Privacy Policy

This policy describes how your personal information is handled by Unloan.

About Unloan

Unloan is a division of the Commonwealth Bank of Australia (CBA) which along with other CBA divisions and subsidiaries (the CommBank Group) provide or distribute banking, finance, insurance, funds management, financial planning and advice, superannuation, stockbroking and other services. The Group includes Bankwest and Commbank, among others.

Australian members of our Group are bound by the Privacy Act and the Australian Privacy Principles (APPs). Commbank has a separate but consistent privacy policy which can be viewed at commbank.com.au/privacy.

For more information about the Group, including a complete list of Group members, see the CBA’s latest Annual Report, available at commbank.com.au/shareholders.

We take privacy seriously and are committed to ensuring the protection of your personal information, no matter where you are located.

Your privacy is important to us

We protect your personal information, and aim to be clear and open about what we do with it. You can find more information in places like our application forms and terms and conditions.

This Policy explains how we handle your personal information. It also includes:

  • Our policy on the handling of credit reports and other credit information
  • Key information about credit reporting matters.

During your relationship with us, we may tell you more about how we handle your information. For example, when you complete an application, or receive terms and conditions.

Sometimes we update our privacy policy. You can always find the most up-to-date version on our website.

What information do we collect?

We collect information about you when you use our products or services, or deal with us. We may also collect information about you from other people and organisations.

Information we collect from you

We collect personal information about you when you contact us, use our products or services, visit our websites or use our mobile apps or deal with us in some other way.

Information we collect from others

We collect information about you from others, such as:

  • Service providers
  • Agents
  • Advisers
  • Employers
  • Companies or bodies that you own shares in or have an interest in
  • Family members.

For example, if you apply for credit, we may ask a credit reporting body for your credit report. We may also collect information about you that is publicly available (for example, in public registers or on social media) or provided by businesses we deal with.

We may collect the following types of personal information:

Types of personal information What kinds of personal information might be involved
Personal and contact details This may include your name, address, email address, phone number, and date of birth.
Australian Government related identifiers and identity documents

These may include your:

  • Country of tax residency
  • Medicare card, Australian passport, driver licence, or pension card details
  • citizenship, birth, death and marriage certificates (for example, to verify your identity).
Foreign government identifiers and identity documents

This may include foreign government identity documents and identifiers such as:

  • tax identification number and country of tax residency
  • foreign passport and driver licence (for example, to verify your identity at the time you request a product or service).
Financial information

This may include:

  • details of your employment, income, assets, financial liabilities
  • copies of bank statements and credit card statements from other financial institutions
  • information from third parties about your credit history.
Credit information See ‘Credit Checks and Credit Reporting’ below for the types of credit information that we collect.
Transaction information This includes information about transactions that you have made using our products. For example, your redraw transactions.
Socio-demographic information This may include your age, gender, number of dependents, occupation and nationality, for example when you apply for a home loan.
Interaction information This includes details of your interactions with us, such as when you call us, use our online services, make an enquiry, provide feedback, or make a complaint.
Digital information

We collect information from you electronically when you use our services.

This includes information such as:

  • location information (if enabled on your device)
  • IP address
  • details of the device used to access our digital services (including mobile and tablet)
  • information on whether your device is enabled to install other apps from unknown sources or whether known malicious apps have been installed on your device.
  • details of the wi-fi network or mobile network used by your device
  • type of authentication used (for example touch ID or face ID)
  • when you access our mobile apps using an Android mobile device – any suspected malware detected on your mobile
  • details of third party sites you access

Some of this information we collect using cookies. For more information, see the “Cookies” section below.

Behavioural information This includes information that we generate about how you use our products and services. For example, we may generate information about your spending patterns so we can help you manage your money.
Call recordings We monitor and record our calls with you. We will let you know if we are doing this and ask for your permission at the start of the call.
Sensitive information

On occasion, we collect and handle sensitive information. This may include:

  • Biometric information (for example, we may ask for an image of your face for biometric identification purposes)
  • health information (where this is relevant, for example if you're in financial difficulty and ask for hardship relief due to illness)
  • race or ethnicity (for example we may ask you what language you speak if you request a translator to communicate with us)
  • criminal history and political affiliation, where it is relevant for our regulatory obligations.

If we need this type of information, we will ask for your permission prior to its collection – except where otherwise allowed by law.

Information about your personal circumstances

On occasion, we may ask you to provide information about your personal circumstances so we can support you during any financial difficulties. This may include:

  • information about significant life events (such as a relationship breakdown or a death in the family)
  • where you have been impacted by an emergency event or a natural disaster
  • any unexpected changes to your financial situation (such as losing a job or incarceration)
  • details of injury, illness, gambling or addiction.
Publicly available information

On occasion, we may collect and handle information that is in the public domain, such as from:

  • online forums, websites, Facebook, Twitter, YouTube or other social media (for example, if you use social media to make a complaint)
  • public registers (for example, those kept by the Australian Securities and Investments Commission).

How do we use your information?

We’re careful about how we use your information. We use it to deliver our products and services. We also use your information for other reasons, such as to better understand you and your needs, and to let you know about other products and services you might be interested in.

Here is a list of the ways we may use your personal information.

Purpose How we use your personal information
Serving you as a customer

We use your information to deliver our products and services including to:

  • assess and process your applications for products and services
  • administer and manage existing products or services you have with us
  • manage our relationship with you
  • improve our service to you and your experience with us
  • communicate with you or your representatives about our products and services
  • let you know about other products and services that may be of interest to you.
Improving our business

We use your information to improve the products and services we provide through activities such as:

  • reviewing customer feedback and assessing how you use our products and services
  • testing and validating the effectiveness of products, services and system enhancements
  • monitoring and reviewing call recordings, online chats and other business activity for quality assurance, training and compliance purposes.
Managing our operations

We use your information to manage our operations including to:

  • deliver our products and services
  • make and manage customer payments and transactions
  • manage charges and interest due on your products and services
  • collect and recover money that is owed to us
  • respond to complaints and seek to resolve them
  • manage our share register and security holder records.
Managing security, risk and crime prevention

We use your information to:

  • prevent, detect and investigate suspicious or fraudulent activities
  • investigate health and safety incidents involving our people and customers
  • support the management of our information security and network controls to prevent cyber-attacks, unauthorised access and other criminal or malicious activities.
To comply with our legal obligations

Where required, we use your personal information to comply with the law, including our regulatory obligations, including to:

  • confirm your identity
  • share relevant information with law enforcement agencies, tax authorities and other regulatory bodies
  • screen applications and monitor accounts to identify criminal activity such as fraud, terrorist financing, bribery, corruption and money laundering.
  • investigate financial crime.
Managing our business

We use your information to run our business in an efficient and proper way. This includes managing our financial position, business capability and planning, testing systems and processes, as well as managing communications, corporate governance, and audit.

We may also use your information to ensure you are complying with your terms and conditions with us.

Performing analytics activities

Sometimes we combine information we have about you and our other customers, for example transaction information, with data from other sources, such as third party websites or the Australian Bureau of Statistics. We use this information to:

  • help us understand trends in customer behaviour including how products and services are used
  • improve the products and services we offer
  • improve the quality of our data
  • develop products and services that better meet our customers’ needs and behaviours
  • understand and manage our risks better.
De-identifying information

Sometimes we de-identify your personal information, for example transaction information, and use this to:

  • provide insights and analytics services to other organisations.
  • share de-identified information with other organisations.

These services help organisations learn about the types of customers they have and their general spending patterns.

Sales or acquisitions

We may also use your personal information to support any changes to the ownership of products or services or the make-up of the CommBank Group. For example, we may:

  • sell, transfer, or merge parts of our business, or our assets, including products or services
  • bring other businesses into the CommBank Group
  • stop providing a particular product or service.

When we do this, we may share your personal information with other members of the CommBank Group or other parties involved, where appropriate.

Determine your eligibility for credit See Credit Checks and Credit Reporting for how we use your credit information.

Bringing you new products and services

From time to time, we may also use your information to tell you about products or services we think you might be interested in. To do this, we may contact you by:

  • Email
  • Phone
  • SMS
  • Social media
  • Advertising through our apps, websites, or third-party websites

If you don’t want to receive direct marketing messages from us or want to change your contact preferences, you may adjust your communication preferences in the Unloan App. You can also unsubscribe from any commercial electronic messages to your electronic address by following the instructions set out in our email/text message.

Using data to give you better customer service

We’re always working to improve our products and services and give you the best customer experience.

New technologies let CommBank Group members combine information we have about you and our other customers, for example transaction information, with data from other sources, such as third party websites or the Australian Bureau of Statistics. Our CommBank Group members analyse this data to learn more about you and other customers, and how to improve our products and services.

The Group members use this combined data to help other businesses better understand their customers. When we do, we don’t pass on any personal information about you.

Cookies

We use cookies to collect information about how you use our website. We may also use cookies for security and to personalise your experience when using our website.

You can choose if and how your computer accepts them by configuring your preferences and options in your browser. If you want to make full use of our website, you may need to set up your browser to accept cookies.

Who do we share your information with?

We may share your information with third parties for the reasons noted in ‘How do we use your information’ or where the law otherwise allows or requires us to. These third parties can include:

Type of third party Description
Other members of the CommBank Group We may share your information between members of the CommBank Group. This helps us offer you a high-quality customer experience. You can read about how CommBank Group members may use your information in How do we use your information?
Authorised Third Parties We may share information with third parties where you have authorised us to do so or where we are legally required. This may include third parties that you have authorised to act for you (such as accountants, financial counsellors, legal representatives, agents, financial advisors, or a person with Power of Attorney).
Third Parties that can verify your information

This includes organisations that can verify information that you have supplied when applying for a product or service, or making a claim, including:

  • your employer, to verify your employment status.
  • other banks and financial institutions that you may have products and services with.
  • commercially available third party databases.
  • credit reporting bodies and credit providers (see Credit Checks and Credit Reporting section).
Our Service Providers

We may share your information with our service partners, external service providers and other organisations that help us to supply products and services. These include:

  • organisations that we partner with to supply products and services, for example, payment and shopping services, mortgage insurers, loyalty program partners and our product distributors.
  • external service providers that we engage to do some of our work for us, for example mailing houses, debt recovery agencies, legal service providers and information technology and cloud service providers.
  • people who help us process applications and claims (like assessors and investigators).
  • organisations involved in our funding arrangements (like loan purchasers, investors, advisers, researchers, trustees and rating agencies).
  • auditors, insurers and re-insurers.
  • organisations that assist us to identify, investigate or prevent fraud or other misconduct.
Other financial services organisation We may collect and share your information with other banks, third party payment providers, superannuation funds and financial services providers to provide you services, for example to process your transactions, facilitate payment reversals and provide refunds.
Government and law enforcement agencies We may share your information with regulatory bodies, government agencies and law enforcement bodies to comply with our legislative or regulatory obligations in any of the jurisdictions where we operate.
Your joint applicants and joint account holders Your information may be shared or visible to other people using the same account (joint account holders), and other people applying for a product with you (joint applicants).

Sending information overseas

Sometimes, we may send your information overseas, including to:

  • Overseas businesses that are part of the Group
  • Service providers or other third parties who store data or operate outside Australia (Unloan uses a number of US based providers)
  • Complete a transaction
  • Comply with laws, and assist government or law enforcement agencies.

If we do this, we make sure there are appropriate privacy, data handling and security arrangements in place to protect your information.

Credit checks and credit reporting

If you ask us for credit, we may check your credit reports. We get these from credit reporting bodies. We also share your credit information with them so they can provide credit reports to others.

When you apply to us for credit, we may need to check your credit reports.

A credit report gives us information about your credit history. Credit reports are provided by credit reporting bodies, who collect and share credit information with credit providers like us, and other service businesses like phone companies.

The Privacy Act limits the information we can give to credit reporting bodies, and that they can give us. The Act also limits how we can use credit reports.

The information we can share with credit reporting bodies include:

  • Your identity
  • Type and amount of credit you have – like credit cards, home loans, or personal loans
  • How much you’ve borrowed
  • If you’ve made all your repayments
  • If you’ve committed fraud or another serious credit infringement.


Credit reporting bodies include this information in their credit reports to assist other credit providers assess your credit worthiness.

We can also ask credit reporting bodies to give us your overall credit score, and may use credit information from credit reporting bodies together with other information to arrive at our own scoring of your ability to manage credit.

The credit reporting body we use is Equifax Pty Ltd. You can download a copy of their privacy policy at www.equifax.com.au

What do we do with credit information?
We use information from credit reporting bodies to:

  • Confirm your identity
  • Assess your credit applications
  • Assess your ability to manage credit
  • Manage our relationship with you
  • Collect overdue payments.


We keep credit information with your other information. You can view this information or ask us to correct it if it’s wrong (see ‘Accessing, updating and correcting your information’ below) or make a complaint to us (see ‘Making a privacy complaint’ below).

Other rights you have
Direct Marketing – Credit providers like us can ask credit reporting bodies to use your credit information to pre-screen you for direct marketing purposes, but you can tell credit reporting bodies not to (See ‘We’re here to help’ below).

Preventing identity fraud – If you have been or could be a victim of fraud – for example, if someone else may be using your name to apply for credit – you can ask the credit reporting body not to use or give anyone your credit information.

Keeping your information safe

Our staff are trained in how to keep your information safe and secure. We use secure systems and buildings to hold your information. We aim to only keep your information for as long as we need it.

We store your hard copy and electronic records in secure buildings and systems or using trusted third parties. We use a range of physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal information we hold about you.

We aim to keep personal information only for as long as we need it – for example for business or legal reasons. When we no longer need information, we take reasonable steps to destroy or de-identify it.

Accessing, updating and correcting your information

You can contact us and ask to view your information. If your information isn’t correct or needs updating, let us know straight away.

Can you see what information we have?

You can ask us for a copy of your information, like your transaction history, by emailing us (see ‘We’re here to help’ below).

To get a copy of current credit information we have about you, you can email us (See ‘We’re here to help’ below).

Is there a fee?

No.

How long will it take?

We try to make your information available within 30 days after you ask us for it. Before we give you the information, we’ll need to confirm your identity.

Can we refuse to give you access?

In some cases, we can refuse access or only give you access to certain information. For example, we might not let you see information that is commercially sensitive. If we do this, we’ll write to you explaining our decision.

Updating your information

It’s important that we have your correct details, such as your current home and email addresses and phone number. You can check or update your information in the Unloan App, or by emailing us (see ‘We’re here to help’ below).

Can you correct or update your information?

You can ask us to correct or update any information we have (including credit information). See ‘We’re here to help’ below for ways to contact us. If we’ve given the information to another party, you can ask us to let them know it’s incorrect. We won’t charge a fee for this.

If the incorrect information was given to us by a credit reporting body, we may need to check with them or the relevant credit provider before we can change it. We’ll try to do this within 30 days. If we can’t, we’ll let you know why it’s taking longer and agree on a new timeframe with you. We’ll also tell you when we’ve corrected the information.

What if we believe the information is correct?

If we don’t think the information needs correcting, we’ll write to let you know why. You can ask us to include a statement with the information that says you believe it’s inaccurate, incomplete, misleading or out of date.

Making a privacy complaint

How can you make a complaint?

If there’s something we can improve, or you're not satisfied with our products, services, people, or complaint handling process, it's important we hear about it so we can make things right.

We will take your complaint seriously, work with you to address your complaint, and try to find a solution that's fair and reasonable.

If you are concerned about your privacy (including credit information), you can make a complaint by emailing us at complaints@unloan.com.au or via phone on 1300 630 000.

What happens when you make a complaint

We’ll acknowledge your complaint

  • Most complaints can be resolved soon after we receive them or within days.
  • We’ll let you know we’ve received your complaint (generally by the next business day), give you a reference number, and let you know the name and contact details of the person who’s handling it.

We’ll assess the information and work with you to find a fair outcome

  • We’ll assess the information you give us, investigate the issues further at our end if we need to, and work with you to find a fair solution.
  • If we're unable to provide you with a final response within 30 days, we'll tell you the reason for the delay, give you a date you can expect to hear an outcome, and continue to update you on our progress.

If you're unhappy with the resolution

  • You can lodge a dispute with the Australian Financial Complaints Authority, an external dispute resolution body. AFCA provides a fair and independent complaint resolution service which is free for customers to access.
  • You can also contact The Office of the Australian Information Commissioner if your complaint is about your privacy.
Australian Financial Complaints Authority
GPO Box 3, Melbourne VIC 3001
Free call 1800 931 678
Email info@afca.org.au
Visit www.afca.org.au
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Phone 1300 363 992
Visit oaic.gov.au

Credit information complaints

If your complaint is about your credit information, we may need to check with credit reporting bodies or the credit provider involved. If we can’t resolve your complaint within 30 days, we’ll get in touch to provide reasons for the delay and work out a new timeframe with you.

We're here to help

If you want to update your personal information, or if you have a privacy concern, need more information, or want to update your preferences, simply email us at hello@unloan.com.au. You can also use the Unloan App to update your information and preferences.

Terms

“we”, “us” or “our” means Unloan, a division of Commonwealth Bank of Australia, ACN 123 123 124.

“Unloan App” includes Unloan iOS or Unloan Android Apps downloaded from an official App store and accessed locally on your device, as well as the Unloan web App. The Unloan App may not yet be available for access or download.