We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.
Credit information is information which is used to assess your eligibility to be provided with finance and 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.
The kinds of personal information we may collect about you include your name, date of birth, address, occupation, and any other information we made need to identify you.
If you are applying for finance we may also collect the ages and number of your dependents and cohabitants, the length of time at your current address, your employment details and earnings and expenses. If you apply for any insurance product through us we may also collect your health information. We will only collect health information from you with your consent.
We collect personal information for the purposes of providing you with a loan comparison and referral service, and for related services. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services.
Where reasonable and practical we will collect your personal information directly from you.
We may disclose your personal information:
- to prospective funders or other intermediaries in relation to your finance requirements
- to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres
- to associated businesses that may want to market products to you
- to companies that provide information and infrastructure systems to us
- to anybody who represents you, such as finance brokers, lawyers and accountants
- to anyone, where you have provided us consent
- where we are authorised to do so by law, such as under the Anti-Money or Laundering and Counter Terrorism Financing Act 2006 (Cth)
- to investors, agents or advisers, or any entity that has an interest in our business or
- organisations that provide products or services used or marketed by us.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
- the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
- you have consented to us making the disclosure.
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.
We are unlikely to disclose your personal information to overseas entities.
From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on (03) 9645 5195 or by writing to us at firstname.lastname@example.org. If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.
We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct personal information we will provide you with our reasons for not correcting the information.
We are unlikely to obtain government identifiers, such as your tax file number. However, if we do, we will not use or disclose this information other than authorised by law. We will never use a government identifier in order to identify you.
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our complaints officer on (03) 9645 5195.
We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.
If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted via the Office of the Australian Information Commissioner website (www.oaic.gov.au) or on 1300 363 992.
You may request further information about the way we manage your personal information by contacting us.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.
How do we differ from a broker?
Capital Growth offers a strong alternative to the traditional & finance broker model. All services are 100% referral based allowing you to refer your clients to licensed experts, and be rewarded with a significant share of referral commission. In addition, there is no formal training, reporting or accreditation requirements imposed on your time or business – a strong point of differentiation when compared to the growing legislative requirements now being implemented in the broker industry.
What are the costs involved?
There are no initial or ongoing fees associated with Capital Growth’s Referral Partners Program.
Do I need formal training or accreditation?
There are no formal training, reporting or accreditation requirements for clients of Capital Growth. Our services are 100% referral based and therefore by referring your clients to licensed professionals all licensing and accreditation requirements are the responsibility of the parties making formal recommendations to your clients. Our belief is that a referral based relationship will provide further value for your business as the legislative requirements on the finance broker industry undoubtedly becomes more onerous.
Are all commissions disclosed to relevant parties?
It is a legislative requirement that all commissions payable to third parties are disclosed. Commission is disclosed on two levels: Firstly, all gross commissions payable under contract from the banks to Capital Growth is disclosed in the lender’s loan offer document to the client. Secondly, as the referrer, you are required to disclose to your client that you will receive a commission from Capital Growth at the initial stage the transaction.
Are my clients dealing with licensed professionals?
A strength of our referral model is the ability for business professionals to deal directly with licensed lending and property professionals, and retain full ownership of the client throughout all stages of the transaction and thereafter. Unlike a broker associated transaction, you retain full control of the process and ensure that your clients obtain independent advice regardless of the level of commission being paid to a third party.
Are my clients profiled for cross marketing?
A significant differential with our referral based model is the strict “non compete” clause we have built into our contract for clients. A “non compete” guarantees that our panel of lenders will not market additional services such as financial planning / general insurance without prior consent from the client. This ensures that whilst the finance needs of your clients are fully serviced by our lenders, they are quarantined from unsolicited cross marketing. This differentiates from a brokerage model where banks retain the right to cross market additional products and services in order to build a closer relationship with your clients.
Who owns the income?
All trail income is owned by the referring partner for the time it remains on the lender’s books and for the period Capital Growth receives remuneration. We refer to this as an “EverGreen Clause” and the terms are clearly set out in our agreements.
How am I remunerated?
Capital Growth manages all commission reconciliation on your behalf with net commissions deposited to your nominated account prior to the 30th of each month. In addition, recipient created tax invoices and client portfolio statements are forwarded to your office each month to assist with administration and financial recording of this service.
Does Capital Growth offer the option to become an authorised Credit Representative?
Yes, Capital Growth also offers Referrers the option to obtain Credit Representative status should this suite your business requirements. For further details please speak to one of Capital Growth’s Account Manager.