Privacy Policy

1. Who we are

In this policy, "we", "us" and "our" refer to Demir Loans Pty Ltd (ABN 49 698 798 088), trading as demir.loans. We are a credit representative (Credit Representative Number 580174) of LMG Broker Services Pty Ltd ACN 632 405 504, Australian Credit Licence 517192.

This privacy policy relates to our management of personal information about borrowers and consumers, including personal information collected in connection with a credit application or a credit facility.

Because your loan is arranged under LMG's licence, LMG's own privacy policy also applies to information we share with them. You can read it at lmg.broker/privacy-policy.

2. Our commitment to protecting your privacy

We understand how important it is to protect your personal information. This document sets out how we collect and manage the personal information we hold about you, and what we do with it.

It matters to us that you are confident any personal information we hold about you is treated in a way that protects it in accordance with the law. Our commitment is to abide by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth), and any other applicable law.

3. What is personal information?

"Personal information" has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. That may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, it is personal information.

4. How we collect your personal information

If you deal with us directly, we generally collect personal information straight from you: in person, on the phone, or electronically. That includes your interaction with this website, our online enquiry form and our social media channels.

We may also collect your personal information in other ways, including:

• from your joint applicants, co-applicants, guarantors or proposed guarantors;
• from the loan applicant, if you are the guarantor or proposed guarantor;
• from your employer, real estate agent or other referees;
• from third parties such as social media platforms, marketing websites, related companies, credit reporting bodies, lenders, law enforcement agencies, other government entities and identity verification service providers;
• from your representatives, for example your solicitor, accountant, conveyancer, builder or agent;
• from a referral partner, such as a migration agent or real estate professional, where they have introduced you to us; and
• when we are legally required to do so, for example in the provision of specific credit services.

We may collect credit reporting information and credit eligibility information about you from credit reporting bodies and credit providers respectively, if you expressly authorise us to do so in writing as part of us providing you with credit assistance services.

5. What personal information we collect and hold

We may collect the following types of personal information:

• your name, date of birth, qualifications and any other information and documents used to verify your identity, including visa and residency status where that is relevant to lender policy;
• your contact details, such as physical address, email address and telephone number;
• your credit information and financial information, including your tax file number, bank account, superannuation or insurance policy information, credit reports from credit reporting bodies, income and expenses, assets and liabilities, and credit and loan repayment history including any defaults;
• other information you submit as part of a finance application, such as the age and number of your dependants and cohabitants, length of time at your current address, your employment details, and proof of earnings and expenses;
• information about loans and finance products that relate to you, including transactional information, audits, investigations, complaints or enquiries relating to those products;
• additional information you provide to us, whether directly through this website or indirectly through your use of it; and
• information you provide to us through phone calls, meetings or customer surveys.

Some of the personal information we collect about you may be sensitive information, such as information relating to your memberships in trade or professional associations or trade unions, your criminal record, and your health information. We do not ask you to disclose sensitive information through this website, but if you choose to provide it, it will also be captured and stored.

6. Why we collect your personal information

We collect, hold, use and disclose your personal information for a number of purposes:

• carrying on our business and providing our products and services, including credit assistance to you;
• managing our relationship with you and communicating with you;
• giving you information about loan products or related services;
• considering whether you are eligible for a loan product or any related service you have requested;
• assisting you to prepare an application for a loan product;
• conducting business processing and administrative functions;
• performing our obligations to third parties involved in your loan, such as lenders and financiers, to assist them in assessing your application or managing their relationship with you;
• referring you to providers of insurance and other services, such as moving utility connections;
• managing our risks, including fraud investigation and prevention, and meeting our legal and regulatory obligations;
• where permitted by law, direct marketing and offering you other products and services; and
• complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

If you do not provide us with your personal information, or do not allow us to collect it, some or all of the following may happen:

• we may not be able to provide our products and services to you, either to the same standard or at all;
• we may not be able to perform our obligations to lenders or financiers, which in turn may mean your application for credit cannot be processed;
• we may not be able to give you information about products and services you may want, including special promotions; and
• we may be unable to tailor the content of this website to your preferences.

7. Who we disclose your personal information to

We may disclose your personal information:

• to the mortgage aggregator through whom we submit loan applications to lenders on the aggregator's panel;
• to the Australian Credit Licence holder that authorises us to engage in credit activities;
• to industry bodies, valuers, your employers, referees, identity verification services or credit reporting bodies;
• to prospective or actual lenders, mortgage insurers or other intermediaries in relation to your finance requirements;
• to service providers, agents, contractors and advisers that assist us to conduct our business, including our document collection platform (FileInvite), our cloud storage provider (Google), and offshore administrative support staff;
• to associated businesses that may want to market products to you;
• to companies that host our ICT infrastructure, or provide cloud services we use to hold or process your personal information;
• to anybody who represents you, such as your finance broker, real estate agent, conveyancer, lawyer or accountant;
• to your guarantors or prospective guarantors;
• to auditors, law enforcement agencies and regulators;
• to anyone where you have given us your consent;
• where we are required to do so by law, such as under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth); or
• to investors, agents or advisers, or any entity that has an interest in our business.

Where a referral partner introduced you to us, we will confirm with you what, if anything, we may share back with them. We do not sell your personal information.

8. Do we disclose your personal information overseas?

We may disclose personal information to our related bodies corporate, and to third party suppliers and service providers located overseas, for some of the purposes listed above. We take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to it.

The countries where your personal information may be stored or accessed are:

• the Philippines, where we use offshore administrative support to help process files;
• New Zealand, where FileInvite, the platform we use to collect your documents, is based; and
• the United States of America, where the cloud storage we use to hold your documents is operated, and where FileInvite also maintains an office.

Documents you send us are collected through FileInvite and stored in Google Drive. Both are operated by third parties on cloud infrastructure that may sit outside Australia. Information held electronically or on a network can be accessed remotely, and it is not always practicable to know precisely which country your information is held in or accessed from at any given moment.

9. Automated decision making

We may use computer systems to support us in providing our services to you, based on personal information collected from you or obtained from other sources on your behalf.

These systems use your personal information to evaluate your circumstances, to filter and better identify products that may be suitable or available to you, and to support decisions about which products to recommend or make available to you based on your needs and the eligibility criteria of different products. We, and not the system, make the decision about which products are recommended or made available to you.

10. Direct marketing

From time to time we may use your personal information to give you current information about finance, offers you may find useful, changes to our business, or new products or services offered by us or a company we are associated with.

We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that use or disclosure.

If you do not wish to receive marketing information from us, you can opt out at any time by emailing ugur@demir.loans or calling 0495 000 228. If the marketing came by email you can also use the unsubscribe link in the message. We will not charge you for acting on your request, and we will take all reasonable steps to meet it at the earliest opportunity. Opting out never affects your loan.

11. Keeping your information accurate

It is important to us that the personal information we hold about you is accurate and up to date. During our relationship with you we may ask you to tell us if any of your personal information has changed. If you wish to make changes, contact us using the details in section 16. We will generally rely on you to make sure the information we hold is accurate and complete.

12. Requesting access to your personal information

You have rights under the Privacy Act to request access to the personal information we hold about you, and you may do so at any time. Where we hold information you are entitled to access, we will try to provide a suitable means of accessing it, for example by emailing or mailing it to you.

We will not charge you for making the request, and we will not charge for making any corrections. Depending on the type of request, we may respond immediately; otherwise we usually respond within 30 days of receiving it.

There may be situations where we are not required to give you access, for example where the information relates to existing or anticipated legal proceedings, or where the request is vexatious. If we deny you access, we will explain why.

13. Correcting your personal information

If any of the personal information we hold about you is incorrect, inaccurate or out of date, you can ask us to correct it. Where appropriate we will correct it at the time of your request. Otherwise we will give you an initial response within seven days of receiving your request, and where reasonable, after our investigation, we will tell you within 30 days whether we have corrected the information.

We may need to consult other entities as part of our investigation. If we refuse to correct the information we will give you our reasons, and at your request we will take reasonable steps to add a note recording that you disagree with it.

14. Government identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose that information other than as required by law. We do not adopt any government identifier as our own identifier of you.

15. Doing business without identifying you

In most circumstances we need to identify you in order to do business with you. Where it is lawful and practicable, we will give you the opportunity to deal with us without providing personal information, for example if you are making a general enquiry about how the process works.

16. How safe and secure is your information?

Because this website is connected to the internet, and the internet is inherently insecure, we cannot give any assurance about the security of information you send us online, and we cannot guarantee that information you supply will not be intercepted while being transmitted over the internet.

We otherwise take reasonable steps to protect your personal information by storing it in a secure environment. We may store it in paper and electronic form. We take reasonable steps to protect personal information from misuse, loss, and unauthorised access, modification or disclosure. Sensitive documents are collected through FileInvite, a secure document portal, rather than by plain email. When we no longer need your information, and we are legally permitted to, we take reasonable steps to destroy or de-identify it.

How this website itself handles cookies, tracking and third-party embeds is set out in our website policy.

17. Privacy complaints

If you are unhappy with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you can contact us using the details below. We ask that privacy complaints be made in writing so we can be clear about the details.

We will typically acknowledge your complaint within seven days, and we will usually give you a decision within 30 days. If we need more time, we will let you know. Our full complaints process, including external dispute resolution through AFCA, is set out on our complaints page.

If you are dissatisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or 1300 363 992.

18. Contact us

If you have questions about this privacy policy, a concern or complaint about how we have treated your privacy, or you want to request access to or correction of your personal information, contact us:

• Demir Loans Pty Ltd, ABN 49 698 798 088
• Attention: Ugur Ozer, Privacy Officer
• Email: ugur@demir.loans
• Phone: 0495 000 228

If you would rather put a privacy matter in writing by post, you can write to the Resolutions team at LMG, who handle written complaints for the credit licence we operate under, and mark it to our attention: Resolutions, Level 28, 35 Collins Street, Melbourne VIC 3000.

19. Changes to this privacy policy

We may revise this privacy policy from time to time to reflect changes in the law or in market practice. When we make changes, they are reflected on this page. To the extent permitted by law, any revised policy applies both to information we already hold about you at the time of the change and to personal information collected afterwards. We encourage you to re-read this policy from time to time to see whether anything has changed that affects you.