Super Loan Exchange Pty Ltd (ABN 916158200520)
Super Loan Exchange Pty Ltd (SuperLX) will collect information from a customer (the “applicant”) and data sources the applicant controls for the purpose of assisting the applicant to apply for an SMSF Loan. SuperLX’s interaction with the applicant will almost exclusively be via its website in a secure environment.
2 Information we receive about the applicant
We will receive a number of different types of information about the applicant, including:
- Identification information upon registration
- Third party sourced information, and
- Other information provided by the applicant
2.1 Identification information upon registration
Upon registration with SuperLX, we will seek information about the applicant to help us identify them and track their application. The information will include their name, their capacity to act on behalf of the borrower (the SMSF) and contact details such as email address and telephone number.
We will obtain consent from the applicant to provide this information to the Lender, as well as permission for the Lender to contact the applicant should they wish to proceed with their application. SuperLX will not be responsible for verifying the applicant’s identity, unless we are requested by the Lender to do this. Otherwise, the Lender will be responsible for verifying the identity of the applicant.
2.2 Accounting Platform sourced information
SuperLX will have arrangements in place with a number of Accounting Platforms to access information about the applicant. Upon registration, the applicant will be invited to authorise SuperLX to access this information for the purposes of undertaking an initial credit assessment of the applicant’s debt service capability and suitability for an SMSF Loan. The information will also be used to complete a full application should the applicant choose to proceed with their application. The applicant will provide authorisation by logging into their Accounting Platform using their unique identification credentials provided by that service. This will be done via the SuperLX portal, which will then be granted a one-time access for SuperLX to extract the required static information to complete the application process. This information will be transferred via a secure API between SuperLX’s platform (powered by Cloud Lending) and the third party accounting service (please also refer to our Data Protection Policy).
The information extracted by SuperLX will include assets, liabilities and income of the SMSF, as well as relevant static statutory information and documentation that is required to complete a full application.
2.3 Other information provided by the applicant
The applicant will be invited to provide additional information required by our online application form. This information will be necessary to make an initial assessment of the applicant’s debt service capability and suitability for an SMSF Loan. This information is also required to complete a full application.
This information will include additional financial information about the applicant, the SMSF, the members of the SMSF and details of the intended investment property.
2.4 Transmission of information to the Lender
SuperLX will obtain the applicant’s authorisation to pass this information on to the Lender in the form of our electronic application.
3 Marketing and solicitation
The applicant’s personal information may be collected so that we, and our related entities can promote and market services to them (including by way of direct mail, telemarketing, email, testing or other messaging). This is to keep the applicant informed of our products, services and special offers that we may seek to provide the applicant after we have provide our initial service to them. We may also market our products to the applicant through third party channels (such as social networking sites).
We will always let the applicant know that the applicant can opt out from receiving our third party marketing.
Where we market to prospective customers, we will always provide an easy way to opt-out.
With the applicant’s consent, we may disclose the applicant’s personal information to third parties such as brokers or agents, or for the purpose of connecting the applicant with other businesses or customers. The applicant can ask us not to do this at any time.
We will never sell the applicant’s personal information to any external organisation.
We will not use or disclose sensitive information about the applicant for direct marketing purposes unless the applicant has consented to that kind of use or disclosure.
SuperLX will not contact a customer or procure their personal information, except for when the customer contacts us through any of the following sources:
- We are contacted as a result of general advertising or marketing
- Navigation to our website though search
- Navigation to our website by introduction through a marketplace service administered an Accounting Platform
- Other services the customer voluntarily provides its information to for the purposes of procuring an SMSF Loan
- For feedback to SuperLX on how we have performed our services
4 How we use the information we receive
4.1 Service providers
- Verify the customer’s identity if required
- Assist the customer to gain approval or provision of a product or service
- Provide the services the applicant requires
- Administer and manage those services such as payments
- Inform the customer of ways the services provided to them could be improved or additional services that they may benefit from
- Research and develop our services provided, either directly or referred
- Gain an understanding of the customer’s information and credit or financial needs in order for us to provide them with a better service
Some of the above external organisations and entities may be located outside of Australia. The customer should note that while they will often be subject to confidentiality or privacy obligations, they might not always follow the particular requirements of Australian privacy laws. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
4.2 The Lender
We will provide the personal information gathered from the applicant to the Lender to enable the Lender to assess the applicant’s ability and suitability to borrow. The Lender may also use the applicant’s personal information in other ways not involving SuperLX that may be agreed between the applicant and the Lender.
4.3 Law and harm
Notwithstanding anything to the contrary in this Policy, we may preserve or disclose the applicant’s information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect SuperLX’s rights or property. However, nothing in this Policy is intended to limit any legal defences or objections that the applicant may have to a third party’s, including a government’s, request to disclose the applicant’s information.
4.4 Business transfers
In the event that SuperLX is involved in a bankruptcy, merger, acquisition, reorganisation or sale of assets, the applicant’s information may be sold or transferred as part of that transaction. The promises in this Policy will apply to the applicant’s information as transferred to the new entity.
4.5 Non-private or non-personal information
We may share or disclose the applicant’s non-private, aggregated or otherwise non-personal information, such as the applicant’s public user profile information, public review, the applicant’s question posted on SuperLX, or the number of users who clicked on a particular link (even if only one did).
5 Accurate information
We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information the applicant or others provided to us.
If the applicant wishes to make any changes to their personal information, we invite them to contact us. We will generally rely on the applicant to assist us in informing us if the information we hold about the applicant is inaccurate or incomplete.
The applicant may request access to the personal information we hold about the applicant by contacting us. We will respond to the applicant’s request within a reasonable period. We will give access in the manner the applicant have requested if it is reasonable to do so.
We may deny the applicant access to the applicant’s personal information in certain circumstances, for example, if required or authorised by or under an Australian law or a court/tribunal order, or it would be likely to prejudice enforcement related activities by an enforcement body.
If we decide not to give the applicant access, we will provide reasons for the refusal and information on how the applicant can complain about the refusal.
6 Storage and security
We store information in different ways, including in paper and electronic form. The security of the applicant’s personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- Confidentiality requirements of our employees
- Our Data Protection Policy
- Security measures for access to our systems
- Only giving access to personal information to a person who is verified to be able to receive that information
- Control of access to our buildings
- Electronic security systems, such as firewalls and data encryption on our websites
We may store the applicant’s information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from anywhere via an Internet connection, it is not always practicable to know in which country the applicant’s information may be held. If the applicant’s information is stored in this way, disclosures may occur in countries other than those listed here or those we referred to from time.
In addition to the above, we also regularly review developments in security and encryption technologies. However, it is important to remember that the use of email and the Internet may not always be secure, even with these safeguards in place.
When we no longer require the applicant’s information, and we are legally permitted to, we take reasonable steps to destroy or de-identify the information. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by the applicant.
7 Deleting and deactivating the applicant’s account
If the applicant wants to stop using the applicant’s “account”, the applicant can delete it by sending an email to [email protected] with an “Account Deletion Request” subject.
When the applicant deletes its account, it is permanently deleted from SuperLX’s system. It typically takes about one month to delete an account, but some information may remain in backup copies and logs for up to 90 days.
8 Business without identifying the applicant
In most circumstances, it will be necessary for us to identify the applicant in order to successfully do business with the applicant.
However, where it is lawful and practicable to do so, we will provide the applicant with the option to remain anonymous or to use a pseudonym, for example, when the applicant make general inquiries about our business or current promotional offers.
We do not adopt a government related identifier (such as the applicant’s tax file number or the applicant’s driver’s licence number) as a means of identifying the applicant.
We are constantly reviewing all of our policy and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.
As a consequence we may change this Policy from time to time or as the need arises.
By providing the applicant’s email address and phone number and then clicking submit on any online application, calculator, tool or query, the applicant consents to receiving notices and other documents from us by email, phone or SMS to the provided email address and phone number, and the applicant understands that if they give this consent:
- We may no longer send the applicant paper copies of notices and other documents
- The applicant should regularly check their email address for documents
- The applicant may withdraw the applicant’s consent to receiving documents by email at any time
The applicant also confirms that it has the facilities to print any notice or document that we send the applicant by email, if desired.
As an Australian based and registered business SuperLX is at all time subject to all rights and responsibilities as published in the Australian Privacy Act 1988.
Privacy disputes and/or claims should be lodged via the Office of the Australian Information Commissioner (OAIC). See www.oaic.gov.au (https://www.oaic.gov.au/) for further detail.