Your privacy is important to us

We know that how we collect, use, exchange and protect your information is important to you, and we value your trust. That’s why protecting your information and being clear about what we do with it is a vital part of our relationship with you. This Privacy Policy explains how we handle your personal and/or credit information.

This Privacy Policy covers:

  • Vertex Asset Management Pty Ltd ABN 45 623 013 892;
  • Vertex Funds Management Pty Ltd ABN 93 610 480 530;
  • Vertex Funds Management No. 2 Pty Ltd ABN 71 627 571 528,

(“the Group”).

In this Privacy Policy, “Vertex”, “us”, “we” or “our” means each member of the Group.

By providing your personal or credit information to us, you consent to us collecting, using and disclosing your personal and/or credit information in accordance with this Privacy Policy.

Please note that during the course of our relationship with you, we may tell you more about how we handle your information. This could be when you complete an application form or receive terms and conditions or an Information Memorandum. When you receive this further information, please consider it carefully.

What is personal and credit information?

Personal information is information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, email address and contact details.

Credit information is personal information that is collected in connection with a credit application. For example, this may include your identification information, default information or repayment history information.

About Vertex

Vertex provides lending, mortgage and funds management services to both investors and borrowers through the Vertex Direct Mortgage Fund and the Vertex Direct Mortgage Fund No. 2. In this Privacy Policy, “Fund” means either the Vertex Direct Mortgage Fund or the Vertex Direct Mortgage Fund No. 2. We are bound by the Australian Privacy Principles (APPs) and the credit reporting provisions under the Privacy Act, upon which this policy is based.

Information we collect

Information we collect from you

We collect and hold information about you and your interactions with us, including when you request information about the Fund, apply to invest in the Fund, apply for a loan through the Fund, use our services, phone us, meet face to face or visit our website. When you use our website or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you’ve accessed third party sites. Some of this website information is collected using cookies, which are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

Specific information we collect from you may include:

  • Identity information – including your name, address (postal or email), date of birth, telephone numbers, information about your dependents or family members.
  • Financial information – including your tax file number, bank account details, credit history and other information about your financial affairs.
  • Credit information – including type and amount of credit sought, payment information, default information, repayment history and new arrangement information (if the terms of repayment have changed).

You are not obliged to provide the personal information we request, however if you do not provide the personal or credit information requested by us, we may not be able to provide you with the requested products or services.

Information we collect from others

We collect information about you from others, such as service providers, agents, advisers, financial institutions, brokers or employers. For example, if you apply for credit, we may need to obtain a credit report from a credit reporting body. We may also collect information about you that is publicly available, for example from public registers or social media, or made available by third parties.

How do we use your information?

We collect, hold, use and disclose your information so that we can:

  • establish your identity and assess applications for our products and services;
  • price and design our products and services;
  • administer our products and services, including by maintaining the Fund and facilitating the issue of investment offers to investors through the Fund;
  • manage our relationship with you;
  • manage our risks and help identify and investigate illegal activity, such as fraud;
  • contact you, for example if we need to tell you something important;
  • conduct and improve our businesses and improve the customer experience;
  • comply with our legal obligations and assist government and law enforcement agencies or regulators;
  • provide information to representatives and advisors, including lawyers and accountants, to help us comply with legal, accounting, or security requirements;
  • resolve complaints;
  • conduct direct marketing and promotional activities; and
  • conduct any other activity related to any of the above listed purposes.

We may also collect, use and exchange your information in other ways where permitted by law or otherwise consented by you.

We will only use your information for the purposes for which it was collected (primary purposes) or a purpose related to the primary purpose, if this use would be reasonably expected by you, or otherwise, with your consent.

Direct marketing

From time to time, we may provide you with direct marketing material.  If at any time, you do not wish to receive this information any further, you may contact us with this request.

Gathering and combining data to get insights

Improvements in technology enable organisations, like us, to collect and use information to get a more integrated view of customers and provide better products and services. Vertex may combine customer information it has with information available from a wide variety of external sources (for example census or Australian Bureau of Statistics data). We are able to analyse the data in order to gain useful insights which can be used for any of the purposes mentioned earlier in this section.

Who do we exchange your information with?

Third parties

We may exchange your information with third parties where this is permitted by law or for any of the purposes mentioned in the previous section.

Third parties include:

  • service providers, for example, valuers and solicitors;
  • those to whom we outsource certain functions, for example, direct marketing, statement production, debt recovery and information technology support;
  • brokers, agents and advisers and persons acting on your behalf, for example guardians and persons holding power of attorney;
  • potential guarantors for loans facilitated through the Fund;
  • persons involved in arrangements that provide funding to us for use in the Fund, including persons who may acquire rights to our assets (for example loans), investors, advisers, trustees and rating agencies;
  • other financial institutions, for example so that we can arrange refinance or repayment of a debt;
  • auditors and insurers;
  • employers or former employers;
  • government and law enforcement agencies or regulators;
  • credit reporting bodies and credit providers;
  • entities established to help identify illegal activities and prevent fraud.

Information provided to third parties will be dealt with in accordance with that entity’s privacy policy.

Sending information overseas

We do not, and do not presently intend to, disclose any personal information to overseas recipients.  If at some point this changes in the future, we will amend this Privacy Policy and notify you of these amendments by posting an updated version of the Privacy Policy to our website www.vertexfundsmanagement.com.au.

Credit checks and credit reporting

We may disclose your personal or credit information to a credit reporting body for the purposes of the following in relation to any commercial credit provided to you:

  • undertaking a credit check in relation to an application made by you or assessing your eligibility for our products and services;
  • verifying your identity in accordance with our customer due diligence obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
  • managing any loans provided by us;
  • collecting payments that are overdue in relation to any loan provided; and
  • disclosing payment default information in relation to any loan provided.

We may disclose information to or collect information from the following credit reporting bodies whose privacy policy and contact details are available at:

Equifax Australiawww.equifax.com.au or 13 8332

  1. Equifax may include any of your personal or credit information, disclosed to it by Vertex, in reports provided to other credit providers to assist other credit providers to assess your credit worthiness.
  2. You have the right to make a request to Equifax not to use or disclose your credit reporting information:
    1. for the purposes of pre-screening of direct marketing by a credit provider; or
    2. if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
What information can we exchange with credit reporting bodies?

The information we can exchange includes your identification details, what type of loans you have, how much you’ve borrowed, whether or not you’ve met your loan payment obligations and if you have committed a serious credit infringement (such as fraud).

Keeping your information secure

We keep your information in hard-copy or electronic records on our premises and systems or offsite using trusted third parties. Our security safeguards include:

  • Staff education- We train and remind our staff of their obligations with regard to your information.
  • Third Party Security Arrangements – When we use third parties that handle or store data, we ensure that appropriate data handling and security arrangements are in place.
  • System security – When you transact with us on the internet via our website or mobile apps we encrypt data sent from your computer to our systems. We have firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing our systems. When we send your electronic data outside the Group we use dedicated secure networks or encryption. We limit access by requiring use of passwords and/or smartcards.
  • Building security – We have protection in our buildings against unauthorised access such as alarms, cameras and guards (as required).
  • Destroying data when no longer required – Where practical, we keep information only for as long as required (for example, to meet legal requirements or our internal needs).

Accessing, updating and correcting your information

Can I get access to my information?

You can ask for access to your personal and/or credit information that we hold by contacting our Privacy Officer. For more substantial information, such as details of what is recorded in your loan file, we may require you to complete and sign a written request for access to this information.

Is there a fee?

There is no fee for making the initial request, but in some cases there may be an access charge to cover the time we spend locating, compiling and explaining the information you ask for. If there is an access charge, we’ll give you an estimate up front and confirm that you’d like us to proceed. Generally, the access charge is based on an hourly rate plus any photocopying costs or other out-of-pocket expenses. You’ll need to make the payment before we start, unless you’ve authorised us to debit your account.

How long does it take to gain access to my information?

We will respond to your request for access to your information within a reasonable time after you make the request in writing. If access is granted, access will be provided within 30 days from your request. You will be provided with access to your information in a manner, as requested by you, providing it is reasonable to do so.

Before we give you the information, we will need to confirm your identity.

Can you deny or limit my request for access?

There are certain conditions under which we may refuse you access to your information or limit the access we provide. For example, we might not provide you access when giving access would unreasonably impact the privacy of other individuals. Whatever the outcome, we’ll write to you explaining our decision.

Updating your basic information

It’s important that we have your correct details, such as your current address and telephone number. You can check or update your information by phoning or emailing our Privacy Officer.

Can I correct my information?

You can request us to correct any inaccurate information we hold or have provided to others (including credit information) by contacting our Privacy Officer. We don’t charge a fee for these requests. Your request for correction will be dealt with within 30 days, or such longer period as agreed by you.

Upon accepting a request for correction of your information, we will take all steps that are reasonable in the circumstances, having regard to the purpose for which your information is held, to correct your information.

If your request for correction of credit information is accepted we will provide written notice of this correction to any entity to which we have disclosed this information previously, to the extent that this is practicable.

What if we disagree that the information should be corrected?

If we disagree with you that your information should be corrected, we’ll let you know in writing our reasons.

Making a privacy complaint

We accept that sometimes we can get things wrong. If you have a concern about your privacy (including credit-related matters), you have a right to make a complaint and we’ll do everything we can to put matters right.

How do I make a complaint?

To lodge a complaint, please contact our Privacy Officer at first instance using the contact details below. We’ll review your situation and try to resolve it straight away. If you believe we have not adequately dealt with your complaint, you may complain to the Privacy Commissioner, details of which can be found at www.oaic.gov.au.

Changes to Privacy Policy

We may change our Privacy Policy from time to time. Any amendments to this Privacy Policy will be notified to you by posting an updated version to our website www.vertexfundsmanagement.com.au.

Privacy Officer Contact Details

Our contact details are:

Name: Privacy Officer

Phone: 1800 940 901

Email:  info@nullvertexfundsmanagement.com.au

Mail: Level 1, 229B St Vincent Street, Port Adelaide SA 5015

 

Last updated: 10th September 2018