1. XIN Mortgage’s Commitment to Maintaining Your Privacy

XIN Mortgage (’us’, ‘we’, ‘our’) and its related entities are bound by the Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles (APPs) and any registered privacy codes that apply to it.

This Privacy Policy has been created because we value our members and recognise their right to keep personal information private. Together with our Terms & Conditions and any other documents referred to on it sets out how we collect, use, disclose and otherwise manage your personal information.

We may, from time to time, review and update this policy, including to take account of new or amended laws, new technology and/or changes to our operations.  All personal information we hold will be governed by the most recently-updated policy.  The latest version of the policy will be available on our website.

2. Collecting Personal Information

‘Personal Information’ is any information or 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 stored in a material form or not.

We only collect personal information that is directly related to, or reasonably necessary for, our functions and activities.  The kinds of personal information we usually collect include your name, address, phone number, email address and certain internet-related details (see below) and other information relevant to providing you with the information or services you are, or someone else you know is, seeking.

Wherever practicable, we will enable you to deal with us anonymously or pseudonymously, however, in many cases it is not practicable to interact in this way.

If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services or information you or they are seeking.

XIN Mortgage registered members

As part of registering with XIN Mortgage, we collect personal information about you in order for you to take full advantage of XIN Mortgage’s services. The types of information we collect include your name, contact details (including phone numbers and physical and electronic addresses), as well as financial information including what products and services you receive, account numbers and bank account details.

Website users

XIN Mortgage collects information regarding visitors to our site on an aggregated basis, including which sections of the site are most frequently visited, how often and for how long. This data is always used as aggregated, non-personal information. XIN Mortgage utilises this information to improve and enhance our services by monitoring the areas on the site which are most popular to you. This aggregated information may be shared with XIN Mortgage partners to provide them with an overview of how XIN Mortgage visitors use the site. This is done for the purposes of providing you with a more efficient site.

 IP Addresses

XIN Mortgage’s web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Again, information is gathered in aggregate only and cannot be traced to an individual user.

Cookies & Applets

XIN Mortgage uses cookies to provide you with a better experience. These cookies allow us to increase your security by storing your section ID and as a way of monitoring single user access. This aggregate, non-personal information is collated and provided to XIN Mortgage to assist in analysing the usage of the site.

How we collect personal information

We collect personal information directly from you wherever reasonable and practicable.  For example, we will collect information from you when you request or acquire a product or service from us, register as a member, complete a survey, questionnaire or form, or when you communicate with us by email, telephone or in writing (for instance when dealing with our customer service team).

We may also collect your personal information from third parties where not reasonable or practicable to collect it from you, or as part of our service (for instance when dealing with third parties with whom you have accounts).  You consent to us collecting information from these third parties as part of our provision of services to you.

3. Purpose of collection

We collect personal information from you for the purpose of providing our services to you, as well as for the purposes set out below:

•to provide you with information about other services that we, our related entities and other organisations that we have affiliations with offer that may be of interest to you;

•facilitating our internal business operations, including the fulfilment of any legal requirements;

•dealing with complaints or enquiries;

•analysing our services and customer needs with a view to developing new or improved services.

4.    Use and disclosure

Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above).  We may disclose personal information about you to third parties:

•for the purpose of fulfilling our primary services of obtaining concessions on commissions (including financial institutions, insurance companies and their agents and sales channels);

•engaged by us to perform functions or provide products and services on our behalf (such as IT service providers, for processing credit card information, for mail outs, financial recovery, marketing, research and advertising);

•that are our agents, business partners or joint venture entities or partners;

•that sponsor or promote any competition that we conduct or promote via our services;

•authorised by you to receive information held by us;

•as part of any investigation into you or your activity, for example, 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 to the Police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator;

•as part of a sale (or proposed sale) of all or part of our business; and/or

•as required or permitted by any law (including the Privacy Act).

XIN Mortgage also provides you with selected information about our documents and website changes in our email communication. This free service is sent to registered users and provides the option of opting out of receiving these by unsubscribing. XIN Mortgage may also make you aware of additional products and services which form part of your relationship with XIN Mortgage.

5. Storage & Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse, loss and interference, and from unauthorised access, modification or disclosure. XIN Mortgage takes all reasonable steps to ensure the security of your personal information, including through appropriate physical and electronic security measures.  For example,

Any information which we hold for you is stored on secure servers. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by XIN Mortgage. You can also play an important role in keeping your personal information secure, by maintaining the confidentiality of any password and accounts used on the XIN Mortgage site.

6. Access and correction

We aim to ensure only required data is held and that all data is complete and accurate.  As a XIN Mortgage member, you are able to change and update your profile at any time.  We encourage you to do this to help us ensure that your personal information that we hold is up to date, accurate and complete.

Should you require assistance with updating your data or removing your details, this can be by forwarding an email to: clientservice@xin.com.au. Users may unsubscribe from the XIN Mortgage services at any time also by contacting us (per the contact details below).

If personal information you have provided us has changed or your circumstances change, or you believe that the data we hold is not accurate, you can also contact us (as per the contact details below) and request access to, or correction of, your personal information.  We will respond to your request within a reasonable time.  If we refuse your request for access or correction, we will give you written reasons (unless it would be unreasonable to provide those reasons) and in the case of a request for correction, a statement setting out the mechanisms available to you to make a complaint.

7. XIN Mortgage Partners & Advertisers

XIN Mortgage provides links and passes to third party sites. The use of your information by these Third party sites is not within the control of XIN Mortgage and we cannot accept responsibility for the conduct of these companies.  Your use of those third party sites may be subject to the separate Privacy Policies of those third parties.

8. Complaints and Feedback

XIN Mortgage welcomes ideas and feedback about all aspects of the site. XIN Mortgage stores feedback that users send to us. This feedback will be used to administer and refine the service and may be shared with XIN Mortgage partners either in aggregate form or with specific identifying characteristics removed.

If you have a complaint about how we deal with your personal information or a breach of this Privacy Policy or the Privacy Act, please contact us as set out below.  We will investigate your complaint within a reasonable time.

Contact Details:

XIN Mortgage Client Service Team

Tel: 1800 896 817

 Email: clientservice@xin.com.au

 Postal address: Suite 502, 80 Mount Street, North Sydney NSW 2060

If you are not satisfied with our response to your complaint, you can contact the Office of the Australian Information Commissioner, at www.oaic.gov.au.