Privacy

1. We respect your privacy

1.1. At Craggle Services Pty Ltd ABN 33 676 327 272 trading as Cromeloan (“we”, “our” or “us”), we respect your right to privacy. We are committed to safeguarding your privacy. This policy sets out how we collect, store, use and disclose your personal information. It also deals with how you can make a privacy complaint, access the personal information we hold about you and have that information corrected (where necessary).

1.2. "Personal information" about you is information or an opinion about you or an individual who is reasonably identifiable as you.

1.3. “Sensitive information” is information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual orientation or practices, criminal record, health information, genetic information, or biometric information. We generally do not handle your sensitive information but if it is reasonably necessary to do so, we will first seek your consent.

1.4. By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy.

2. Collection of personal information

2.1. We will, from time to time, collect and store personal information about you, as reasonably required for our functions and activities.

2.2. The types of personal information we may collect includes:

1. basic information such as your name, telephone number, address and email address;

2. your date of birth, occupation, and employment details;

3. information about your personal affairs including your account information, your transaction history, your income and expenses, proof of earnings, your assets including the value of any security properties;

4. credit-related information such as the amount of borrowings, repayments, defaults, credit capacity and credit worthiness;

5. your product and service preferences, and other information you may provide when you test or use our products and services;

6. records of any correspondence with us including call recordings you have consented to;

7. your location (IP address) when you use our website;

8. your resume, work history and education history if you apply for a role with us, or are otherwise a potential candidate; and

9. any other information you provide while interacting with us that we think is necessary for us to provide you with the services.

2.3. We collect personal information about you in a variety of ways including when you:

1. subscribe for our waitlist;

2. subscribe for updates or other notifications from us;

3. enter your personal information into our website in the course of creating an account or using our service;

4. provide us with your bank statements;

5. make an enquiry through our website, email, social media channels or other means;

6. provide information over the phone, in person, through private messaging or other channels, or in application forms or documents;

7. make a complaint or provide other feedback;

8. change your email preferences;

9. participate in user testing or respond to surveys and/or promotions;

10. correspond with our customer support; and

11. use our website.

2.4. We may collect personal information about you that is publicly available.

2.5. We may receive personal information about you from third parties including from:

1. any of your joint account holders, prospective or current co-loan applicants or guarantors;

2. financial institutions or other organisations that you hold accounts with or that otherwise provide you with products or services;

3. our service providers (including identity verification service providers and our data aggregation service provider where you have authorised them to access and link your account information held with third party financial institutions. You acknowledge that such access may not comply with your financial institution’s terms and conditions);

4. referral partners who refer your business to us; and

5. your representatives such as your lawyer, accountant or attorney.

2.6. We may combine or link your personal information to other information held about you in our customer relationship management system (or other system or software) to improve the products and service we provide to you.

3. Use of your personal information

3.1. We may use your personal information to:

1. manage our relationship with you;

2. verify your identity;

3. assess the suitability of a product or service;

4. assist you to apply for a product or service;

5. establish and administer our services to you, including to understand your financial situation, to combine the information with information collected from external sources to personalise your experience, and to provide you with information such as comparisons, insights, and updates;

6. test, develop and improve our product and services;

7. make you aware of new and additional products, services and opportunities available to you; and

8. assess your suitability for a role and/or for recruitment purposes if you apply for a role with us.

3.2. We may send you offers, updates, articles, newsletters or other information about products and services. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us that you wish to do so. You can also request to opt-out of direct marketing offers via email, at info@cromeloan.com.au.

3.3. We may contact you in a variety of ways including, but not limited to, telephone, email, sms or mail.

3.4. The website may make third party social media features available to its users. We cannot ensure the security of any information you choose to make public in a social media feature. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy.

3.5. You may use a pseudonym (i.e. a name, term or descriptor that is different from your actual name) for some interactions with us through the website (like signing up to our wait list or mailing list). However, due to the nature of the services we provide, we will need to identify you to provide our full services including linking your account information.

4. Disclosure of your personal information

We may disclose your personal information to:

1. our professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy;

2. financial institutions or other organisations to enable you to consider or apply for products and services available from them;

3. your guarantors or other security providers;

4. to your representatives such as your lawyers and accountants;

5. third parties who provide support functions, information or infrastructure systems to us including contractors or other service providers who supply services to us, e.g. to handle mailings on our behalf, to provide analytics, to facilitate customer relationship management, sales and servicing, to verify identification, and external data storage providers;

6. other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event;

7. a court, tribunal or other body or agency where required to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request;

8. an external dispute resolution body or to your or our insurers or prospective insurers or underwriters;

9. to your current or previous employer or referees; and

10. to anyone, where you have provided us with consent.

4.2. We will take reasonable steps to ensure that any person or organisation we disclose your personal information to has a commitment to protect your information in the same way that we do, or you have consented to us making the disclosure.

4.3. Information that we collect may from time to time be stored, processed in or transferred to, organisations that provide support to us located in countries outside of Australia including United States and Germany. It may be necessary for those overseas entities to disclose your personal information under foreign law. In such case we will not be responsible for that disclosure.

4.4. We may store your information in cloud or other types of networked or electronic systems. Such servers may be located in countries other than those listed but it is not always practicable for us to know in which countries they are held.

4.5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

5. Security of your personal information

5.1. We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. We will take reasonable steps to destroy or de-identify your personal information if we receive unsolicited information that we don’t need for our functions and activities. Under law, we are required to keep certain information for certain periods.

5.2. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us.

5.3. If a data breach occurs, we will take immediate steps to assess the breach, its cause and actions required. We will comply with relevant legal requirements (including providing notification to you and regulators where relevant).

6. Access to your personal information

6.1. You may request details of personal information that we hold about you. A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at privacy@cromeloan.com.au

6.2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances.

7. Complaints about privacy

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 47 Russell Street, Abbotsford, Victoria 3067 or by email to privacy@cromeloan.com.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

8. Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website. Please check back from time to time to review our Privacy Policy.

9. Website

9.1. When you visit our website
When you come to our website (cromeloan.com.au) we may collect certain information such as browser type, operating system. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

9.2. Site usage information
We may from time to time use cookies and other tracking technologies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. We may also use the information provided by you on an anonymous basis where your personal information is not identifiable and we may use this for any purpose or share it with third parties. We may also provide this information to third parties to allow them to serve relevant advertisements to you.

9.3. Third party links
Our website may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these third parties. Please be aware that we are not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.