We take your privacy seriously, and that’s why we want you to know exactly how your information will be shared amongst our different businesses and when we need to share it with a third party.
OpenAgent Pty Ltd ABN 93 161 595 679 (OpenAgent), OA Real Estate Pty Ltd ACN 164 368 843, Doorsteps Finance Pty Ltd ACN 648 541 879 (Doorsteps Finance) and Doorsteps Solutions Pty Ltd ABN 60 654 334 246 and Australian Credit Licence Number 537369 (Doorsteps Solutions), ) respects all customers, third parties, suppliers and visitors (you, your or yours) privacy and is committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles and the Privacy (Credit Reporting) Code 2014 (Credit Reporting Code). The Privacy Act defines personal information as information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not (personal information). In this policy, “Doorsteps”, “we”, “us” and “our” refers to each of OpenAgent Pty Ltd, OA Real Estate Pty Ltd, Doorsteps Finance Pty Ltd and Doorsteps Solutions Pty Ltd.
We collect personal information from you for the purposes of dealing with you and in assisting us to arrange for the products and services you request to be provided to you. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. This may also entail collecting credit-related information where you decide to apply for credit.
The personal information we collect and hold may include, your contact details, such as your name, property address, telephone numbers and email address, your personal details, such as date of birth, your employment information, residential status and information about your financial position, including your income, expenses, savings and assets and any (other) credit arrangements, your reasons and objectives for applying for a product or service and where required other details such as the ages and number of your dependants, the length of time you have lived at your current address, information relevant to your property interests, including properties you have shown an interest in and other information we consider relevant to assessment of your application for credit or any other service we provide. We also hold all records of your communications and other interactions with us.
The credit-related information we collect about you and hold includes details of credit applied for and details of the type and amount of credit granted, the fact that credit provided to you has been repaid, whether or not you have made payments on time, default information, being payments overdue and for which collection action has started, information about your credit worthiness, details of any new arrangements made with you, court proceedings and person insolvency information, and if in you have committed a serious credit infringement.
If you would like to understand what information in particular we hold on you, please contact us on email@example.com.
We collect personal information about you when it is reasonably necessary for one or more of our activities or functions. This personal information is collected in a number of ways, including through the Sites. This information may also be collected automatically sometimes. For example, through tracking technologies (including cookies). We may:
The provision of your personal information is voluntary. However, if you cannot, or will not, provide us with the personal or credit-related information we reasonably require, we may not be able to verify your identify, assess your application for a product or service, manage our relationship with you, contact you or otherwise interact with you, perform our statutory functions, or provide you with some or all of our credit products and other services.
We will not collect or use your personal information or credit-related information unless it is lawful for us to do so. We collect and use personal and credit-related information for the following purposes:
In addition to the specific circumstances above, we will only use your personal information with your consent (if required under applicable data protection laws) when we process your personal information in order to send you carefully selected marketing materials about our products and services (or those of our third party partners) by email, text or push notification, depending on your account or operating system settings. You have the right to opt out of receiving direct marketing at any time. If at any time you wish to stop receiving direct marketing messages from us you can let us know by contacting us. In your request, please indicate that you wish to stop receiving marketing communications from us.
We may disclose your personal and credit-related information to any of our related and associated companies, affiliates and subsidiaries, including those established in the future, for example, guarantors and security providers, credit bureaus, credit reporting bodies, other credit providers, brokers, agents, financial advisors and people who act on your behalf, organisations involved in our funding arrangements, other banks and financial institutions, auditors, organisations that help identify illegal activities and prevent fraud, any data processors processing your information on our behalf, where applicable, third parties who provide related services or products in connection with our business such as real estate agents, our vendors, business partners, and any party assisting us in carrying out the purposes described above.
We may also disclose your personal and credit-related information to parties which participate in joint marketing schemes with us, any agent, contractor or service provider who provides verification of identity, administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business, any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law, government agencies, statutory authorities and industry regulators, our auditors, consultants, accountants, lawyers or other financial or professional advisers and our sub-contractors or third party service or product providers as may be determined to be necessary or appropriate.
Individuals may request access to their personal and credit-related information unless we are permitted by law to withhold that information. Individuals may also request the correction of any personal information which is inaccurate by contacting our Privacy Officer at firstname.lastname@example.org. To the extent permitted by law, there are some exceptions where this access may be denied. If we deny you access to the personal or credit-related information we hold about you, or if we refuse to correct your personal or credit-related information, an explanation will be provided to you. To request access and seek the correction of personal information held by us, please email, call or write to us. We will endeavour to respond to any access or correction request within 7 working days of receipt.
If you would like any further information about our handling of personal information, or to make a complaint about our handling of your personal information, or you believe there has been a breach by us of the Privacy Act or the credit reporting provisions of the Credit Reporting Code, please lodge a complaint addressed to our Privacy Officer at email@example.com. Once we receive your complaint, we will respond to you within 7 working days. We will provide you with a decision on your complaint within 30 days. If you are unsatisfied with the outcome of your complaint, you may contact us further to advise of your concerns and, if we are unable to reach a satisfactory resolution, you may wish to take your complaint to the Australian Financial Complaints Authority, which can be contacted by phone on 1800 931 678, by email at firstname.lastname@example.org, or in writing to GPO Box 3, Melbourne VIC 3001. Please email email@example.com if you need to obtain our AFCA membership details or if you need further assistance in this regard. Or, you can contact the Office of the Australian Information Commissioner (OAIC). The OIAC can be contacted by phone: 1300 363 992. Website: www.oaic.gov.au
The Notifiable Data Breaches (NDB) scheme applies to eligible data breaches that occur on or after 22 February 2018. It mandates a reporting and notification process for Doorsteps.The OAIC administers the NDB scheme.
If there is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that Doorsteps holds;
The NDB scheme ensures that as an organisation, we are accountable for your privacy protection. The notification process is important for building a relationship of trust and transparency. In addition, by keeping you notified, you’re better able to take steps to mitigate harm, such as changing passwords or being alert to phishing emails or scams. In the interim, Doorsteps would also be taking steps to remediate the breach and will keep you advised on our progress, including the security measures being undertaken.
Please contact us on the details provided if you have any questions about this.
By Post: PO Box 419, Alexandria NSW 1435
By Email: firstname.lastname@example.org
We also use Google Signals. This allows us to assign and track the customer journey of an individual website visitor to different end devices. For example, we can see when a user clicks on an Doorsteps advertisement on one device and then registers for our services on another device. However, we can only see this if the user has logged in to a Google service when visiting a website and has activated the option “personalised advertising” in their Google account settings at the same time. If you do not want “Google Signals” to be used, you can disable the “Ads Personalisation” option in your Google Account preferences. No personal data or user profiles are accessible to us; this means you remain anonymous to us.
For example, we will use and share historical and current de-identified user and transactional data to develop marketing initiatives and product offerings. Those understandings, whether developed internally or in connection with an external partner may also be provided to our selected business and commercial partners from time to time. If you have any concerns or questions about our approach to, or use of, de-identified data, please let us know.
This refers to the use and disclosure of government related identifiers. For example, your tax file number and country of tax residency, medicare card, Australian passport, driver licence or pension card details , citizenship and birth certificate, death and marriage certificates etc.
We do not adopt a government related identifier of an individual as our own identifier unless required or authorised to do so by or under an Australian law, regulation or court/tribunal order. Before using or disclosing a government related identifier of an individual, we ensure that such use or disclosure is:
From time to time, you may send an application to us via an online form. We may use that information to correspond with you directly and to determine the suitability of any products and services. If you start but do not submit an online application, we may contact you using any of the contact details you have supplied to offer help completing it.
We may in some cases use automated decision-making. We will only do so if it is authorised by law, if you have provided an explicit consent, or if it is necessary for the performance of a contract. For example, we may use an automated credit approval process. You may request that we use a manual decision-making process instead. You can also express an opinion on or contest any decision which was based solely on automated processing or profiling. If we are using automated decision-making, we will let you know about the logic used, our legal basis, and the significance and envisaged consequences.