Privacy Policy

Connect Capital Solutions Pty Ltd (ACN 006 778 678) (CCS)

CCS is committed to protecting your personal information. It is a Melbourne-based mortgage lending business. It offers investors a unique opportunity to directly participate in mortgages as the lenders on title.

This Privacy Policy explains how CCS (“we”, “our” or “us”) handles personal information in operating its lending business. It also gives you information about how to contact us if you have any further queries about this.

Background

We comply with the thirteen Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (the Act) in handling the personal information of investors, borrowers and guarantors who are individuals. The APPs regulate how to handle personal information throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.

Personal information is information or an opinion, in any form and whether true or not, about an identified individual, or an individual who is reasonably identifiable. Special rules apply for collecting personal information which is sensitive information. This includes health information and information about a person’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual orientation or practices and criminal history.

The kind of personal information we collect and hold

General

This Privacy Policy applies to you if you are an individual, i.e. a natural person whose personal information is protected by the Act. You may be an investor, borrower or guarantor in your own right, or you may be an individual who is associated with an investor, borrower or guarantor, i.e. an officer or shareholder (associated individual).

Borrowers and guarantors and associated individuals

We may collect your full name, date of birth, residential address and phone, email and other contact details. We will also collect information about the purpose for the loan and how the borrower proposes to repay it, as well as details about the property that will be mortgaged in favour of the investor/s. We may also collect any other information which may affect a loan proposal or the borrower’s ability to service the loan.

Investors and associated individuals

We may collect your contact details, as well as your bank account details for payment of interest to you. We may also collect information certifying that you have the net assets or gross annual income to qualify as a wholesale client for the purposes of the Corporations Act 2001 (Cth).

How we collect and hold personal information

To the extent required by the Act:

  • we will not collect your personal information unless that information is reasonably necessary for one or more of our functions or activities; and
  • we will collect personal information only by lawful and fair means.

When we collect personal information directly from an individual, we will take reasonable steps at or before the time of collection to ensure that they are aware of certain key matters, such as the purposes for which we are collecting the information, the organisations (or types of organisations) to which we would normally disclose information of that kind, the fact that you are able to access the information and how to contact us.

The purposes for which we handle personal information

Borrowers, guarantors and associated individuals

We collect your personal information for the purposes of:

  • considering a loan application and fulfilling regulatory requirements, including seeking a property valuation and undertaking customer identity verification for land mortgage and anti-money laundering and counter terrorism financing purposes;
  • providing details of the loan application to investors; and
  • administering the loan under which you or your associated company is the borrower or guarantor.

Investors and associated individuals

We collect your personal information to administer our relationship with you or your associated company. This includes keeping you up-to-date about loans in which you or your associated company is an investor and arranging for loan payments to be made to you or your associated company.

General

If we use or disclose the personal information of an individual for a purpose (the “secondary purpose”) other than the main reason for which it was originally collected (the “primary purpose”), to the extent required by the Act, we will ensure that:

  • the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and the individual would reasonably expect that we would use or disclose their information in that way; or
  • the individual consented to the use or disclosure of their personal information for the secondary purpose; or
  • the use or disclosure is required or authorised by or under law; or
  • the use or disclosure is otherwise permitted by the Act (for example, as a necessary part of an investigation of suspected unlawful activity).

We may disclose personal information to our service providers to facilitate our provision of services to investors and loans to borrowers.

Data quality and security

To the extent required by the Act, we will take reasonable steps to:

  • make sure that the personal information that we collect, use and disclose is accurate, complete and up to date;
  • protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
  • destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Act.

Transfer of personal information outside Australia

We do not transfer personal information to recipients located outside Australia.

Access and correction of your personal information

Please contact us at info@connectcs.com.au if you would like to access or correct the personal information that we hold about you. We will generally provide you with access to your personal information if practicable (although a fee may be imposed), and will take reasonable steps to amend any personal information that is incorrect. In some circumstances, we may not permit access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision.

Questions or complaints

Please contact us at info@connectcs.com.au if you have any questions or complaints about the personal information that we hold about you or about the way we handle that personal information. We will acknowledge your question or complaint as soon as possible and will seek to address any question or complaint within 21 days after that.

Notifiable data breaches

If there is a loss, or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with the Act.

Changes

We may change this Privacy Policy from time to time. You can find our up-to-date Privacy Policy posted on our website from time to time.

Contact Details

Connect Capital Solutions Pty Ltd (ACN 006 778 678) Authorised Representative No 001273645 of C.S. & Co Managers Pty Ltd (AFSL 495639), Level 4, 380 Collins Street, Melbourne, Victoria 3000. Email: info@connectcs.com.au