Direct Marketing

CampaignAgent is committed to providing transparency and control over your Personal Information and how it is used for marketing purposes. We respect your privacy and are committed to ensuring that your Personal Information is handled in accordance with the Privacy Act and the Spam Act 2003 (Cth).

On occasion, we, and our Related Companies, or other third parties with whom we have a relationship, may use your Personal Information to offer you products and services which we believe may be of interest to you.

1. Opt-in to marketing communications
   By opting in to CampaignAgent’s marketing communications, you consent to receive direct marketing messages including electronic direct mails (eDMs), SMS, and targeted online advertising promoting our goods and services. You may opt in by subscribing through our event campaign landing pages, payment gateway portal, during an application process, or by explicitly requesting to receive our marketing content.

2. Opt-out (Unsubscribe) from marketing communications
   If you wish to unsubscribe from our marketing communications, you can do so at any time using one of the following methods:

   1. Unsubscribe link: click the unsubscribe link located at the bottom of any marketing email you receive from us.

   2. Email: send an email to support@campaignagent.com.au requesting to unsubscribe.

   3. Phone: contact our support team at 1300 882 622 and request to unsubscribe from our marketing communications.

Upon receipt of your unsubscribe request, we will process it promptly and you will no longer receive marketing communications from us.

Sharing and Disclosing your Personal Information

We may share your Personal Information with our Related Companies, other third parties and unrelated parties from time to time, including to:

• our employees, related bodies corporate, contractors or external service providers (including debt collection agencies, real estate agents and mortgage loan brokers) for the operation of our business, fulfilling requests by you, and otherwise provide products and services to you;
• information service providers including credit reporting bodies (CRBs), and parties that assist in verifying your identify and providers of fraud detection services. This may include making an electronic request to, and receiving a response from, government agencies through the Document Verification Service (DVS) to determine whether your information matches details in records held by those agencies. Use of the DVS may involve the use of third party systems and services;
• our existing or potential agents, business partners or joint venture entities or partners;
• our sponsors, or promoters of any competition that we conduct or promote via our services;
• other credit providers;
• any person we consider necessary to execute your instructions;
• any person who is named in an application including, for example, guarantors or co-applicants;
• persons in connection with a securitisation arrangement or wholesale funding of your loan;
• any person who is considering whether to acquire or who has acquired our business or part thereof, or the rights or obligations under the contract that has been entered into with you;
• specific third parties authorised by you to receive information held by us;
• law enforcement, regulatory and government bodies as permitted or required by law, (including the police, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary); or
• as required or permitted by any law (including the Privacy Act), regulations or codes binding on us.

Details of who they are may change from time to time. You can contact us for details. In some cases we may not be able to take reasonable steps to ensure they do not breach the Privacy Act and they may not be subject to the same level of protection or obligations that are offered by the Privacy Act. By proceeding to acquire our services and products you agree that you cannot seek redress under the Privacy Act or against us (to the extent permitted by law) and may not be able to seek redress overseas.

Related and unrelated third parties to whom your Personal Information is disclosed are required to keep the information confidential and only use it for the same purposes we are permitted to use it.

We do not disclose your Personal Information to recipients located overseas.

Quality of your Personal Information

We aim to ensure that your Personal Information is accurate, complete and up to date.

During the course of your relationship with us we will ask you to inform us of any changes to your Personal Information. You should, however, contact us at any time to update your Personal Information or advise us that the information we have is not accurate or complete.

Security of your Personal Information

We are committed to keeping your Personal Information secure and will use all reasonable precautions to protect it from loss, misuse or interference and unauthorised access, modification or disclosure, including:

• securing our external and internal premises;
• maintaining computer and network security such as user identifiers and passwords to control access to computer systems;
• restricting access to your Personal Information to employees or those who perform services on our behalf who are authorised to handle your Personal Information and on a ‘needs to know’ basis;
• entering into confidentiality agreements with relevant employees and third parties;
• appropriate training of staff;
• retaining your Personal Information for no longer than it is reasonably required to provide any products and services to you, unless we are required by law to retain it for longer; and
• taking reasonable steps to destroy or de-identify Personal Information that we no longer require or which was unsolicited and we identify that we would not have otherwise collected it from you.

Access to your Personal Information

You may generally access the information we hold about you. This right is subject to the exceptions detailed in the Australian Privacy Principles. For example, we may refuse access where the:

• information may have an unreasonable impact on the privacy of others;
• request is frivolous or vexatious;
• information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings; or
• information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.

If we refuse access to give you access in the manner requested by you we will let you know why in writing.

Where providing access would reveal evaluative information in connection with a commercially sensitive decision-making process, we will provide an explanation for the decision rather than direct access to the information.

In most cases, you may access your Personal Information at no cost to you by contacting our Privacy Officer by sending an email to privacy@campaignagent.com.au. For access to complex information or more detailed requests for access to your Personal Information, for example, access to information that is archived, we may require you to place your request in writing and charge you a fee for our reasonable costs of retrieving and supplying the information to you.

In all cases you will be asked to verify who you are before your Personal Information is provided. All requests for Personal Information will be handled in a reasonable period of time.

Correction of your Personal Information

We seek to ensure that the personal information that we collect, use and disclose is accurate, up-to-date and complete and additionally, in the case of use and disclosure, relevant. Where we believe that the personal information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information.

You can contact us with corrections or edits to your personal information (including financial or credit information) by using the contact details below under the heading “How to contact us”.

We’ll try to respond to your request within 30 days. If we can’t, we’ll let you know why it’s taking longer.

If we don’t think the information needs correcting, we’ll write to let you know why. You can ask us to make a note with the information that says you believe it is inaccurate, incomplete, misleading or out of date.

How to contact us

If you have any questions, suggestions or complaints about our privacy practices or this privacy policy, please contact the Privacy Officer by sending an email to privacy@campaignagent.com.au. We will respond to your question, suggestion or complaint as soon as possible.

Depending on the nature of your enquiry we may ask you to put your request in writing. To contact the Privacy Officer, you can send an email to privacy@campaignagent.com.au or write to:

Campaign Agent Pty Ltd
511 Church Street
Richmond VIC 3121
Australia

Following a complaint, our Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. At all times, privacy complaints:

• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or impact on the commercial arrangements between you and us.

If you are not satisfied with our response to your enquiry or complaint you can contact the Privacy Officer and request that it be reviewed by a senior staff member who will endeavour to resolve your dispute within 30 days. If you are still not satisfied, you may make a complaint to the Office of the Australian Information Commissioner if your complaint is about your privacy or how we handled your credit-related information, or lodge a dispute through the Australian Financial Complaints Authority (AFCA), our external dispute resolution provider. AFCA provides consumers and small businesses with fair, free and independent dispute resolution for financial complaints.

Office of the Australian Information Commissioner
Visit: oaic.gov.au
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Mail: GPO Box 5288, Sydney NSW 2001

Australian Financial Complaints Authority
Visit: afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678 (free call)
Mail: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001