FME Financial Services Pty Ltd trading as GHET Finance - Privacy Policy

1. Our Commitment to Your Privacy

GHET Finance ("we", "us", "our") is committed to protecting your privacy and handling your personal information in an open and transparent way. We comply with the Australian Privacy Principles (APPs) as defined in the Privacy Amendment (Enhanced Privacy Protection) Act 2012.

This policy outlines the following, including but not limited to:

• Who we are and what our main function or activity is;
• The kinds of Personal Information (PI) we collect and hold;
• How we collect PI;
• The purposes for which we collect, hold, use and disclose PI;
• How we deal with individuals who remain anonymous or use a pseudonym;
• How we deal with solicited information;
• How we deal with unsolicited information;
• Notification of the collection and use of PI;
• Direct marketing and how you can opt out of receiving marketing material;
• Cross-border disclosure of PI;
• Collection and use of government related identifiers;
• How we ensure your PI is accurate and up to date;
• How we keep PI secure;
• How you may access your PI and seek its correction;
• How you can make a complaint if you believe we have breached the APPs and how we handle the complaint;
• Changes to this policy; and
• How you can contact us if you have any questions relating to this policy or how we handle personal information.

2. What is Personal Information?

Personal information is 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 recorded in a material form or not. This can include sensitive information and credit-related information.

3. What Personal Information Do We Collect and Hold?

We may collect and hold various types of personal information necessary to provide our financial brokerage services and conduct our business functions. This may include:

• Identity Information: Name, address, date of birth, contact details (phone numbers, email addresses), gender.
• Financial Information: Bank account details, income/earnings details, expense details, asset and liability information, Tax File Number (TFN), credit history, transaction history.
• Credit-Related Information: Information about your creditworthiness, credit standing, credit history, or credit capacity, including information obtained from credit reporting bodies (CRBs).
• Employment Information: Occupation, employment history, employer details, proof of earnings.
• Other Information: Number and ages of dependents/cohabitants, length of time at current address, purpose of finance, information provided via our website (e.g., IP address, device type, pages visited, location information), details required for identity verification (e.g., driver's licence, passport details), referees.
• Sensitive Information: Such as health information (e.g., if applying for certain insurance products). We will only collect sensitive information with your explicit consent and where it is necessary for our functions.

4. How Do We Collect Your Personal Information?

We collect personal information in various ways, including:

• Directly from you: When you fill out application forms (online or paper), contact us via phone or email, use our website or mobile apps, or meet with our brokers.
• From third parties: Such as your referees, employers, accountants, lawyers, other representatives, credit reporting bodies, other credit providers, publicly available sources (e.g., public registers, social media), or other organisations involved in managing or administering your finance.
• When you use our website: Through cookies and other tracking technologies which may collect your IP address, device information, location, and browse activity.

5. Why Do We Collect Your Personal Information?

We collect, hold, use, and disclose your personal information for purposes including:

• Assessing your application for finance and related services.
• Providing you with credit assistance and brokerage services.
• Verifying your identity.
• Managing the finance products and services we provide to you.
• Managing our relationship with you.
• Complying with our legal and regulatory obligations (e.g., Anti-Money Laundering and Counter-Terrorism Financing Act, National Consumer Credit Protection Act).
• Direct marketing of products and services offered by us or associated companies (you can opt-out).
• Managing risks and investigating potential illegal activity.
• Conducting research and improving our products, services, and customer experience.
• Responding to your enquiries and complaints.

6. Who Do We Disclose Your Personal Information To?

We may disclose your personal information to third parties where necessary for our business functions, including:

• Prospective lenders, funders, mortgage insurers, or other intermediaries relating to your finance requirements.
• Credit reporting bodies (CRBs).
• Our mortgage aggregator.
• Other organisations involved in managing or administering your finance (e.g., third-party suppliers, mail houses, call centres).
• Entities that provide services to us (e.g., IT service providers, data hosting providers, identity verification services).
• Your representatives (e.g., lawyers, accountants, referees).
• Government and regulatory bodies (where required or authorised by law).
• Anyone to whom you have consented for us to disclose information.
• Debt collection agencies or potential assignees of debts.
• Our related bodies corporate.

7. Overseas Disclosure

We may disclose your personal information to entities located outside of Australia. This may include:

• Our data hosting and IT service providers located in Australia.

Where we disclose your information overseas, we take reasonable steps to ensure the recipient has privacy commitments at least equal to the Australian Privacy Principles, or we obtain your consent. However, by providing your information, you acknowledge that overseas recipients may not be bound by the Australian Privacy Act, and you may not be able to seek redress under Australian law.

8. Credit-Related Information

We may collect, use, and disclose credit-related information about you. This includes exchanging information with Credit Reporting Bodies (CRBs) like Equifax, Experian, and Illion.

9. Direct Marketing

We may use your personal information to offer you products and services we believe may interest you. If you do not wish to receive marketing communications, you can opt-out at any time by contacting us using the details below or using the unsubscribe function in electronic messages.

10. Data Security and Storage

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. We store information physically and electronically, potentially using third-party data storage providers (including cloud storage which may be located overseas). We use security measures such as firewalls, access controls, encryption, and secure premises.

11. Data Retention

We retain personal information only for as long as necessary for the purposes it was collected, or as required by law (e.g., often 7 years for financial records under the Corporations Act or AML/CTF Act). When no longer needed, we take reasonable steps to destroy or deidentify it.

12. Accessing and Correcting Your Personal Information

You have the right to request access to the personal information we hold about you and request its correction if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading. To request access or correction, please contact us using the details below. We will generally respond within a reasonable period (e.g., 7-30 days). We may need to verify your identity first. In some circumstances, we may refuse access or correction as permitted by law, but we will provide reasons for any refusal.

13. Making a Complaint

If you believe we have breached the Privacy Act or mishandled your personal information, please contact our Privacy Officer using the details below. Please provide details of your complaint. We will acknowledge your complaint within 7 days and investigate it, providing you with a decision within 45 days. If you are dissatisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Online: www.oaic.gov.au
• Phone: 1300 363 992
• Mail: GPO Box 5218, Sydney NSW 2001

14. Policy Updates

We may update this Privacy Policy from time to time. The latest version will always be available on our website at www.ghetfinance.com.au. We encourage you to review it periodically.

15. Contact Us

If you have questions about this policy, wish to access or correct your information, make a complaint, or opt-out of marketing, please contact our Privacy Officer:

• Privacy Officer: [Insert Name/Title]
• Mail: Level9, 1 Corporate Court, Bundall QLD 421
• Email: admin@ghet.com.au
• Phone: 07 33773737