1. Introduction and scope
1.1 Welcome to HomePlanner, operated by Willow Park Ventures Pty Ltd (ABN 69 672 686 985) (HomePlanner, we, us or our). Our current products and services include a property buying assistance service which includes strategic purchase planning, factual information and general financial advice, education, project management support and services introductions. These currently form our products and services.
1.2 While providing our products and services to you, HomePlanner will collect, store, use and disclose personal information. We are committed to the protection of your personal information and to compliance with applicable privacy laws. This privacy policy sets out how we collect, hold, store, use, and disclose your personal information.
1.3 Upon obtaining user consent, a snapshot of a users financial information which we have collected from a user thought the provision of the Services may be passed to a referral partners. The sharing of this data is to support the partner in providing the services they have been referred to provide. This data will be qualified as unverified and the service provider will need to independently verify this information to satisfy their regulatory and licensing requirements.
1.4 HomePlanner does not provide personalised financial advice. The information we present you with via our products and services is factual information and is based on data and information that has been linked to your Account. While we present this information in a way which is intended to provide you with useful insights, we do not provide you with any opinion or recommendation about your financial affairs and the information we provide is general information. You should always seek professional advice which takes your personal goals, objectives and circumstances into account when making financial decisions.
2. Personal informationPersonal information and/or personal data (the terms commonly used in applicable privacy laws) is information or an opinion about an identified or reasonably identifiable individual, whether or not the information or opinion is true and whether or not the information is recorded in a material form.
3. Types of personal information we collect and hold
3.1 We collect and hold personal information about individuals for the provision of our products and services and purposes connected to those products and services.
3.2 Consistent with the provision of our products and services, the types of personal information we may collect, and hold include the following:(a) Identity and contact details. Including individuals’ name, address, telephone number, email address.(b) Sociodemographic information. Including marital status, age, gender, and/or the age and number of your dependents.(c) Financial information. Including details of your past and current employment, income, assets, and financial liabilities, information about the past and current financial products you have held, your credit history and rating (including repayment and default history),and/or information included on documents to help verify your financial information (eg tax returns, payslips, statements (financial, credit card, bank, loan), and/or confirmation of your employment.(d) Payment information. Information associated with payment and card details that you use to purchase our/access to our products and services (when relevant) and Bank Account details we collect from you to pay your share of Partner referral revenues.(e) Consumer data information. To the extent that any consumer data information incorporates any personal information (please, refer to clause 5 regarding our role as a Trusted Adviser (TA) in respect of such data).(f) Other information. This includes text of written and oral communications gathered in the course of our interaction with you, including where you interact on live-chat, our website, social media, and emails, provide feedback and online reviews and other information from your interactions with us online, including information about your personal or business affairs, cookie information, IP address, URLs, search histories and other associated information.
4. How we collect and hold personal information
4.1 We may collect personal information in the following ways.(a) Directly from you. We may collect personal information directly from you, including in the course of providing our products and services, from communications via phone, email and text, your completion and submission of website and enquiry forms, as well as generally from our website and other online platforms, including by using cookies.(b) From third parties. We may collect personal information about you from third parties who you have authorised to disclose your personal information to us, including but not limited to your authorised representatives (such as your financial planners, brokers, lawyers, and/or accountants), Accredited Data Recipients who you authorize to share your personal data with us in our quality of Trusted Adviser under the Consumer Data Right scheme, your services providers and professional data aggregation providers. While your disclosure of personal information to such third parties remains governed by your relationship with that third party, including their privacy policy and/or CDR policy, our use of your personal information that we receive from them will be governed by this privacy policy.
4.2 We may also collect personal information from publicly available sources of information, including via social media channels.
4.3 Personal information is held securely, is subject to various security protections and is held only for as long as the information remains relevant to the purpose for which it was collected, unless the law requires otherwise
5. Consumer Data Right scheme
5.1 At Homeplanner we are building our platform, our data policies and processes to comply with the Consumer Data Right Scheme so that we can leverage your data in a way that benefits you. In the near future we will be working to become an Representative of an Accredited Data Recipient and therefore will be bound by the stringent compliance standards of the Consumer Data Right Scheme. For more information on the Consumer Data Right scheme, please, visit the official Australian government's website: https://www.cdr.gov.au/.
6. Purposes for which we hold, use and disclose personal information
6.1 We set out below the purposes for which we may collect, hold, use and disclose your personal information. We will not use or disclose personal information for any secondary purpose, unless that secondary purpose is related to the primary purpose for which we have collected that information, and you would reasonably expect the disclosure in the circumstances, or unless you consent to that use or disclosure.
6.2 The purposes include the following:(a) Providing our services and/or the services of a third party, to you, and undertaking our activities in relation to our products and services.(b) Enabling you to use our products and services, including creating analytics and insights using your personal information.(c) Verifying your identity and assessing your eligibility for our and/or third party products and services.(d) Communicating information about our products and services, or third party products or services that may be of interest to you.(e) To provide you with information or advertising relating to our products or services (including targeted advertisements) or marketing communications we believe may be of interest to you.(f) To improve and optimise our platforms (including our websites), products, and services.(g) To protect our legal interests and rights (including our intellectual property rights), as well as the interests and rights of our customers and third parties.(h) For our internal administrative, research, planning, marketing, and product development purposes.(i) To comply with legal and regulatory obligations, including in respect of any licences we hold, our services as a loan broker, and managing corporate governance obligations.(j) To create aggregated insights into consumer spending and wealth accumulation to support the wider users on their financial goals.6.3 We may also disclose personal information to the following third parties, as necessary for the purposes set out above.(a) Prospective funders or other intermediaries in relation to your finance requirements, including other organisations involved in administering your finances.(b) Your authorised representatives, such as your financial planners, brokers, lawyers, and/or accountants, and your trusted advisors.(c) Credit reporting bodies.(d) Third party partners who help us fulfil and deliver our products and services to you, including our employees, officers, insurers, professional advisers, agents, suppliers, partners or subcontractors.(e) Investors or entities who have an interest in investing in, and/or buying, our business.(f) Third party technology and marketing partners, including but not limited to Facebook (including for their custom audience and lookalike audience tools), Amazon Web Services and Google (including Google Analytics) and other technology and marketing service providers.(g) Any other third parties who you have provided us with consent to disclose your personal information to.
7. Links to other websites
Our website may contain links to other organisations’ information and websites. We are not responsible for the information or activities of other organisations, even if accessed via the HomePlanner website. It is recommended that you check the privacy policy of websites you visit that are linked through our website.
8. Changes to this Privacy Policy
We will review and update this privacy policy from time to time as needed without notice. Therefore, you should review the terms of this policy periodically to make sure that you are aware of how we collect, hold, store and use personal information.
9. Access and correction
9.1 We will take all reasonable steps to ensure any personal information we collect, use or disclose is up to date and accurate. If you believe personal information that we hold about you is not up to date or accurate, you may ask us to correct it.
9.2 You may ask us to provide you with details of the personal information we hold about you, and copies of that information. We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.
9.3 If we provide you with copies of the information you have requested, to the extent permitted by law, we may charge you a reasonable fee to cover the administrative costs of providing you with that information.
9.4 Please direct all request for access and correction to welcome@HomePlanner.com.au.
10. Overseas disclosure
We will not disclose or store your personal information to any overseas entities unless we obtain your prior consent to do so, in which case we will also only do so in accordance with our obligations under any applicable laws, codes and regulations.
11. Complaints
11.1 If you consider a breach of the Privacy Act 1988 (Cth) has occurred, you may direct your query to us using the details set out below and we will attempt to resolve your complaint.
11.2 If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.giv.au or by telephone on 1300 363 992.
12. Contacting us
If you have any questions about this privacy policy and would like further information, please contact us at welcome@HomePlanner.com.au.
HomePlanner, operated by Willow Park Ventures Pty Ltd (ABN 69 672 686 985)