Circle Finance Pty Ltd ACN 624 683 245 (“Circle Finance”, “we”, “us”) is a Credit Representative (507534) of BLSSA Pty Ltd ACN 117 651 760, Australian Credit Licence 391237. We respect your privacy and handle your personal information in line with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and, where it applies, the credit reporting provisions in Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code.

This policy explains what we collect, why we collect it, who we share it with and how you can access, correct or complain about it.

What information we collect

To help you find and apply for finance, we need to understand your circumstances. Depending on the service, we may collect:

Identity and contact details: name, date of birth, address, phone number, email and identification documents such as a driver licence or passport.
Financial information: income, employment, assets, liabilities, living expenses, bank statements, tax returns and business financial statements.
Credit information: your credit history, credit reports and credit scores, repayment history, defaults and existing credit accounts.
Property and asset details: information about the property, vehicle or equipment you want to buy or refinance.
Other information you choose to share: for example details of dependants, residency status or circumstances that affect your ability to repay.

We may also collect sensitive information, such as health information, where it’s relevant to your application (for example if you’re applying for hardship assistance). We only collect sensitive information with your consent.

We only collect what we need for the purposes set out in this policy. If you don’t provide the information we ask for, we may not be able to help you, or a lender may not be able to assess your application.

Identity documents

To confirm who you are, we collect or sight documents such as your driver licence, passport, Medicare card, visa or work rights documents and birth certificate. We use them only to verify your identity, and as lenders require, not as our own customer reference number. We keep them no longer than we need to and protect them in the same way as the rest of your information.

Dealing with us anonymously

You can ask us general questions, or read our website, without telling us who you are. To arrange finance, though, we need to know who you are: lenders require it, and the law requires us to verify your identity and keep records.

Why we collect it

We collect, hold and use your information to:

understand your needs and objectives and assess which loans may suit you
meet our obligations under the National Consumer Credit Protection Act 2009, including our responsible lending and best interests obligations
prepare and submit applications to lenders on your behalf and manage your loan through to settlement
verify your identity, including under anti-money laundering and counter-terrorism financing laws
review your loan over time and contact you about your finance
handle enquiries and complaints, and meet our legal, regulatory and record-keeping obligations.

We also use information for internal reporting and to improve our services, where that’s related to why we collected it and you would reasonably expect it. We don’t use your information for an unrelated purpose without asking you first, unless the law requires or allows it.

How we collect it

We collect most information directly from you, for example through our website enquiry forms, by phone, by email, in meetings and through secure document upload tools.

With your consent, we may also collect information from third parties, including lenders, credit reporting bodies, your employer or accountant, valuers, other professional advisers you nominate, and identity verification services. We don’t obtain credit reports ourselves. When you apply, the lender obtains your credit report from a credit reporting body such as Equifax, Experian or illion.

You can ask us where we got your personal information, and we’ll tell you unless it’s unreasonable or impracticable to do so.

Referring you to other professionals

Sometimes the help you need isn’t something we provide, such as financial advice, conveyancing or legal services. In that case we may refer you to a professional who can help. We ask you first, and we only pass on your details once you’ve agreed, and only what’s needed for the referral. How that professional then handles your information is governed by their own privacy policy, not this one.

If we receive a fee or other benefit for a referral, we’ll tell you before anything is passed on. You’re always free to use someone else, and it doesn’t affect your loan.

Who we disclose it to

We only disclose your information for the purposes described in this policy, or as otherwise permitted by law. This may include:

lenders and credit providers on our panel to whom you’ve asked us to submit an application
our licensee BLSSA Pty Ltd and its aggregator, Plan Australia, which provides our systems and oversees our compliance
credit reporting bodies, valuers, lenders mortgage insurers and identity verification providers
service providers who help us run our business, such as IT, cloud storage, CRM and document management providers
professional advisers you’ve authorised, such as your accountant, solicitor or conveyancer
professionals we refer you to, such as financial advisers, conveyancers or lawyers, only where you’ve agreed
regulators, courts and government agencies where we’re required or authorised by law, and the Australian Financial Complaints Authority (AFCA) if you lodge a complaint.

We require anyone who handles personal information for us to protect it and use it only for the purpose we gave it to them. We don’t sell or rent your personal information.

Where an Australian law, court or tribunal requires or authorises us to disclose information, for example under a subpoena, warrant or regulator’s notice, we disclose only what is required and, where we’re allowed to, we’ll tell you.

Overseas disclosure

Some of our back-office administration is carried out by support staff in the Philippines, engaged through an Australian-based talent sourcing business. These staff may access your personal information to help us prepare and manage your application. We take reasonable steps to make sure they handle your information in line with the Australian Privacy Principles, including confidentiality obligations and access only to the systems they need.

Some of the service providers we use may also hold information outside Australia:

Email delivery: enquiries you send through our website are delivered by email through Resend, which processes them in Japan.
Cloud storage and software: our CRM and cloud storage providers (Google Drive, Dropbox and OneDrive) may store information in other countries.
AI tools: see “AI tools” below.
Website analytics: Google Analytics data may be stored outside Australia, as explained below.

Before disclosing information overseas, we take reasonable steps to make sure the recipient handles it consistently with the Australian Privacy Principles.

AI tools

We use AI tools to help with some of our work. Where we do, the information we put in may be sent to the provider of that tool, which may hold it outside Australia. This can include your emails or messages and our notes. We don’t record calls or meetings, or use AI to transcribe them.

Marketing and how to opt out

If you’ve agreed, we may send you occasional updates about our services by email, SMS, phone, post, messaging apps or our social media accounts. We don’t use pre-ticked consent boxes.

Every email or SMS identifies us and includes a way to unsubscribe, as the Spam Act 2003 requires. Where we call you, the Do Not Call Register Act 2006 applies. You can also opt out at any time by contacting us, and we’ll action it promptly, and within 30 days at the latest.

Reviews and testimonials

We publish testimonials clients have given us, and display reviews and ratings from sites such as Google and Facebook. We ask your permission before we publish anything that identifies you. You can ask us to take down anything we’ve published that identifies you. Where a review is on a platform we don’t control, we’ll remove our copy and tell you what we can’t remove.

Your information on our website

You can read our website without telling us who you are. Our website collects information you submit through enquiry and contact forms.

Like any website, ours also records technical information about each visit, such as your IP address, browser and device type, the pages you viewed, the date and time, and the site you came from. On its own this usually doesn’t identify you, and we don’t try to work out who you are from it. We use it to keep the site working and secure.

We also use cookies:

Essential cookies help the site work and remember your cookie choice.
Analytics cookies (Google Analytics 4) are only used if you accept them through our cookie banner. They help us understand how the site is used, such as which pages are visited. We don’t send your name, email, phone number or other personal details to Google Analytics.

You can change your choice at any time using the “Cookie settings” link in the website footer. See our Cookie notice for more detail.

Our calculators and automated decisions

Our online calculators, such as the repayments, stamp duty and borrowing power calculators, work automatically in your browser. The figures you enter are not sent to us or stored by us, and we can’t see them. If you accept analytics cookies, we may record that a calculator was used, but not the figures you entered.

Calculator results are estimates only. They are not a quote, an offer of credit or a decision about whether you can borrow. If you talk to us about your finance, Jenny personally reviews your actual circumstances and figures before recommending any loan. We don’t use automated systems to make decisions about you.

Lenders make their own credit decisions, and some use automated systems, such as credit scoring, to help them. You can ask the lender how they assess your application.

We have accounts on Facebook, Instagram and LinkedIn, and you can message us through apps such as WhatsApp and Messenger. When you message us, comment, review us or otherwise interact with those accounts, we receive the information you provide and whatever your profile shows publicly. Each platform collects information about you under its own privacy policy, which we don’t control. If you’d rather not deal with us through a platform, you’re welcome to phone or email us instead.

Contacts at other businesses

We also hold contact details for people at other businesses we work with, such as lenders, the professionals we refer clients to and contractors we engage. This is usually a name, job title, work email and phone number, collected directly from the person. We use it to run the working relationship, not to market unrelated products. Everything in this policy, including access, correction and complaints, applies to that information too.

How we keep it secure

We take reasonable steps to protect your information from misuse, interference, loss and unauthorised access, change or disclosure. These steps include separate logins for each person, two-factor authentication, encrypted document handling, staff training and restricting access to the few people who need it. No system is completely safe from every risk, and we review how we hold information as our business changes.

We keep records for as long as we need them for our services and to meet our legal obligations, which for credit-related records is generally at least seven years. When information is no longer needed, we securely destroy or de-identify it.

If we suspect a data breach, we assess it promptly, and within 30 days, and take steps to contain it. If a breach is likely to cause serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable, as required under the Notifiable Data Breaches scheme.

Access, correction and deletion

You can ask to access the personal information we hold about you, or ask us to correct it if it’s inaccurate, out of date, incomplete, irrelevant or misleading. You don’t need to give a reason. Contact us using the details below. Before we give you access, we’ll confirm who you are, often just by checking a couple of details we already hold. We’ll respond within a reasonable time, usually within 30 days, and tell you if we need longer.

We don’t charge for making a request or for correcting your information. In limited cases we may charge a reasonable fee for providing access, and we’ll tell you the cost before we go ahead.

If we’ve already given incorrect information to someone else, you can ask us to tell them about the correction. If we disagree that something is wrong, we’ll explain why in writing, and you can ask us to attach a statement to the record saying why you believe it’s incorrect. If we refuse a request, we’ll explain why in writing and tell you how to complain.

You can also ask us to delete your information. We’ll delete what we’re not required to keep. Some records, such as credit, tax and anti-money laundering records, must be kept for a set period. Where that applies, we’ll tell you what we’re keeping, why and for how long.

If your request relates to credit information held by a lender or a credit reporting body, we can help you contact them.

Complaints

If you have a concern about how we’ve handled your information, please contact us first so we can try to fix it. We’ll acknowledge your complaint within one business day where practicable and aim to resolve it within 30 days. Our Complaints page explains the process.

If you’re not satisfied with our response, you can contact:

Office of the Australian Information Commissioner (OAIC): oaic.gov.au, phone 1300 363 992, GPO Box 5288, Sydney NSW 2001.
Australian Financial Complaints Authority (AFCA), for privacy complaints connected to credit assistance: afca.org.au, phone 1800 931 678.

How to contact us

Privacy Officer, Circle Finance Pty Ltd

Phone: 0421 066 065
Email: [email protected]

Collection notice for enquiries

When you send us an enquiry through our website, by phone or by email, we collect your name, contact details and the information you choose to share about your finance needs. We use it to respond to your enquiry and, if you go ahead, to provide credit assistance. We won’t share it with a lender or anyone else without your agreement, except where required by law. If you don’t provide your contact details, we won’t be able to reply. You can read how we handle, store and secure your information, and how to access, correct or complain about it, in the sections above.

Changes to this policy

We review this policy at least once a year, and whenever our business changes in a way that affects how we handle personal information. The current version will always be on our website, with the date it was last updated.

Privacy Policy and Collection Notice