Terms + Conditions
Bromleigh Capital Pty Ltd
Privacy policy
This is the Privacy Policy of Bromleigh Capital Australia Pty Ltd ACN 629 265 578 (Bromleigh). Bromleigh is committed to ensuring the privacy of your personal information and is bound by the Australian Privacy Principles contained in the Privacy Act 1988(Cth) (Privacy Act). Our handling of personal credit information is also subject to the Privacy Act and the Privacy (Credit Reporting) Code 2014.
This Privacy Policy is relevant to your dealings with Bromleigh and to your use of the Bromleigh website at www.Bromleigh.com.au. The Policy sets out how we manage your personal information and, if applicable, your personal credit information. The Website is owned and operated by Bromleigh, and is used by Bromleigh to facilitate the provision of our business loan products and related services.
In this Privacy Policy, a reference to “we” or “us” is a reference to Bromleigh.
This Privacy Policy details how we collect, handle and deal with personal information (including credit information) that we collect about individuals.
If you have any questions relating to this Privacy Policy, you may contact our Privacy Officer in the manner described below, under the heading “Access and correction”.
Collection of personal information
The personal information that we collect about an individual will usually depend upon the products or services that are being provided, or that may be provided. That product or service may be provide to you or to another person connected to you. The information we may collect about you, where you are an individual, may include some or all of the following:
your name, address, date of birth and contact details;
your business name;
your e-mail address;
your tax file number;
your unique identifiers, such as user name, password and IP address;
information from personal identification documents;
information required for identity verification purposes;
details about your financial situation, which may include information about your assets, expenses and any debts you may have (including by the collection of bank statements, credit report information and payments history);
details of any securities you have given to us or another person;
information about your business, including its size and business type; and
details of specified transactions with which you are involved.
We may also process consumer credit-related personal information about a customer to develop a credit rating or score, which assists us in our assessment of a customer’s credit worthiness.
From time to time, we may reach out to you to request additional or updated information, for example, where you wish to take out a new loan or to vary an existing loan, or where we otherwise need such information to better allow us to provide our products and services.
Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
Before Bromleigh provides a product or service to you, or to a person connected with you, we may (where you are an individual) be required to collect your personal information. We may be required to do this in order for Bromleigh to comply with its customer identification obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AMLCTF Act).
The personal information we collect for this purpose typically includes identification information, such as name, residential address and date of birth. In some cases, we may need to collect information about the political activities and opinions of individuals to determine whether they are politically exposed persons for the purposes of the AMLCTF Act. If we ask for this information, and you provide it to us, we will infer your consent to use and disclose the information for this purpose.
In certain circumstances, we may need to clarify and/or update the personal information we previously collected for identity verification purposes, and/or collect further information, including financial information about individuals. Where this is necessary, we will collect the information directly from you and/or from third party sources.
As a part of our AMLCTF verification processes we may need to take copies of your personal identification documents in order to verify your identity in accordance with the requirements of that Act.
We may also disclose your full name, residential address and date of birth to a credit reporting body for the purpose of providing an assessment of whether this identification information matches (wholly or in partly) personal information held by the credit reporting body. The credit reporting body may compare your details with personal information held by the body (being the names, residential address and dates of birth of other individuals) for the purposes of making this assessment.
You have the right to:
let us know by email at contact@Bromleigh.com.au if you do not want us to disclose your personal information to a credit reporting body for this purpose; and
opt for an alternative means of verifying your identity for the purposes of the AMLCTF Act.
How we collect personal information
In most instances, we will collect information about you:
from an application form completed by you or by a person connected to you;
from information provide to us by you or by person seeking finance from Bromleigh (including through the Website or our mobile application (Mobile App);
from information you otherwise provide to us, or our agents;
from information and referrals provided by our business partners;
from conducting site visits to obtain information;
from external data providers used by lenders, for example, credit reporting agencies or other credit providers, as well as other vendors and social media;
by our accessing public databases, such as those maintained by the Australian Securities and Investment Commission;
by us seeking verification information in relation to your identity from a third party, such as Veda Advantage Information Services and Solutions Ltd;
by our obtaining other information from third party commercial and business information providers;
by email request to you; and/or
by telephone contact with you.
We will normally collect your personal information directly from you, unless it is unreasonable or impractical to do so. We may collect information from you electronically from our Website and Mobile App. This information collected through our Website or Mobile App may include internet protocol addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.
We will not collect sensitive information about you without your consent except where we are authorised or required to do so by law.
Uses and disclosure of personal information
We will only use or disclose personal information we collect about you:
for the purpose for which it was collected;
for related purposes for which you would reasonably expect us to use or disclose the information;
for marketing purposes, where we are permitted by law to do so;
where you have consented to us using or disclosing the information; or
where we are required or otherwise permitted to do so by law.
We may use your personal information to:
identify you, conduct appropriate due diligence, or establish your tax status under any Australian or foreign legislation, regulation or treaty or pursuant to an agreement with any tax authority;
assess and process your request and application for a financial product or service;
assess and process a request for the provision of a financial product or service to a person or entity connected with you;
assess your suitability as a guarantor or potential guarantor;
operate, maintain, improve and provide a financial product or service to you, or a person or entity connected with you;
open and maintain a business loan account for you, or the account of a person or entity connected with you;
complete and manage our transactions with you, including by deducting periodic payments due;
communicate with you to send confirmations and to send account update notifications;
manage our relationship with you, or a person or entity connected with you and respond to customer requests;
help us to assess products that may suit your financial needs or the needs of a person or entity connected with you;
send marketing communications and notify you of any products that may be of interest to you or a person or entity connected with you;
audit and monitor the services we provide to you or a person or entity connected with you;
assist us to perform administrative or operational task (including risk management, systems development and testing, credit scoring, staff training and customer research);
investigate, identify or prevent any actual or suspected fraud or unlawful activity;
update the personal information we hold about you or the files of a person or entity connected with you;
enable us to meet our obligations under law, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or under Australian taxation laws;
post and review your comments on our blog, where you request us to do so; and/or
produce data analytics and reports containing anonymised summaries derived from personal information and other information that is not personal information (General Information) that we may then share with business partners. (General Information may include personal information that has been aggregated, anonymized and that will not identify you.)
We may disclose your personal information to:
our related companies;
our business partners, service providers, subsidiaries and affiliates that are assisting in the review or processing of a credit application with which you are connected, or with the provision of our services, such as by providing data storage and other similar services;
our agents, the person who introduced you to us, contractors or other third party service providers, to enable them to provide administrative and other support services to us;
credit reporting bodies;
other credit providers;
other financial institutions in connection with a credit application with which you are connected or in connect with your dealings with us;
your authorised agents or your executor, administrator or legal representative; and
government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes.
people with or considering acquiring an interest in our business or assets.
While we may use third party service providers to maintain some of our data systems and provide auxiliary services, these entities are authorised to use your personal information only as necessary to provide these types of services to us. We require any person that has access to personal information that we have collected must act in a manner consistent with our obligations under the Privacy Act and with our general privacy standards.
Data sharing with our business partners
We may share personal information (including credit-related personal information) and business-related information with our business partners with whom you have an existing business relationship. Our business partners refer your details to us for the purpose of inviting you to apply for a business loan. If you apply for a loan, we will disclose certain personal information (including credit-related personal information) and business-related information to the relevant business partner. The information we disclose to the business partner is collected by us in the course of the application process, and in servicing your loan.
Our business partners use this information for the purposes of internal reporting, assessing and improving the customer experience, and for marketing and promotional activities.
The types of information we typically share with the relevant business include the following:
the name of your business and contact details;
whether we approved or declined your loan, the loan amount and term;
your assets reported, liabilities, and turnover; and
details about failed or late payments, and arrears.
For further information about the information we share with our business partners, please contact us using the contact details on our website.
Overseas disclosures
We may disclose your personal information to our business partners, service providers and subsidiaries and affiliates who are located overseas and/or do not carry on business in Australia in order to assist us in delivering our products and services to you, such as providing customer service, processing credit checks or securing data storage and other similar services.
Where we do so, we will do so in compliance with applicable laws. It is likely that such disclosures will be made to persons in countries including the United States of America.
Credit reporting – Notifiable matters
While we do not provide our customers with consumer credit, we may use a customer’s consumer credit information to assist us in assessing an application for commercial credit, or an application to act as guarantor in relation to such credit. To this end, we may disclose personal information to, or collect personal information, from a credit reporting body. The credit reporting body to which we disclose the information will include this information in reports that are made available to other credit providers to assist them to assess an individual’s credit worthiness.
The credit reporting bodies from which we collect, and to which we disclose, credit information include Veda Advantage Information Services and Solutions Ltd (Veda) and Dunn & Bradstreet (Australia) Pty Ltd (D&B). For contact details and information as to how these bodies manage credit information, please see their privacy policies and credit reporting policies, available here:
Veda: www.veda.com.au
D&B: www.dnb.com.au
You can ask these credit reporting bodies not to:
use or disclose your credit reporting information for a period if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud; and
use your credit reporting information for the purposes of pre-screening of direct marketing by a credit provider.
Bromleigh does not use credit related personal information for the purposes of direct marketing our products or services to individuals.
Access and correction
We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date. You may, at any time, request access to personal information (including your personal credit information) that we hold about you and, if there is an error (or our information about you is incomplete, inaccurate or out of date), you can advise us about this matter and we will, if needed, correct, amend or add to the information we hold about you.
We will not charge you a fee for your access request, but may charge you the reasonable cost of processing your request, including so as to allow us to provide you with access to your personal information.
If you would like to request access to the information that Bromleigh holds about you, please contact our Privacy Officer c/- Customer Support at: contact@bromleigh.com.au or by contacting us by postal mail at the contact address listed below. We will respond to your request within 30 business days. We will retain your information for as long as your account is active or as long as reasonably useful for commercial purposes.
Marketing and option to opt out
Bromleigh may contact you to offer you products and services that may be of interest to you. You may choose to stop receiving our marketing material and telephone solicitations or other forms of contact from Bromleigh by following the unsubscribe instructions included in our emails or by contacting us by email at contact@bromleigh.com.au (and including your full name and business mailing email addresses and account number) or by postal mail to us at the following address:
Bromleigh Capital Pty Ltd
10.41 Tintern Av, Toorak VIC 3142
You may also opt-out from continuing to share any personal information that you have provide on our Website for public display, such as through contributions to publicly accessible blogs or community forums and testimonials on the Website. You may do this by contacting us on the email address provided above.
Concerns or breaches
Bromleigh takes the security of your information very seriously.
If you have a complaint about our treatment or our records of your personal information, please contact our Privacy Officer (using the contact details provided above). Our Privacy Officer will investigate your complaint and endeavour to resolve any issue to your satisfaction.
If we do not adequately answer your concerns, you have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the Privacy Act, the Australian Privacy Principles, or the Privacy (Credit Reporting) Code 2014(or other applicable code). Complaints to the OAIC must be made in writing.
Further information about making a complaint to the OAIC can be found at:
http://www.oaic.gov.au/privacy/making-a-privacy-complaint
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email or by means of a notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Tracking Technologies
Technologies such as cookies, beacons, tags and scripts are used by Bromleigh and our partners (for example, our marketing partners), affiliates, or analytics or service providers, including our live chat, marketing trackers, and survey tool service providers. These technologies are used in analysing trends, administering the Website, tracking users’ movements around the Website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies for user authentication and analytics. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Website, but your ability to use some features or areas of our Website may be limited. If you would like to learn more about cookies or how to configure your browser, please visit www.allaboutcookies.org.
Log Files
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve marketing, analytics, and Website functionality.
Behavioural Advertising/Re-Targeting
We partner with third parties to display advertising on our Website and manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being presented with advertisements. You will continue to be presented with generic advertisements.
Security of Information
Bromleigh takes the security of your information very seriously. Bromleigh protects your information using bank-level data security: 128 bit-encryption and a Secure Sockets Layer (SSL) protocol. This creates an encrypted connection between your browser and our servers. When you enter Sensitive Personal Information (such as a credit card number) on our order forms, we encrypt the transmission of that information. If you allow Bromleigh to see your banking information online rather than in paper form, it is on a read-only basis. We do not have access to change, edit, or modify bank account information in any way. Bromleigh employees cannot view your banking username and passwords, and we securely store them in separate encrypted areas with our financial services providers.
Additional Information – Links to third party sites
Our Website includes links to other websites whose privacy practices may differ from those of Bromleigh. If you submit personal information to any of those sites, your information is governed by their privacy policies and practices. We encourage you to carefully read the privacy policy of any website you visit.
Blog/Forum
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us by email at contact@bromleigh.com.au or by postal mail at the contact information listed above. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
How we hold personal information
We take reasonable steps to ensure that the personal information we collect is protected from loss, misuse and interference, and from unauthorised access, modification or disclosure. The information we collect about individuals will be stored in electronic files and hosted in the United States by our parent company, Bromleigh Capital, Inc. We use a range of physical and electronic security measures, such as access restrictions, to secure the personal information we hold. We also train our employees to keep our customers’ personal information confidential.
contact@bromleigh.com.au
Testimonials
We display personal testimonials of satisfied customers on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us by email at contact@bromleigh.com.au or by postal mail at the contact information listed below.
Social Media Widgets
Our Website includes social media features, such as the Facebook “Like” button. These features may collect your IP address, which pages you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.