Privacy
There’s this legislation thingy that we need to abide by. We do, and here’s how.
At HoLo (HOLO HOME LOANS PTY LTD), we are committed to protecting your privacy in accordance with the Privacy Act 1998 (Cth). This Privacy Policy describes our current policies and practices in relation to the handling and use of personal information.
About Us
HoLo is the trading name of HOLO HOME LOANS PTY LTD ACN 604 562 781. HoLo is a Credit Representative 493411 and is authorised under Australian Credit Licence 389328. In this document, ‘HoLo’, ‘we’, ‘us’ and ‘our’ are references to HoLo, HOLO HOME LOANS PTY LTD and any related bodies. We provide a range of broker services in the Financial Services industry, including services such as home loans and car finance.
Your personal information
When we refer to personal information, we mean information or an opinion from which your identity is apparent or can reasonably be ascertained. The personal information we hold about you may also include credit information. Credit information is a sub-set of personal information and is information, which is used to assess your eligibility to be provided with finance. It may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies (CRBs).
About credit information and 'Notifiable Matters'
The law requires us to advise you of ‘Notifiable Matters’ in relation to how we may use your credit information. You may request to have these notifiable matters (and our Privacy Policy) provided to you in an alternative form, such as a hard copy.
We exchange your credit information with CRBs. We use the credit information that we exchange with the CRBs to assess your creditworthiness, assess your application for finance and manage your finance. If you fail to meet your payment obligations in relation to any finance that we have arranged, or you have committed a serious credit infringement, we may disclose this information to a CRB.
You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information if needed and we explain how you can do this below. Sometimes, your credit information will be used by CRBs for ‘pre-screening’ credit offers on the request of other credit providers. You can contact the CRB at any time to request that your credit information is not used in this way.
You may contact the CRB to advise them that you believe that you may have been a victim of fraud. For 21 days after the CRB receives your notification, the CRB must not use or disclose that credit information. You can contact any of the following CRBs for more information: Dun & Bradstreet (Australia) Pty Ltd (www.dnb.com.au); Experian (www.experian.com.au) and Veda Advantage Ltd (www.veda.com.au).
Your personal information and its protection are of utmost importance to us. Personal information held by us may include your name, date of birth, current and previous addresses, telephone or mobile phone number, email address, bank details, occupation, driver’s licence number and financial details. We may hold details of your products and services (including their status) such as your home loan, car finance or superannuation provider.
If you choose not to provide certain personal information (e.g. your date of birth), we may not be able to provide you with the services you require, or the level of service on which we aim to offer.
You may need to provide personal information about other individuals to us (e.g. about your authorised representatives). If so, we rely on you to inform those individuals that you are providing their personal information to us and to advise them that we can be contacted for further information (see ‘How to contact us’ at the end of this statement).
How we collect personal information
We collect personal information in a number of ways, including: directly from you, for example, when you provide information by phone, in application forms or other agreements, or when you submit your personal details through our websites (e.g. during an application or via holo.com.au); from third parties, marketing websites, related companies, CRBs or your representatives. If we obtained your information through any of these methods and you would like a list of these entities or websites, please contact us below.
How we use your personal information
We will ask you for personal information when we assist you with your finance. We use the information you provide to advise about and assist with your credit needs. We only provide your information to the companies with whom you choose to deal (and their representatives).
Your personal information may be used to: verify your identity; assist you to gain approval or provision of a product or service; provide the services you require; administer and manage those services such as payments; inform you of ways the services provided to you could be improved or additional services that you may benefit from; conduct appropriate checks for credit-worthiness and for fraud; research and develop our services provided, either directly or referred; gain an understanding of your information and credit or financial needs in order for us to provide you with a better service.
Also, your personal information is collected so that we, and our related entities can promote and market services to you (including by way of direct mail, telemarketing, email, SMS and MMS messages). This is to keep you informed of products, services and special offers and we may continue after you cease holding an active product or service through us. If you do not wish for this to take place or continue, please contact us via Privacy@holo.com.au
When we disclose your personal information
We do not sell, trade, or rent your personal information to others. At HoLo, we want to make it super easy for you to transact on a property, as well as get access to better financial services, to assist you growing your wealth and protecting you. In order to deliver these services that you may require, we may disclose your personal information to organisations outside of HoLo. Your personal information is disclosed to these organisations only in relation to us providing our services to you, these partners may include:
BMT Tax Depreciation Pty Ltd (ACN 115 282 392) and a copy of the Privacy Policy can be found at:
We use external organisations for services
We may use external organisations for client enquiries; mailing operations; information technology services; marketing and telemarketing market research; and website usage analysis. This means we may disclose your personal information (such as name and address) to them. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
Additional disclosure to external organisations
We may also need to disclose your personal information to your authorised representatives or your legal advisers (e.g. when requested by you to do so); credit-reporting and fraud-checking agencies; credit providers (for credit related purposes such as credit-worthiness, credit rating, credit provision and financing); Australian Banks, non-bank lenders and providers of credit, financial or insurance services; our professional advisers, including our accountants, auditors and lawyers; other comparison sites, mortgage brokers or providers of investment, financial or credit where it is legal for us to do so; government and regulatory authorities and other organisations under which we are governed, such as ASIC as required or authorised by law; and organisations who manage our business, marketing and corporate strategies. Some of the above external organisations and entities may be located outside of Australia. You should note that while they will often be subject to confidentiality or privacy obligations, they may not always follow the particular requirements of Australian privacy laws. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Transfer of information overseas
In order to supply you with the best service possible and pursuant to the Australian Privacy Principles, we may transfer personal information we have collected about you to someone in a foreign country only if such transfer is permitted by the Australian Privacy Principles. HoLo may use employees based overseas, whose role is to assist with and expedite the provision of services to you. If you are: a client with an active application and; you have any concerns regarding the use of our employees based overseas; please contact us at Privacy@holo.com.au or your point of contact within our business. We do not utilise offshore personnel for the purposes of marketing or sales. We will not share any of your credit information with a credit reporting body, unless it has a business operation in Australia.
Sensitive information
Sensitive information is any information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information. We may seek, collect, use or disclose sensitive information about you but only if that sensitive information relates directly to our ability to arrange or provide credit to you or manage the credit provided to you (including, for example, assessing hardship applications and collecting overdue payments).
Sharing with a Credit Reporting Body (CRB)
HoLo will disclose information about you to a CRB when you are applying for credit, you have obtained credit from us, or if you guarantee or are considering guaranteeing the obligations of another person to us. When we give your information to a CRB, it may be included in reports that the CRB gives other organisations (such as other lenders) to help them assess your credit worthiness. Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get credit from other lenders.
Cookies and Web Beacons
Cookies
We use cookies on our website to provide you with a better experience. When you visit the HoLo website or related landing pages to read, browse, submit or download information, our system will record/log your IP address, date and time of your visit to our site, the pages viewed and any information downloaded. We may automatically collect non-personal information about you such as the site from which you linked to our websites. We do not personally identify you by this information. You can configure your browser to refuse cookies or delete existing cookies from your hard drive. Rejecting cookies may have the effect of limiting access to or functionality of parts of our website.
Web Beacons
A web beacon is typically a transparent graphic image invisible to the user that is placed on a website. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel. We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and “advertising/marketing personalisation”. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing third party networks and websites (Third Party Websites) such as Google and Facebook.
Information from third parties
Our website may contain links to Third Party Websites (e.g. third party providers of goods and services). If you accessed Third Party Websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties. Where you access a Third Party Website from our website, cookie and web beacon information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
Advertising and tracking
We may advertise on Third Party Websites. When you view our advertisements on Third Party Websites, the advertising company may use cookies, and in some cases, web beacons, to collect information such as the server your computer is logged onto, your browser type, the date and time of your visit and the performance of their marketing efforts. When you access our website after viewing one of our advertisements on a Third Party Website, the advertising company may collect information on how you utilise our website (e.g. which pages you view) and whether you commenced or completed an online application.
We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you or others provided to us.
If you wish to make any changes to your personal information, please contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete. You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable period and we will give access in the manner you have requested if it is reasonable to do so. We may charge you a fee to access the information. The fee will not be excessive and will not apply to the making of the request. We may deny you access to your personal information in certain circumstances, for example, if required or authorised by or under an Australian law or a court/tribunal order, or it would be likely to prejudice enforcement related activities by an enforcement body. If we decide not to give you access, we will provide reasons for the refusal and information on how you can complain about the refusal.
What if you don’t provide some information to us?
If you don’t provide us with full information, we can’t properly advise or assist you with your credit needs.
How do we hold and protect your information? We strive to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We hold the information we collect from you, which is held electronically within our Aggregator’s operating system or our system. We ensure that your information is safe by confirming annually that our Aggregator’s information security practices remain consistent with world class good practice; and the connection to our site is encrypted and authenticated using a strong protocols, a strong key exchange and a strong cipher.
Storage and security
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are: confidentiality requirements of our employees; document storage security policies; security measures for access to our systems; only giving access to personal information to a person who is verified to be able to receive that information; control of access to our buildings; and electronic security systems, such as firewalls and data encryption on our websites. We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from anywhere via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed here or those we referred to from time. In addition to the above, we also regularly review developments in security and encryption technologies.
However, it is important to remember that the use of email and the internet may not always be secure, even with these safeguards in place. When we no longer require your information, and we are legally permitted to, we take reasonable steps to destroy or de-identify the information. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in our privacy policy.
Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our credit licensee e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, re-organisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.
We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate. If you wish to access or correct your personal information, please write to the Privacy Officer at Privacy@holo.com.au. We do not charge for receiving a request for access to personal information or for complying with a correction request. We do not charge for providing access to personal information.
Compliments
Our representatives are always delighted to know that they have succeeded in making your experience a pleasant and successful one. If one of our representatives has provided you with exceptional service in any way, please let us know so that we can tell them, by contacting us at sayholo@holo.com.au
Concerns
If, for any reason, you do not feel that you have received the highest standard of care from us, we encourage you to share this with us. We would like to address your concerns as quickly as possible, so please contact us as at sayholo@holo.com.au and please make sure you provide as much detail as possible about your concern.
Complaints
We welcome your questions and comments about privacy. If you have any concerns or complaints, please let us know because if we don’t know about it we can’t fix it. You can provide any feedback by contacting us at:
Managing Director
HoLo
2/42 Clarence Street, Coorparoo, QLD 4151
Email Privacy@holo.com.au
Please explain the details of your complaint clearly. When we receive a complaint, we will attempt to resolve it promptly. By giving us as much information as possible, you will help us resolve things faster. We will acknowledge receipt of your complaint within one business day of it being sent. Additionally, if you have any supporting documentation, please have it handy when you raise your concern. Most complaints are resolved quickly and you should receive a full response within five business days. You may request further information about the way we manage your personal information by contacting us.
Need an update on your complaint?
If you have lodged a complaint with us, you can contact us at any time to ask for an update on its status. Contact us through any of the methods listed above and please be sure to refer to your earlier communication so that we can respond effectively.
Resolution
We will try to deal with your complaint on the spot. However, if this is not possible, we will write to you to acknowledge your complaint within 5 days. We will ensure we treat you fairly and will work to resolve your complaint as soon as possible. In the rare event we are still investigating your complaint after 45 days, we will write to you to explain why and to let you know when we expect to have completed our investigation. When we have completed our investigation we will write to let you know the outcome and the reasons for our decision.
Taking it further
We hope that you will be satisfied with how we deal with your complaint. However, if your concerns remain unresolved, or you have not heard from us within 45 days, then you can have your complaint heard by an independent party, Australian Financial Complaints Authority (AFCA). You can contact AFCA at:
Phone 1800 931 678 (local call cost)
Address Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001
Website www.afca.org.au
We’d love to hear any questions or comments you have about HoLo, so please drop us a note at sayholo@holo.com.au
Change within our privacy policy
We are constantly reviewing all of our policy and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices. As a consequence, we may change this privacy policy from time to time or as the need arises.