Privacy Policy | FinanceFlow

1 · Scope and commitment

About This Privacy Policy

FinanceFlow is an Australian credit intermediary platform. We do not lend money or make lending decisions. Our role may involve collecting information about a business-finance enquiry, identifying potentially relevant pathways and connecting suitable enquiries with appropriate finance professionals.

This Privacy Policy explains FinanceFlow's usual personal-information handling practices. FinanceFlow is committed to privacy practices aligned with the Australian Privacy Principles (APPs), and where the Privacy Act 1988 (Cth) applies to us, we will comply with the obligations that apply.

This policy is separate from any privacy or collection notice presented when you submit a form, complete a survey, communicate by SMS or provide information for a particular enquiry. A collection notice may contain more specific information about that collection.

What we collect How we collect it How we use it Who we share with Access & correction Privacy complaints

2 · Information we collect

Kinds of Personal Information We May Collect and Hold

The information we collect depends on how you interact with FinanceFlow and how far an enquiry progresses.

Initial enquiry

Contact and enquiry details

This may include your name, email address, telephone number, postcode, business-finance purpose, approximate amount sought and other answers you choose to provide through our website, forms, surveys or conversations.

Business context

Business and eligibility information

Where relevant, we may collect details such as business name, ABN, trading history, turnover ranges, finance purpose, existing finance, defaults or other information relevant to understanding the enquiry.

Later-stage information

Finance and security information

If required to progress an enquiry, you may provide information about assets, proposed security, property, liabilities, financial position or supporting documents. We aim not to request this information earlier than reasonably necessary.

Website use

Technical and communications information

We may collect IP address, device and browser information, referral source, pages or features used, communication history, consent records and other technical information generated when you interact with our website or communications.

Sensitive information

FinanceFlow does not seek sensitive information unless it is reasonably necessary for a legitimate function or activity and collection is permitted by law, including where any required consent has been obtained. Please avoid providing sensitive information that is not relevant to your enquiry.

Unsolicited information

If you provide personal information we did not request, we may determine whether we could lawfully have collected it. If not, and where lawful and reasonable, we may destroy or de-identify it.

3 · Collection

How We Collect Personal Information

We usually collect personal information directly from you when you:

use the FinanceFlow website, enquiry forms, surveys or calculators;
contact us by telephone, email, SMS, web chat or social media;
respond to advertising or other communications;
provide documents or information after an initial enquiry; or
ask us to help identify a finance pathway or make an introduction.

We may also receive information from referral partners, finance professionals, service providers, advertising platforms or other third parties where they are permitted to provide it to us.

Initial FinanceFlow enquiries and credit checks

An initial FinanceFlow enquiry does not itself trigger a credit check. If you later choose to proceed with a finance professional or credit provider, that party may request consent to obtain a credit report or make other enquiries as part of its own assessment process.

Identity verification

FinanceFlow does not represent that every enquiry requires FinanceFlow itself to conduct identity verification. A finance professional, credit provider or other regulated party may need to verify identity or satisfy customer-identification requirements before providing a regulated service. Where FinanceFlow assists with collecting information for that purpose, we will explain the purpose of the collection and seek any consent required.

Anonymity and pseudonyms

You can browse much of our website without identifying yourself. However, we generally need accurate identifying and contact information to review a finance enquiry, contact you, make an introduction or respond to a privacy request.

4 · Use and purpose

How We Use Personal Information

We may use personal information for purposes including:

receiving, reviewing and administering business-finance enquiries;
understanding the purpose, timing and circumstances of an enquiry;
identifying potentially relevant mainstream, specialist or private-credit pathways;
contacting you about your enquiry and requesting further information where appropriate;
introducing suitable enquiries to finance professionals or specialist providers;
operating our website, CRM, communications, workflow and customer-support systems;
maintaining records of enquiries, introductions, consents and communications;
preventing fraud, misuse, security incidents or unlawful activity;
complying with applicable legal, regulatory, accounting or record-keeping requirements;
improving our website, processes, services and customer experience; and
sending marketing communications where permitted and subject to your communication preferences.

Automated workflows and decision-making

FinanceFlow may use software automation to record, route, organise or prioritise enquiries and communications. FinanceFlow does not make credit or lending decisions. Lending decisions, credit assessments and any regulated recommendations are made by the relevant finance professional or credit provider.

5 · Disclosure

Who We May Disclose Personal Information To

Where reasonably necessary for the purposes described in this policy, FinanceFlow may disclose personal information to:

finance professionals and credit providers — including brokers, private-credit professionals, lenders or other finance providers where an introduction may be appropriate;
specialist referral providers — where you ask for, or agree to, an introduction for a complementary business service;
technology and operational providers — including CRM, cloud hosting, communications, email, SMS, workflow, analytics, security and customer-support providers;
professional advisers — such as legal, accounting, compliance, insurance or other advisers where reasonably required;
regulators, courts, law-enforcement agencies or government bodies — where disclosure is required or authorised by law; and
a purchaser or successor — in connection with a proposed or completed sale, restructure or transfer of all or part of the business, subject to appropriate confidentiality and legal requirements.

When FinanceFlow introduces you to an independent finance professional, credit provider or specialist provider, that organisation may collect and handle information under its own privacy policy and legal obligations. You should review the relevant provider's privacy information before proceeding.

6 · Overseas processing

Overseas Disclosure and Processing

Some of the technology and communications providers FinanceFlow uses may process or store personal information outside Australia. Based on current provider disclosures, overseas processing may include the United States and India, and locations may change as service-provider infrastructure changes.

Where the Australian Privacy Principles apply to an overseas disclosure, FinanceFlow will take reasonable steps required by law in relation to the handling of that information. If you would like current information about the countries in which a particular service provider may process information, contact us using the details below.

7 · Marketing and communications

Email, SMS, Telephone and Direct Marketing

FinanceFlow may contact you about an enquiry you submitted or a service you requested. Where a communication is marketing, we will send it only where permitted by applicable law and will provide an appropriate way to opt out.

Commercial email and SMS communications will identify the sender and provide an unsubscribe mechanism as required.
You can unsubscribe from marketing email or SMS using the instructions in the message or by contacting FinanceFlow.
We will action valid marketing opt-out requests within the time required by applicable law.
Telephone marketing, where undertaken, is subject to applicable Do Not Call Register and privacy requirements.

Opting out of marketing does not prevent us from sending non-marketing communications reasonably necessary to administer an enquiry, respond to you, provide requested information or meet legal obligations.

Mobile information

SMS consent is not sold or shared for unrelated third-party marketing.

Phone numbers and SMS consent records may be provided to communications platforms and service providers only as needed to deliver messaging, maintain consent records or support requested services. We do not sell SMS opt-in data or disclose it to unrelated third parties for their own marketing.

8 · Website and cookies

Cookies, Analytics and Advertising Technologies

FinanceFlow's website may use cookies, tags, pixels and similar technologies to operate the site, remember preferences, understand website use, measure advertising performance, improve user experience and help prevent misuse.

These technologies may collect information such as IP address, browser or device details, pages viewed, interactions, approximate location derived from IP address and the website or advertisement that referred you to FinanceFlow.

We may use service providers such as analytics, advertising and social-media platforms. Those providers may process information under their own terms and privacy policies. Browser settings and platform privacy controls may allow you to restrict some cookies or tracking, although doing so can affect website functionality.

9 · Security and retention

How We Protect and Retain Personal Information

FinanceFlow takes reasonable steps to protect personal information it holds from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include access controls, authentication, secure service providers, encryption or secure transmission where supported, staff access restrictions and monitoring of systems and accounts.

No internet transmission, cloud service or storage method can be guaranteed to be completely secure.

Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or as required for legal, regulatory, tax, accounting, dispute-management, security or record-keeping purposes. When information is no longer required, we will take reasonable steps to destroy or de-identify it where required and practicable. Residual copies may remain temporarily in secure backup systems.

Data breaches

If a data breach occurs, FinanceFlow will assess and respond to it in accordance with applicable legal obligations. Where the Notifiable Data Breaches scheme applies and a breach is eligible for notification, FinanceFlow will notify affected individuals and the Office of the Australian Information Commissioner as required.

10 · Your choices and rights

Access, Correction and Privacy Choices

You may contact FinanceFlow to request access to personal information we hold about you or to ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

We may need to verify your identity before providing access or making a correction. In some circumstances, access may be refused or provided in another form where permitted by law. If that occurs, we will explain the relevant basis and available complaint mechanisms where required.

FinanceFlow does not charge a fee merely for making an access request. If applicable law permits a reasonable charge for providing access in a particular form or circumstances, we will explain that before proceeding.

You may also:

ask us to update your communication preferences;
unsubscribe from marketing communications;
ask questions about how information has been used or disclosed; and
raise a privacy complaint using the contact details below.

11 · Third-party websites and providers

Links and Independent Providers

FinanceFlow's website may link to third-party websites, finance professionals, credit providers or specialist providers. FinanceFlow is not responsible for the privacy practices of independent third parties. Their own privacy policies and collection notices apply to information they collect directly from you.

Where FinanceFlow makes an introduction, the introduction does not mean that FinanceFlow controls the third party's systems, privacy practices, lending assessment or service delivery.

12 · Complaints and contact

Privacy Questions, Access Requests and Complaints

If you have a privacy question, want to request access or correction, or believe FinanceFlow has mishandled your personal information, please contact us. We will review privacy complaints and aim to respond within a reasonable period.

Privacy / Compliance Contact

FINANCEFLOW PTY LTD
Suite 303, 17 High St, Berwick VIC 3806
Phone: 0483 916 632
Email: [email protected]

We generally ask that you first give FinanceFlow an opportunity to address a complaint. If you are not satisfied with our response and the Privacy Act applies to the matter, you may be able to make a complaint to the Office of the Australian Information Commissioner (OAIC).

13 · Policy updates

Changes to This Privacy Policy

FinanceFlow may update this Privacy Policy from time to time to reflect changes to our services, technology, information-handling practices or legal requirements. The current version will be published on this page with an updated revision date.

If a change materially affects how we handle personal information already collected, we will take any additional steps required by applicable law.