Privacy Policy

1. About this Privacy Statement

We take your privacy very seriously and are committed to ensuring the protection of your personal information, no matter where you are located. Each member of the Securely Holdings Pty Ltd collects and handles your personal information in accordance with its legal obligations, including those under the Privacy Act 1988 (Cth).

The Securely Group and its subsidiaries (Securely Holdings Pty Ltd) provide or distribute a wide range of banking, finance, funds management, financial escrow and other services.

This Statement describes how your personal information and credit information is collected and handled by the Securely Holdings Pty Ltd:

2. Collection, use and sharing

2a. What information do we collect?

We collect your personal information directly from you most of the time, however on occasion, we may also collect information about you from other people and organisations.

We collect personal information when you:

enquire about, apply for, or use our products or services
contact us to make an enquiry or give us feedback
visit our website or use our digital services
participate in other activities we offer, such as competitions or surveys
talk to us or do business with us.

While we are required to collect some types of personal information to meet our legal obligations, we do attempt to keep our collection of your personal information to what is necessary to offer you the products and services you require. Depending on those products and services, or your interactions with the members of the Securely Holdings Pty Ltd, we may collect the following types of personal information:

Types of personal information

What kinds of personal information might be involved

Personal and contact details

This may include your name, address, email address, phone number, and date of birth.

Australian Government related identifiers and identity documents

These may include your:

Tax File Number and country of tax residency
Medicare card, Australian passport, driver licence, or pension card details
Security holder Reference Number (SRN) or Holder Identification Number (HIN)
Citizenship, birth, death and marriage certificates (for example, to verify your identity).

Foreign government identifiers and identity documents

This may include foreign government identity documents and identifiers such as:

tax identification number and country of tax residency
foreign passport and driver licence (for example, to verify your identity at the time you request a product or service).

Finacial Information

This may include:

details of your employment, income, assets, financial liabilities
copies of bank statements and credit card statements from other financial institutions
information from third parties about your credit history and insurance claims history.

Credit information

See Credit Reporting (Your credit information, Section 4) for the types of credit information that we collect.

Transaction information

This includes information about transactions that you have made using our products and services or in relation to Securely Holdings Pty Ltd.

This may include your marital status, age, gender, number of dependents, occupation and nationality.

Interaction information

This includes details of your interactions with us, such as when you call us, use our online services (such as Escrow Services), make an enquiry, provide feedback, or make a complaint.

Digital information

We collect information from you electronically when you use our online services.

This includes information such as:

location information (if enabled on your device)
IP address
details of the device used to access our digital services (including mobile and tablet)
details of the wi-fi network or mobile network used by your device
type of authentication used (for example touch ID or face ID.)

More information about the digital information we collect is available in the Terms and Conditions. Importantly, we do not link this information to you unless we need to access these details for fraud or security reasons.

Behavioural information

This includes information that we generate about how you use our products and services. For example, if you use our escrow services, we may generate information about your spending patterns.

Call recordings

On occasion, we monitor and record our calls with you. We will let you know if we are doing this.

Sensitive information

On occasion, we collect and handle sensitive information. This may include:

health information (where this is relevant to an insurance policy, claim or if you’re in financial difficulty and ask for hardship relief due to illness)
race or ethnicity (for example we may ask you what language you speak if you request a translator to communicate with us)
criminal history and political affiliation, where it is relevant for our regulatory and/or legal obligations
Biometric information (such as fingerprints or face), where this information is Collected and Used for the purpose of automated biometric verification or biometric identification

Publicly available information

On occasion, we may collect and handle information that is in the public domain, such as from:

online forums, websites, Facebook, Twitter, YouTube or other social media (for example, if you use social media to make a complaint)
public registers (for example, those kept by the Australian Securities and Investments Commission or Land Registry Services).

2b. What do we do with your information?

We’re careful about how we use your information to deliver our products and services. We also use your information for other reasons, such as to better understand you, your needs, and to let you know about other products and services you might be interested in.

Here is a list of the ways we may use your personal information.

Purpose

How we use your personal information

Serving you as a customer

We use your information to deliver our products and services including to:

assess and process your applications for products and services
administer and manage existing products or services you have with us
manage our relationship with you or your business
improve our service to you and your experience with us
communicate with you or your representatives about our products and services
let you know about other products and services that may be of interest to you.

Improving our business

We use your information to improve the products and services we provide through activities such as:

reviewing customer feedback and assessing how you use our products and services
testing and validating the effectiveness of products, services and system enhancements
monitoring and reviewing call recordings, online chats and other business activity for quality assurance, training and compliance purposes.

Managing our operations

We use your information to manage our operations including to:

deliver our products and services
make and manage customer payments and transactions
manage fees, charges and interest due on your products and services
collect and recover money that is owed to us
respond to complaints and seek to resolve them

Managing security, risk and crime prevention

We use your information to:

prevent, detect and investigate suspicious or fraudulent activities
investigate health and safety incidents involving our people and customers
support the management of our information security and network controls to prevent cyber-attacks, unauthorised access and other criminal or malicious activities.

To comply with our legal obligations

Where required, we use your personal information to comply with the law, including our regulatory obligations, including to:

confirm your identity
share relevant information with law enforcement agencies, tax authorities and other regulatory bodies if required
screen applications and monitor accounts to identify criminal activity such as fraud, terrorist financing, bribery, corruption and money laundering
investigate financial crime.

Managing our business

We use your information to run our business in an efficient and proper way. This includes managing our financial position, business capability and planning, testing systems and processes, as well as managing communications, corporate governance, and audit.

Performing analytics activities

Sometimes we combine information we have about you and our other customers, for example transaction information, with data from other sources, such as third party websites or the Australian Bureau of Statistics. We use this information to:

help us understand trends in customer behaviour including how products and services are used
improve the products and services we offer
improve the quality of our data
develop products and services that better meet our customers’ needs and behaviours
understand and manage our risks better.

Sales or acquisitions

We may also use your personal information to support any changes to the ownership of products or services or the make-up of the Securely Holdings Pty Ltd.

For example, we may:

sell, transfer, or merge parts of our business, or our assets, including products or services
bring other businesses into the Securely Holdings Pty Ltd
stop providing a particular product or service.

When we do this, we may share your personal information with other members of the Securely Holdings Pty Ltd or other parties involved, where appropriate.

We may also collect, use and share your information for other reasons where the law allows or requires us to.

Direct marketing

From time to time, we may also use your personal information to tell you about products and services we think may be of interest and value to you, but we will stop if you tell us to.

We may contact you by various means, including by mail, telephone, email, SMS or other electronic means, such as through social media or targeted advertising through CommBank websites or through our online banking services.

If you do not want to receive direct marketing offers from us, you can opt-out by:

updating your message preference settings in your online services
contacting us using the details in We’re here to help, Section 6a.

We may first require you to log into your sell-securely.com account or otherwise identify yourself.

2c. Who do we share your information with

We may share your information with third parties for the reasons mentioned in How do we use your information? (Collection, use & sharing, Section 2b), or where the law otherwise allows or requires us to.

The types of third parties are listed below.

Type of third party

Description

Other members of the Securely Holdings Pty Ltd

We may share your information between members of the Securely Holdings Pty Ltd. This helps us offer you a high-quality customer experience. You can read about how Securely Holdings Pty Ltd members may use your information in How do we use your information? (Collection, use & sharing, Section 2b).

Authorised Third Parties

We may share information with third parties where you have authorised us to do so or where we are legally required. They include:

third parties that you have authorised to act for you (such as accountants, financial counsellors, legal representatives, agents, mortgage brokers, financial advisors, or a person with Power of Attorney)
guarantors and other security providers.

Third Parties that can verify your information

This includes organisations that can verify information that you have supplied when applying for a product or service, or making a claim, including:

your employer, to verify your employment status
your doctor, to verify your medical history
other banks and financial institutions that you may have products and services with.
commercially available third party databases

Our Service Partners

We may share your information with our service partners, external service providers and other organisations that help us to supply products and services.

These include:

organisations that we partner with to supply products and services, for example, payment and shopping services, mortgage insurers, loyalty program partners and our product distributors.
external service providers that we engage to do some of our work for us, for example mailing houses, debt recovery agencies, legal service providers and information technology and cloud service providers.
people who help us process applications and claims (like assessors and investigators).
organisations that assist us to identify, investigate or prevent fraud or other misconduct.
Organisations that provide us with information, including publicly available information, so we can tell you about products and services we think may be of interest and value to you

Strategic Referral Partners

We may share your information, with external parties with whom Securely Holdings Pty Ltd has entered into strategic alliance or referral arrangements to enable you to inquire about the services or products they offer.

A product refers to any offering of features and benefits to a Customer.

This may include products that allow a Customer to:

facilitate payments (e.g. BPay, Eftpos or clearing and settlement facilities).

Other financial services organisation

We may collect and share your information with other banks, third party payment providers, superannuation funds and financial services providers to provide you services, for example to process your transactions, facilitate payment reversals and provide refunds.

Government and law enforcement agencies

We may share your information with regulatory bodies, government agencies and law enforcement bodies to comply with our legislative or regulatory obligations in any of the jurisdictions where we operate.

3. Securing your information

Our staff are trained in how to keep your information safe and secure. We use secure systems and buildings to hold your information. We aim to only keep your information for as long as we need it.

We store your hard copy and electronic records in secure buildings and systems or using trusted third parties. We use a range of physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal information we hold about you.

We aim to keep personal information only for as long as we need it – for example for business or legal reasons. When we no longer need information, we take reasonable steps to destroy or de-identify it.

4. Your credit information

We collect credit information about you when you apply or use our credit related products or services. We may also collect credit information about you from credit reporting bodies (such as Equifax).

What is credit information?

Types of credit-related information we collect, hold and disclose

We also collect credit information about you from third parties, including credit reporting bodies (such as Equifax) or other credit providers (such as another bank).

The types of credit information we collect and handle are set out below.

Identification information

This includes your name (including any aliases), gender, date of birth, driver licence number, current and most recent past addresses, as well as current and most recent past employers.

Consumer credit liability information

This is information about any accounts that you currently have open or may have had in the past. It includes the type of account, the open and/or close date, as well as the credit limit.

Repayment history

This includes a history of your repayments, including whether you have made payments when due, and if not, when overdue payments have been made.

Financial Hardship Information

This includes information about agreed financial hardship arrangements that you may have with us or our credit providers, both temporary and permanent. Financial hardship information will be recorded with the repayment history information.

Default information

Details of any defaults or serious credit infringements.

Public information

Public record information such as:

- court judgments
- directorship and business proprietorship details
- bankruptcy, debt agreement and personal insolvency.

Information about credit worthiness

Information about your credit worthiness such as credit scores, credit risk ratings, summaries and evaluations.

Preventing identity fraud: If you think you have been, or could be, a victim of fraud you can ask the credit reporting body not to use or give anyone your credit information.

We collect from, and share information with, the following credit reporting bodies. For more information about how they handle credit reporting information they hold about you, or about direct marketing or identity fraud, you can contact them below.

- Equifax Pty Ltd www.equifax.com.au
- Experian Australia Credit Services Pty Ltd www.experian.com.au
- Illion Australia Pty Ltd www.illion.com.au

5. Accessing your information

You can contact us and ask to view your information. For more detailed information, we may ask you to fill out a request form. If your information isn’t correct or needs updating, let us know straight away.

How will we handle you request?

There is no fee to ask for your information, but sometimes we might charge a fee to cover the time we spend gathering the information you want. If there’s a fee, we’ll let you know how much it is likely to be, so you can choose if you want to go ahead.

We try to make your information available within 30 days after you ask us for it.

In some cases, we can refuse access or only give you access to certain information. For example, we might not let you see information that involves other people. If we do this, we will write to you explaining our decision.

Can you correct or update your information?

It’s important that we have your correct details, such as your current home address, email address and phone number. You can check or update via your online services (such as sell-securely.com) or by calling us (see We’re here to help, Section 6a).

If you think your personal or credit information is incorrect, contact us to investigate the issue (see We’re here to help, Section 6a).

We’ll try to respond to your request within 30 days. If we can’t, we’ll let you know why it’s taking longer.

If we don’t think the information needs correcting, we’ll write to let you know why. You can ask us to include a statement with the information that says you believe it is inaccurate, incomplete, misleading or out of date.

6. We’re here to help

If you need more information, want to access or update your personal information or if you have a privacy concern – help is just a phone call or a few clicks away.

www.sellsecurely.com

Call 1300 781 244

What else can you do?

If you’re not satisfied with our response after you’ve been through our internal complaints process, you can lodge a dispute through the Australian Financial Complaints Authority (AFCA), our external dispute resolution provider.

AFCA provides consumers and small businesses with fair, free and independent dispute resolution for financial complaints.

Australian Financial Complaints Authority

Visit: www.afca.org.au

Email: [email protected]

Phone: 1800 931 678 (free call)

Mail: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001

You can also contact the Office of the Australian Information Commissioner if your complaint is about your privacy or how we handled your credit information.

Office of the Australian Information Commissioner

Visit: oaic.gov.au