Privacy Policy | Loan Shepherd

Draft — not yet ready to publish.

This has been written to cover everything an Australian Privacy Principles-compliant policy needs for a credit assistance business, but it is not a compliance opinion. Replace every bracketed item with Loan Shepherd’s actual details, then have the whole document reviewed by your lawyer and your licensee or aggregator’s compliance team before the site goes live.

Loan Shepherd Pty Ltd trading as Loan Shepherd, ABN 12 700 380 025 (“we”, “us”, “our”) is committed to protecting your privacy. This policy explains how we collect, hold, use and disclose your personal information and credit information, and applies to this website and to the credit assistance services we provide.

We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and by Part IIIA of that Act and the Privacy (Credit Reporting) Code 2014, which together govern credit reporting.

Anonymity and pseudonymity

You are welcome to browse this website and make general enquiries without identifying yourself. However, to provide credit assistance we must generally know who you are — we are required by law to verify your identity, including under anti-money laundering and counter-terrorism financing legislation, and to assess your requirements before recommending or arranging any credit product. For that reason, we are not usually able to assist you on an anonymous or pseudonymous basis once you ask us to act for you.

What we collect

To assess and arrange credit for you we generally need to collect:

Identity information — your name, date of birth, contact details, residential address and identification documents.
Financial information — income, employment, assets, liabilities, expenses, bank statements, tax returns and business financials.
Credit information — details of your credit applications, credit limits, repayment history and any defaults, obtained from credit reporting bodies with your consent.
Information about your requirements and objectives, and about any dependants or co-applicants.
Website information — if you contact us through this site, the details you send us.

We collect this information directly from you wherever we can. We may also collect it from your co-applicant, accountant, employer, referrer, a lender, an insurer, a previous broker or lender, or a credit reporting body, with your consent, or from publicly available sources.

If you choose not to provide information we ask for, we may not be able to assist you.

Sensitive information

We do not seek to collect sensitive information about you, such as health information, unless it is necessary and you have consented — for example, if you tell us about a health or personal circumstance that may affect your ability to make repayments, so that we can consider it or refer you to appropriate hardship assistance.

Why we collect it and how we use it

To assess your requirements and objectives and to determine whether a credit product is not unsuitable for you.
To prepare, submit and manage a credit application on your behalf.
To comply with our legal obligations, including anti-money laundering and responsible lending requirements.
To manage our relationship with you, including reviewing your loan periodically to see whether a better option is available.
To improve our services, on a de-identified or aggregate basis.
To send you information about our services, where you have not opted out. You can opt out at any time by emailing admin@loanshepherd.com.

We will only use or disclose your personal information for another purpose where you would reasonably expect us to, where you have consented, or where the law permits or requires it.

Who we disclose it to

Lenders and their mortgage insurers, valuers and assessors.
Our licensee, LMG Broker Services Pty Ltd, and our aggregator, [AGGREGATOR NAME — TO BE CONFIRMED].
Credit reporting bodies, and other credit providers where permitted by law.
Service providers who help us operate our business, including our customer relationship management, document collection, e-signature and IT providers.
Your other advisers where you have asked us to, such as your solicitor, conveyancer, accountant or financial planner.
Government and regulatory bodies where required or authorised by law.

We do not sell your personal information.

Overseas disclosure. [OVERSEAS DISCLOSURE — list the countries where any service provider or team member handling client data is located, for example if client service work is performed offshore, and confirm the safeguards in place — TO BE CONFIRMED]

Credit reporting

With your consent we may obtain a credit report about you from a credit reporting body. We may also disclose information to a credit reporting body where permitted. The credit reporting bodies we deal with are [CREDIT REPORTING BODIES USED — TO BE CONFIRMED].

We will only use credit reporting information we obtain about you for the purpose of assessing your application and for other purposes permitted under Part IIIA of the Privacy Act. We will not use your credit reporting information for direct marketing.

You may contact a credit reporting body at any time to ask it not to use your credit reporting information for pre-screening of direct marketing by credit providers, and to ask it to place a ban period on disclosing information about you if you believe you have been, or are likely to be, a victim of fraud. Each credit reporting body has its own policy about how it handles your information, available on its website.

How we hold and protect it

We hold your information electronically in access-controlled business systems, and in paper form where necessary. We take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure, including access controls, multi-factor authentication and staff confidentiality obligations.

We keep your information for as long as we need it for the purposes above and to meet our legal record-keeping obligations, then destroy or de-identify it.

If we experience a data breach involving your personal information that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner in accordance with our obligations under the Notifiable Data Breaches scheme.

Accessing and correcting your information

You can ask for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details below. We will respond within a reasonable period and will generally not charge you, though we may charge for the reasonable cost of providing access in some circumstances. If we refuse access or correction we will explain why in writing.

This website

You do not need to register an account or log in to use anything on this site. The repayment, borrowing power, stamp duty, extra repayments and offset calculators run entirely in your browser — nothing you type into them is sent to us, stored, or seen by anyone.

This site sets no cookies of its own. We use Cloudflare Web Analytics to understand how many people visit and which pages they read; it does not use cookies or any persistent identifier, and does not track you across other websites. It reports aggregate figures only, such as total visits and popular pages — not who you are. See Cloudflare's privacy policy at cloudflare.com/privacypolicy.

The Contact page separately embeds a Calendly scheduler so you can book a time directly; Calendly may set its own cookies and process the details you enter into it under its own privacy policy, available at calendly.com/privacy.

[Confirm this description is accurate and add any other analytics or embedded tool now in use. — TO BE CONFIRMED]

Complaints

If you believe we have breached your privacy, please contact us first at admin@loanshepherd.com or 0408 372 766, or write to us at 148 Merthyr Road, New Farm QLD 4005. We will acknowledge your complaint and investigate it promptly.

If you are not satisfied with our response you can contact the Australian Financial Complaints Authority on 1800 931 678 or at afca.org.au, or the Office of the Australian Information Commissioner on 1300 363 992 or at oaic.gov.au.

Changes to this policy

We may update this policy from time to time to reflect changes in our practices or the law. The current version is always available on this page, and continuing to use our website or services after a change takes effect means you accept the updated policy.

Version [VERSION — TO BE CONFIRMED] · Last updated [DATE — TO BE CONFIRMED]