Who are we?
‘We’, ‘us’ and ‘our’ refer to Spring Loans Pty Ltd ABN 69 689 826 980, Australian Credit Representative Number 574863 for Australian Credit Licence 405961
Our commitment to protect your privacy
At Spring Loans Pty Ltd, we understand that the details you provide us are private and personal. It’s important that you feel secure whenever you deal with us. It’s also important that you understand how we protect your privacy and the manner in which we may use your details. As such our policies relating to personal information are designed to ensure that you are fully protected under Australian privacy laws.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
Why we collect your personal information
We collect personal information to provide you with the services that you have requested, manage our relationship with you, for the purposes of assessing your application for finance and managing of that finance. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services. If you would like to opt out of direct marketing material, please contact us directly
How we collect your personal information
Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from finance brokers and other related parties such as accountants and lawyers.
Disclosing your personal information
We may disclose your personal information:
- to prospective funders or other intermediaries in relation to your finance requirements;
- to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres;
- to associated businesses that may want to market products to you;
- to companies that provide information and infrastructure systems to us;
- to anybody who represents you, such as finance brokers, lawyers and accountants;
- to anyone, where you have provided us consent;
- where we are required to do so by law, such as under the Anti-Money or Laundering and Counter Terrorism Financing Act2006 (Cth);
- to investors, agents or advisers, or any entity that has an interest in our business; or
- to your employer, referees or identity verification services.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
- the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
- you have consented to us making the disclosure.
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.
We may disclose your personal information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
Accessing and correcting personal information we hold about you
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct personal information we will provide you with our reasons for not correcting the information.
Our Responsible Lending Obligations to You
We are obliged to ensure that any loan, or principal increase to a loan, we help you to obtain, or any lease we help you enter, is not unsuitable for you. To decide this, we may need to ask you some questions in order to assess whether the loan or lease is not unsuitable. The law requires us to:
- make reasonable enquiries about your requirements and objectives;
- make reasonable enquiries about your financial situation; and
- take reasonable steps to verify that financial situation.
Credit will be unsuitable for you if, at the time of the assessment, it is likely that the following would apply at the time credit is provided:
- you could not pay or could only pay with substantial hardship; or
- the credit will not meet your requirements or objectives.
For example, if you can only repay by selling your principal place of residence, it is presumed that the loan will cause substantial hardship unless the contrary is proved. For this reason we must ask you to provide a significant amount of information. It is important that the information you provide is accurate, complete and up-to-date. If we proceed on incomplete or incorrect information, you may be in breach of your legal obligations to the lender. We will provide you with a copy of our preliminary assessment of your application if you ask, within seven years of when we provided assistance to you. This requirement is only triggered if we give you credit assistance. If we arrange a loan for you to purchase or refinance real estate, remember you must make your own enquiries about the value of the real estate and its potential for future growth. Although we may obtain a valuation, that is for our own use and you should not rely on it.
Our Best Interests Duty (BID) Obligations to You
Mortgage brokers are required to act in the best interests of the consumer when providing credit assistance. The law requires us to:
- Act in the best interests of the consumer when providing credit assistance;
- Give priority to consumers where a conflict of interest is identified when providing credit assistance;
- Not accept conflicted remuneration.
- Gather and document information about a consumers’ individual circumstances, requirements & objectives;
- Educate the consumer to make informed decisions;
- Assess relevant products in line with the consumers needs; and those options & the recommendation are presented.
Commissions
We may receive commissions from the lenders and lessors who provide finance for you as our customers. These fees are not payable by you. You may obtain information relating to reasonable estimates of those commissions and how they are calculated.
If we assist you with a non-consumer credit contract and you or the lender are in NSW, the law in that State requires that we also tell you that we have commission arrangements relating to this type of credit contract. When we provide you with credit assistance, you may ask us for a reasonable estimate of the commission likely to be received by the credit representative. From time to time, we may receive financial or non-financial benefits from lenders, lessors or others. Some or all of a commission received may be paid to the Credit Representative.
Referral Fees
We may pay a referral fee (i.e. commission) for third party referrals. An example of a referrer would be a real estate agent or solicitor. This fee is not payable by you. This fee will be disclosed in the Credit Proposal Disclosure Document. You may on request obtain a reasonable estimate of the amount of commission and how it is calculated. We may also receive a benefit for referring you, with your consent, to other specialist service providers.
Internal Dispute Resolution
If you are unhappy with our services, please contact us first by contacting our complaints manager on the following:
Telephone 1300 667 694
Email brokers@redrockgroup.com.au
Post PO Box 33142, Melbourne VIC 3004
Website www.redrockgroup.com.au
We will try to deal with your complaint within 45 days. If you are unhappy with any decision or the handling of a complaint by us, you can refer your complaint to our external dispute resolution provider below. External dispute resolution is a free service established to provide you with an independent mechanism to resolve specific complaints.
External Dispute Resolution
Authority Australian Financial Complaints Authority (AFCA)
Telephone 1800 931 678
Email info@afca.org.au
Post GPO Box 3 Melbourne VIC 3001
Website www.afca.org.au