WinQuest Finance (“WinQuest”) is committed to providing exceptional customer service by offering a broad range of financial products and lending solutions tailored to our clients’ needs.

We recognise the importance of protecting your personal information and are committed to managing it responsibly. This Privacy Policy explains how we collect, use, store, disclose, and protect the personal information you provide to us.

Protecting your privacy is an important part of our business. We are dedicated to ensuring that any personal information collected by us is handled securely and only used for the purposes outlined in this policy. We want you to feel confident that your information is treated with care and respect at all times.

Our commitment to privacy includes complying with the Australian Privacy Principles contained in the Privacy Act and any other applicable privacy laws and regulations.

If you are located within a country that is part of the European Economic Area (EEA), your personal information may also be subject to the General Data Protection Regulation (GDPR) 2016/679. Under the GDPR, WinQuest acts as a data controller and determines how and why your personal information is processed.

Who is WinQuest?

WinQuest Finance is a financial services organisation operating within the mortgage and lending industry. We help clients explore suitable finance options, assess loan applications, and connect borrowers with lenders that may meet their financial requirements. We may also provide information about related products and services that may be beneficial to our clients.

By engaging our services, you authorise us to act as your representative for the purpose of obtaining credit-related information from credit reporting bodies where necessary to support your finance application. You also authorise us to provide any relevant credit information obtained to prospective lenders and financiers for the purpose of assessing your application.

Respecting your privacy

We value your privacy and are committed to protecting your personal information.

This Privacy Policy explains how we collect, store, use, disclose, and manage your personal information.

This Policy also incorporates our credit reporting practices and outlines how we manage information collected in connection with credit applications, credit facilities, and lending products. Throughout this document, this information is referred to as “credit information.”

What personal information do we collect and hold?

The types of personal information we may collect and maintain include identification details such as your name, postal address, email address, telephone number, and date of birth. We may also collect additional contact details, including social media information, financial details such as your tax file number, and any other information reasonably required to provide our services or meet our legal obligations.

Sensitive Information

Sensitive information includes details relating to a person’s racial or ethnic background, political opinions, political associations, religious beliefs, philosophical views, memberships of professional or trade associations, trade union memberships, sexual orientation or practices, criminal history, and health information.

We generally do not request sensitive information. However, if you choose to provide such information to us, it may be collected, stored, and managed in accordance with this Privacy Policy and applicable privacy legislation.

When the law authorises or requires us to collect information

In certain circumstances, we are required or authorised by law to collect personal information from you.

For example, Australian Anti-Money Laundering and Counter-Terrorism Financing legislation requires us to verify your identity before providing certain financial services. Where legislation requires us to collect personal information, we will only do so to the extent necessary to satisfy those obligations.

What do we collect via your website activity?

If you use our online services, we may monitor your interaction with our website and digital platforms to help verify your identity, communicate effectively with you, and improve the quality of our services.

If you begin an online application but do not complete or submit it, we may contact you using the details you have provided to offer assistance. Information entered into incomplete applications may be retained temporarily and securely deleted if the application is not finalised.

We also recognise that many clients choose to interact with us through social media platforms. Where you engage with us through these channels, we may collect information relevant to that interaction. For matters involving confidential information, we will take reasonable steps to communicate through secure channels.

To improve our products, services, and website security, we may collect aggregated or de-identified information from website visitors. This may include information such as IP addresses, browser data, device information, or general geographic location information.

How do we collect your personal information?

Where practical and reasonable, we will collect personal information directly from you. This information is referred to as “solicited information.”

To help us provide accurate and efficient services, it is important that the information you provide is current and up to date.

We may collect your personal information in several ways, including when you complete forms, communicate with us by telephone, submit information through our website, or correspond with us electronically. We may also use email, SMS, and other digital communication methods to verify your information and provide services to you.

How we collect your information from other sources

In some circumstances, we may collect personal information about you from third parties where permitted under the Privacy Act 1988.

We will only do so where it is reasonably necessary for the services we provide. For example, we may obtain information from third parties relating to a loan or lease application, use publicly available sources to update your contact information when we are unable to reach you directly, or exchange information with your legal representatives, financial advisers, accountants, or other authorised representatives.

What if you don’t want to provide us with your personal information?

If you choose not to provide the personal information we request, it may affect our ability to deliver the services you require.

Without the necessary information, we may be unable to:

• Provide the credit assistance or financial services you have requested
• Help identify a loan or lease product suitable for your circumstances
• Verify your identity or take steps to prevent fraudulent activity
• Comply with legal and regulatory obligations or
• Inform you about products, services, or opportunities that may be relevant to your financial needs

How we collect and hold your credit information

We collect credit-related information during the course of assessing and processing your request for credit assistance.

In addition to the methods of collection outlined above, we may obtain credit information from a variety of sources where it is reasonably necessary to do so. These sources may include:

• Joint applicants, co-borrowers, or co-signatories associated with your application
• Existing or proposed guarantors
• Your employer, accountant, property manager, real estate agent, or other referees
• Your authorised representatives, including solicitors, conveyancers, settlement agents, and referral partners
• Organisations that assist with the processing and assessment of credit applications
• Property valuers and other parties involved in assessing security offered in support of a loan
• Government agencies or organisations responsible for issuing identification documents for identity verification purposes, and
• Service providers and third-party organisations that assist us in evaluating and processing finance applications

We collect, store, and manage this information only where it is reasonably required to provide our services, assess your application, meet regulatory obligations, or facilitate your dealings with lenders and other finance providers.

What do we do when we get information we didn’t ask for?

From time to time, we may receive personal information that we did not actively request. This is referred to as unsolicited information.

When unsolicited personal information is received, we will assess whether the information is reasonably necessary for our business functions or activities. If it is relevant, we will manage the information in accordance with this Privacy Policy.

If the information is not required for our legitimate business purposes and we are not legally permitted or required to retain it, we will take reasonable steps to securely destroy the information or remove any identifying details from it.

When will we notify you that we have received your information?

When we collect personal information directly from you, we will take reasonable steps to inform you about:

• The purpose for which the information has been collected
• How the information may be used
• The organisations or individuals to whom the information may be disclosed
• How you may access or correct your information and
• How you can make a complaint regarding our handling of your personal information

There may be occasions where we obtain personal information from a third party rather than directly from you. In such circumstances, where required by law and where practical to do so, we will take reasonable steps to notify you that we have collected your information and explain the circumstances of that collection.

How do we take care of your personal information?

Protecting your personal information is a priority for WinQuest. We maintain a range of physical, electronic, and administrative safeguards designed to protect information from misuse, loss, unauthorised access, interference, alteration, or disclosure.

Some of the measures we use include:

• Secure document storage and handling procedures
• Controlled access to systems and databases containing personal information
• Identity verification processes before releasing information, and
• Ongoing monitoring and security practices designed to protect sensitive data

Your personal information may be stored in both electronic and physical formats. In some circumstances, we may engage third-party service providers to securely store or manage information on our behalf.

Where third-party providers are used, we implement appropriate contractual and security arrangements to ensure your information is protected and only used for authorised purposes consistent with this Privacy Policy.

What happens when we no longer need your information?

We retain personal information only for as long as it is required to fulfil the purposes for which it was collected, to provide our services, or to meet legal, regulatory, and compliance obligations.

When personal information is no longer required, and we are not required by law to retain it, we will take reasonable steps to securely destroy the information or permanently de-identify it so that it can no longer be associated with you.

How we use your personal information and what are the main reasons we collect, hold and use your information?

Collecting and maintaining your personal information enables us to provide the financial products, services, and support you request from us.

We may use your personal information for a range of purposes, including:

• Providing credit assistance and financial guidance
• Supplying information about loan products, finance solutions, and related services
• Assessing your eligibility for a loan, lease, or associated financial product
• Assisting you in preparing and submitting finance applications
• Managing and administering the services we provide to you, including responding to enquiries and resolving complaints, and
• Processing and administering payments associated with your loan, lease, or other financial arrangements

Can we use your information for marketing our products and services?

Yes. From time to time, we may use or disclose your personal information to inform you about products, services, promotions, or opportunities offered by WinQuest or selected third parties that may be relevant to your interests or financial circumstances.

Where required by law, we will obtain your consent before sending marketing communications. In all cases, you will be given the opportunity to opt out of receiving such communications.

With your permission, we may also share your personal information with third parties for the purpose of introducing you to businesses, services, or individuals that may be able to assist you. You may withdraw this consent at any time.

WinQuest does not sell personal information to third parties.

Yes, you can opt-out.

You may request at any time that we stop sending you direct marketing communications.

Upon receiving your request, we will take reasonable steps to remove you from our marketing lists and process your opt-out request as soon as practicable.

What are the other ways we use your information?

In addition to the purposes already described, we may use your personal information for a variety of business, operational, and compliance-related activities, including:

• Verifying your identity and personal details
• Informing you about products and services that may be relevant to your needs, unless you have requested otherwise
• Operating and managing our business efficiently
• Carrying out administrative, reporting, and record-keeping functions
• Detecting, investigating, preventing, and responding to suspected fraud, criminal activity, or misconduct
• Complying with applicable laws, regulations, industry codes, and regulatory requirements, and
• Any other purpose that you have authorised or consented to

What are the grounds which we deal with your personal information under the GDPR?

Where the GDPR applies, we must have a lawful basis for processing your personal information.

The legal grounds we may rely upon include:

• The performance of a contract or taking steps before entering into a contract with you
• Compliance with legal or regulatory obligations
• Your consent, where consent is required
• Protecting your vital interests or those of another person, and
• Pursuing our legitimate business interests, provided those interests do not override your rights and freedoms

Our legitimate interests may include:

• Fraud prevention and risk management
• Maintaining the security of our systems and services
• Conducting due diligence and compliance activities
• Improving our products and services
• Business administration and operational management, and
• Direct marketing activities where permitted by law

Who do we share your personal information with?

To provide our services effectively and meet your financial needs, it may be necessary for us to share your personal information with other parties.

We only share information where it is reasonably required for the purposes described in this Privacy Policy or where permitted or required by law.

Sharing Your Information

We may disclose your personal information to individuals, organisations, and service providers where necessary to support the products and services we provide to you.

Any information shared will be limited to what is reasonably necessary for the relevant purpose.

Sharing with your representatives and referees

We may disclose your personal information to:

• Your authorised representatives or any individual acting on your behalf, such as solicitors, accountants, settlement agents, financial advisers, or real estate professionals, and
• Referees nominated by you, including employers and other individuals who can assist us in verifying information relevant to your application.

Sharing with third parties

Where appropriate, we may share your personal information with third parties involved in providing, assessing, facilitating, or administering the services you have requested.

These third parties may include:

• Mortgage aggregators through whom loan or lease applications are submitted
• The Australian Credit Licence holder that authorises our credit activities
• Referral partners who have introduced you to our services
• Property valuers and valuation service providers
• Lenders, lessors, mortgage insurers, and finance intermediaries
• Fraud prevention and verification organisations
• Government agencies, regulators, and statutory authorities where disclosure is required or authorised by law
• Guarantors and proposed guarantors associated with your loan or lease
• Service providers, contractors, consultants, and professional advisers who support our business operations
• Organisations involved in a merger, acquisition, sale, or transfer of business assets and
• Any other person or organisation where you have provided your consent

We also engage service providers that support the finance and broking services we offer. These providers may collect, use, and manage personal information in connection with customer enquiries, complaint handling, commission administration, compliance reviews, and other operational functions.

Further details regarding how these organisations manage personal information can usually be found within their respective privacy policies.

Sharing outside of Australia

Some of the organisations and service providers with whom we share personal information may be located outside Australia, including in countries such as India and the Philippines.

Where personal information is transferred internationally, we will take reasonable steps to ensure that appropriate safeguards are in place to protect your information. Where required, we will obtain your consent or implement contractual arrangements designed to ensure that overseas recipients handle your personal information in a manner consistent with Australian privacy laws and the standards maintained by WinQuest.

Your personal information may also be stored using cloud-based or other electronic storage solutions. As these systems can be accessed from multiple jurisdictions via the internet, it is not always possible to determine the exact location where information is stored at any given time.

In some countries, overseas organisations may be legally required to disclose information under local laws or regulatory requirements. Where such disclosures occur independently of WinQuest, we are not responsible for those disclosures.

Where personal information is transferred from the European Economic Area (EEA) to a recipient outside the EEA, we will take appropriate measures to ensure an adequate level of protection is maintained. This may include the use of approved contractual safeguards or other lawful transfer mechanisms designed to protect your personal information.

How do you access your personal information?

We are committed to providing you with access to the personal information we hold about you, subject to any legal restrictions or exemptions that may apply.

You may request access to your personal information by contacting us in writing. In some situations, we may be able to process your request through a telephone enquiry.

Where reasonable and practical, we will provide access to your information in the format requested. In some circumstances, a reasonable administrative fee may apply to cover the costs associated with retrieving and providing access to your records. If a fee applies, we will inform you before processing your request.

There are circumstances where we may be unable to provide access to some or all of your personal information. Examples include where:

• Providing access could pose a serious threat to the life, health, or safety of an individual
• Access would unreasonably impact the privacy of another person
• The request is considered frivolous or vexatious
• The information is connected to existing or anticipated legal proceedings
• Disclosure may prejudice ongoing negotiations
• Providing access would be unlawful
• Disclosure could interfere with investigations into serious misconduct
• Access may prejudice the activities of a law enforcement or regulatory agency, or
• The information contains commercially sensitive or confidential business information

If we are unable to provide access in the manner requested, we will explain the reasons in writing. If you are dissatisfied with our decision, you may make a complaint using the procedures outlined in this Privacy Policy.

How do you correct your personal information?

We encourage you to contact us if you believe any personal information we hold about you is:

• Inaccurate
• Outdated
• Incomplete
• Irrelevant or
• Misleading

Where appropriate, we will take reasonable steps to correct the information and ensure our records remain accurate and up to date.

If incorrect information has been disclosed to another organisation, you may request that we notify that organisation of the correction. Where practical and appropriate, we will assist in facilitating this process.

If we are unable to make the requested correction, we will provide you with a written explanation outlining the reasons for our decision.

What additional things do we have to do to correct your credit information?

Where your request relates specifically to credit information, additional requirements may apply under credit reporting legislation.

Helping you manage corrections

Whether the error originated with us or another organisation, we are required to assist you in seeking correction of inaccurate credit information.

To investigate and process your request, we may need to communicate with credit reporting bodies, lenders, credit providers, or other relevant organisations. In many cases, the quickest way to resolve an issue is to contact the organisation responsible for the original information; however, we will provide assistance where appropriate.

Where we can’t correct information

If we determine that a correction cannot be made, we will provide written notice of our decision within five business days.

Our response will explain the reasons for the decision and provide information about available options, including access to external dispute resolution services and the Office of the Australian Information Commissioner (OAIC).

Time frame for correcting information

Where we agree that a correction is required, we will take reasonable steps to update the information within 30 days of receiving your request, or within any longer period agreed between you and us.

If we are unable to complete the correction within the required timeframe, we will:

• Notify you of the delay
• Explain the reasons for the delay
• Provide an estimated timeframe for resolution
• Request your written agreement to extend the timeframe where necessary and
• Inform you of your right to lodge a complaint with our external dispute resolution provider or the Office of the Australian Information Commissioner.

How do you generally make a complaint?

If you have concerns about how we have collected, handled, used, disclosed, or managed your personal information, we encourage you to contact us so we can investigate and address the matter.

You may contact us using the details provided below.

Privacy Complaints Officer

Name: Simon Dehne
Phone: 1300-886-100
Email: compliance@moneyquest.com.au

or

Deputy Privacy Complaints Officer

Julie Ryburn
Phone: 1300-886-100
Email: compliance@moneyquest.com.au

Mail:

WinQuest Finance Complaints Officer
PO Box 263
Flinders Lane VIC 8009

We are committed to handling complaints fairly, efficiently, and promptly. In most circumstances, we aim to acknowledge and investigate complaints within five business days.

Need more help?

If you are not satisfied with the outcome of our investigation or the way your complaint has been handled, you may refer the matter to the Australian Financial Complaints Authority (AFCA), of which WinQuest Finance is a member.

AFCA provides an independent dispute resolution service for consumers and small businesses.

Freecall: 1800 931 678

Email: info@afca.org.au

Website: www.afca.org.au

Mail: GPO Box 3 Melbourne VIC 3001

If you reside within the European Economic Area (EEA), you may also lodge a complaint with the relevant data protection authority in your country of residence or the jurisdiction where you believe your privacy rights have been affected.

For example:

Office of the UK Information Commissioner

Website: www.ico.org.uk

Phone: 0303 123 1113

Live Chat: https://ico.org.uk/global/contact-us/live-chat

What additional things do we have to do to manage your complaints about credit information?

If your complaint relates to how we handled your access and correction requests

Where your complaint concerns a request to access or correct credit information, you may choose to refer the matter directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner (OAIC). You are not required to submit the complaint to us first.

For all other complaints relating to credit information

If your complaint concerns any other aspect of how we have managed your credit information, we will acknowledge your complaint and advise you of the process we will follow to investigate and resolve the matter within seven days of receiving it.

Ask for more time if we can’t fix things in 30 days

If we are unable to resolve your complaint within 30 days, we will:

• Explain the reasons for the delay
• Provide an estimated timeframe for resolution
• Request your agreement to extend the response period where required, and
• Advise you of your right to refer the complaint to our external dispute resolution provider or the Office of the Australian Information Commissioner

Letting you know about our decision

We will provide you with a written response outlining the outcome of our investigation within 30 days, unless a longer period has been agreed upon.

If you remain dissatisfied with our decision, you may escalate your complaint to the appropriate external dispute resolution body or regulatory authority.

Your Rights under GDPR

If you are located within the European Economic Area (EEA), you may have additional rights under the General Data Protection Regulation (GDPR).

These rights may include the ability to:

• Object to the processing of your personal information
• Request that we restrict or cease processing your personal information
• Request the deletion of your personal information, subject to any legal obligations requiring us to retain it
• Withdraw consent previously provided for the processing of your information (where processing is based on consent)
• Request a copy of your personal information in an electronic format, and
• Request that your personal information be transferred to another organisation where technically feasible and legally permissible

To exercise any of these rights, please contact us using the details provided in this Privacy Policy.

If we are unable to comply with a request, we will explain the reasons for our decision and advise you of any available review or complaint options.

What do we do with government-related identifiers?

In some circumstances, we may be required to collect government-issued identifiers, such as your Tax File Number (TFN), in order to meet legal, regulatory, or operational requirements.

We will only collect, use, store, or disclose government-related identifiers where authorised or required by law, and we will take reasonable steps to ensure such information is handled securely and appropriately.

Changes to this Privacy Policy

WinQuest Finance may update or amend this Privacy Policy from time to time to reflect changes in legislation, regulatory requirements, business practices, technology, or the services we provide.

Any updates will be made available through our website and may also be communicated through email, postal correspondence, or other appropriate channels where required.

The most current version of this Privacy Policy will always be available upon request.

Contact Details

The Privacy Officer
WinQuest Finance
57 Patricia Loop
Keysborough VIC 3173

Telephone: +61 420 981 189

Email: dan@winquestfinance.com.au