Privacy policy

Who are we?

‘We’, ‘us’ and ‘our’ refer to Digital Mortgage Solutions Pty Ltd (ACN 628 608 391), Australian Credit Licence 511406 and our related businesses, including Nano Home Loans Pty Ltd.

Our commitment to protecting your privacy

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

Any personal information we collect will only be used for the purposes we have collected it for or as allowed under law. It is important to us that you are confident that we’ll treat your information in a way which ensures its protection.

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.

Privacy Collection Statement

This policy also includes our Privacy Collection Statement for your review and acceptance before we deal with your personal information. Our credit reporting policy, which covers how we manage your personal information collected in connection with a loan application or a home loan, is also included.

The law requires us to notify you of certain things regarding the collection of your personal information.

We collect your personal information from you or from your joint borrower(s) or joint applicant(s) via our application form, website or mobile app. We may also collect information from you or your joint applicant or borrower directly. If you give us personal information about a joint borrower or joint applicant, we rely on you telling them so, and pointing them to our Privacy Policy to explain how we handle their information.

We may collect information from a third party source about you or your property to decide whether to offer you a product or service. We may also collect information from third parties and share information about you for the purposes of marketing products and services to you.

We share your personal information with credit reporting bodies (CRBs) to obtain a consumer and/or commercial credit report about you. With the introduction of Comprehensive Credit Reporting (CCR), credit reports contain both positive and negative bureau information on your credit history (see below).

We share your personal information with outsourced service providers, such as property valuers, so that they can assess your selected home loan, and other entities who help provide the loan and other associated features to you.

We share your personal information with our advisors and our payments partner Hay Ltd (Hay). Nano and Hay may share your information with any organisation providing online verification of your identity and to service providers based in the US and UK who provide risk assessment and transaction monitoring (PEPs and sanctions checking).

What is Personal Information?

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

The kinds of information we may collect include your name, address, date of birth, photo, bank account details, occupation, contact details, financial information, identity information and any other information we may need to provide you our products and services. When you use our website or mobile applications, we may collect information about your location or activity, including IP address, telephone number, email address and whether you have accessed third-party sites, the date and time of visits, the pages you viewed, information about the device used and other user location information. We collect some of this information using cookies (for more information, please see our Cookies Policy).

If you’re applying for a home loan or provide a guarantee, we may also collect the number of your dependants, the length of time you have resided at your current address, your employment details, and proof of earnings and expenses.

What is credit-related information?

There are two types of credit-related information that we talk about in our Privacy Policy below. They are:

• 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, financial hardship 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 a Nano home loan. Usually, credit-related information is exchanged between credit and finance providers and credit reporting bodies.

Why we collect your personal information

We collect personal information for the purposes of:

• assessing your application for a home loan and managing and servicing that loan;
• providing the payment functionality associated with your offset sub-account balance;
• assisting you where online applications are not completed;
• establishing your identity and verifying any information you provide to us;
• contacting you;
• managing our risks, including fraud risk;
• responding to a complaint;
• portfolio analysis;
• complying with our legal and regulatory obligations, and for audit or reporting purposes;
• referring your loan application to another lender if we are unable to provide you with a loan; and
• sending you or facilitating marketing.

If we request personal information about you and you do not provide it, we may not be able to provide you with the product or service that you request. If we’re required to comply with certain legislation to continue to provide you with products and services, then collection of certain personal information will be mandatory.

How do we collect your personal information?

We collect your personal information in a number of ways, including:

• directly from you via our application form, Nano’s website, or Nano mobile app or when you provide it to us via telephone, SMS, email or online chat;
• from joint applicants and borrowers to your home loan, for example where one applicant has provided information to us on behalf of both of you;
• from third-party data providers to verify information you provide in your application or as part of a request to change your credit contract;
• from sources that are publicly available, for example public registers or social media, or made available by third parties; and
• from third parties.

Do we disclose your personal information?

We may disclose your personal information:

• to prospective funders, lenders or any person or body in connection with new or proposed loan securitisation arrangements;
• to other organisations involved in managing, administering or servicing your home loan, offset sub-account balance and payment functionality, such as third-party service providers and credit reporting bodies;
• to Hay, our payments partner, to provide you services associated with your Nano Card and to undertake identity verification where necessary;
• to our group companies;
• to associated businesses that may want to market products to you as a customer of Nano or to third parties for the purposes of Nano marketing products and services to you;
• to other lenders or mortgage brokers that may want to offer you products or services where we cannot offer you a suitable product;
• to businesses that provide information and infrastructure systems to us;
• to our agents, contractors and external service providers we outsource certain functions to, for example, statement production, debt recovery and information technology support;
• to anybody who represents you, such as lawyers, persons holding power of attorney and accountants;
• to anyone, where you have provided us consent;
• to other guarantors or borrowers (if more than one);
• to our auditors and insurers;
• 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;
• to fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
• to external dispute resolution schemes;
• to regulatory bodies, government agencies and law enforcement bodies in any jurisdiction;
• to organisations that provide products or services used or marketed by us; or
• to your employer, former employer, referees or identity verification services.

Credit-related information

We collect, hold and exchange credit-related information to assess your application for a home loan and your ability to manage that loan. If you propose to be a guarantor, we may obtain a credit report about you.

This credit-related information may be held by us in electronic form on our secure servers or cloud storage. The cloud storage and the IT servers may be located outside Australia.

When we obtain credit-related information or credit eligibility information from a credit reporting body about you, we may also seek publicly available information, and information about any serious credit infringement 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. We advise you of these electronically, but 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 this information to confirm your identity, assess your creditworthiness, assess your application for a home loan or your capacity to be a guarantor, and manage your home loan.

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

If you fail to meet your payment obligations in relation to your home loan, if you enter into a financial hardship arrangement or you have committed a serious credit infringement, 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 ask us to correct that credit-related information, if needed. Please see the heading ‘Access and correction to your personal and credit-related information’, below.

Your credit information may 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. The credit reporting body must not use or disclose that credit information for 21 days after they have received your notification. You can contact the following credit reporting bodies for more information:

• Experian Australia Credit Services Pty Ltd – www.experian.com.au.
• Equifax Pty Ltd – www.equifax.com.au.

Direct marketing

From time to time we may use your personal information to provide you with current information about 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 6266 or by writing to us at [email protected]. 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.
You can contact us on 13 6266 or at [email protected] to update your personal information. We will generally rely on you to ensure the information we hold about you is accurate and 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 on your request. We may charge a fee for our costs of retrieving and supplying the information to you.

Where possible, we’ll respond to your request immediately, but we’ll usually respond within seven days. We may need to contact other entities to properly investigate and complete 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. If we deny you access to the personal or credit-related information we hold about you, we’ll explain why.

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 6266 or by writing to us at [email protected]. If appropriate, we will correct the personal information at the time of the request. Otherwise, we’ll provide an initial response within seven days of receiving your request. Where reasonable, and after our investigation, we’ll let you know 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’ll explain why.

Can we do business without identifying you?

In most circumstances, it will be necessary for us to identify you to successfully do business with you. However, where it is lawful and practicable to do so, we’ll offer you the opportunity of doing business with us without providing personal information, for example, if you make general enquiries about interest rates or current promotional offers.

What is sensitive information?

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

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

We’ll take a range of measures and reasonable steps to protect your personal information. It will always be stored in a secure environment in electronic form. We will also take reasonable steps to protect any personal information from misuse, loss, 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 13NANO (13 6266).

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 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 by calling 1800 931 678 or writing to [email protected], or the Privacy Commissioner which can be contacted at www.oaic.gov.au or on 1300 363 992.

Further information

If you’d like further information about the way we manage your personal or credit-related information, please contact us on 13 6266, by email to [email protected] or by mailing address at Level 3, 121 Harrington Street, Sydney, NSW, 2000

Change in our privacy and credit reporting policy

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 marketplace 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.