Privacy Policy – Paradigm Financial Management Pty Ltd

1. Our Privacy Commitment

Paradigm Financial Management Pty Ltd ("we", "us", "our") is committed to safeguarding your privacy and protecting your personal and credit-related information. This policy outlines how we handle your information under the Privacy Act 1988 (Cth), Australian Privacy Principles (APPs), and the Privacy (Credit Reporting) Code 2014.

We also operate in conjunction with Australian Finance Group Ltd (AFG) ABN 11 066 385 822, Australian Credit Licence 389087, and its subsidiaries, who may access and process information in accordance with this policy.

2. What Constitutes Personal Information

Personal information means data that can identify you. This may include:

Name, address, date of birth
Email, phone number
Occupation and employment details
Account and transaction information
Tax File Number (TFN) or tax residency status
Location, IP address, mobile device data when using our digital services

We may also collect sensitive information (e.g., racial or ethnic origin, health, membership in unions, sexual preferences) with your explicit consent.

3. Collection of Your Information

We primarily collect information directly from you when you:

Apply for finance or employment
Use our website, forms, or mobile applications
Contact us via phone, email, or in person

We may also obtain your data from:

Credit reporting bodies (Equifax, Experian, Illion)
Brokers, employers, referees, legal and financial advisers
Public registers and social media

4. Why We Collect and Use Your Information

We use your personal and credit-related information to:

Assess and process finance applications
Manage financial services and compliance
Identify and verify your identity
Provide customer service and direct marketing
Process payments or make payments to you
Support employment and broker applications
Meet legal obligations such as under AML/CTF laws

We may also analyse data to improve our products and personalise your experience.

5. Credit-Related Information

Credit-related information includes:

Credit type, terms, limits, repayment history
Overdue or default payments
Hardship arrangements and serious credit infringements
Court judgments or insolvency records

We use this information to assess your creditworthiness. It may be shared with credit reporting bodies and used for identity verification or credit assessments. Overseas storage of such data is possible under secure arrangements.

6. Disclosure of Your Information

We may disclose your information to:

Funders, credit providers, lenders mortgage insurers
Debt collectors, lawyers, valuers, surveyors, recovery agents
Third-party service providers (e.g., IT, call centres, printing)
Your authorised representatives (brokers, guardians, accountants)
Our insurers, auditors, reinsurers, and investigators
Government regulators, courts or law enforcement
Businesses with whom we have a marketing relationship (with your consent)
Overseas service providers (in USA, UK, Canada, Malaysia, India, Ireland, Philippines)

We ensure that third parties meet privacy standards or that we have your consent before disclosure.

7. Overseas Disclosures

Your data may be stored or accessed overseas via cloud services or third-party vendors. We take reasonable measures to ensure those entities uphold privacy protections.

8. Use of Data Analytics and Third-Party Data

We may combine your data with other sources (e.g., ABS data, third-party sites) to better understand customer behaviour and improve our services. This analysis may also support business partners, but we do not disclose your identifiable data unless legally required.

9. Cookies and Online Tracking

When you visit our website, we may collect:

Device and browser type
Pages visited, navigation patterns, interactions
IP address and location data

Cookies help improve user experience. Third-party advertisers may also use cookies to track ad performance. You can adjust your browser to manage or disable cookies, though some functionality may be affected.

10. Direct Marketing

We may use your information for marketing purposes, such as:

Product and service updates
Promotions and offers from us or partners

You may opt out at any time via email or unsubscribe links. We honour all opt-out requests promptly.

11. Updating Your Information

To ensure accuracy, we may periodically ask you to confirm your details. You can update your personal information by contacting us directly. We aim to ensure that the personal details we have about you—such as your address, phone number, and email—are accurate and current. Throughout our relationship, we may ask you to let us know if any of your details have changed.

If you need to update your personal information, please reach out to us. We generally depend on you to provide correct and complete information.

12. Access and Correction of Your Information

You can request:

Access to your personal and credit information
Correction of inaccurate or outdated data

We aim to respond within 30 days. Fees may apply for accessing data. If we decline your request, we will provide an explanation.

13. Notifiable Data Breaches (NDB)

If a data breach occurs that may cause serious harm, we will notify:

You
The Office of the Australian Information Commissioner (OAIC)

We will explain the breach and advise on how to mitigate risks.

14. Complaints and Dispute Resolution

If you are dissatisfied with our privacy handling or credit related information or compliant about our compliance with Privacy Act

If unresolved, contact:

AFCA: 1800 931 678 | info@afca.org.au | GPO Box 3, Melbourne VIC 3001
OAIC: 1300 363 992 | www.oaic.gov.au

15. Government Identifiers

We only collect and use government-issued identifiers (e.g., TFN) when legally permitted. These are not used to identify clients internally.

16. Anonymity and Pseudonymity

In most cases, we need to verify your identity to provide our services. However, where the law allows and it is practical, you may interact with us anonymously - for example, when requesting general information about interest rates or promotional offers.

17. Sensitive Information

We collect sensitive data only with your consent and only when necessary for our services or legal compliance. 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 or biometrics.

18. Information Storage and Security

We will take all reasonable steps to protect your personal information by storing it in a safe & secure environment. We store data securely in both digital and physical formats. Reasonable steps are taken to prevent misuse, unauthorised access, or data loss.

19. Changes to This Policy

We may revise this Privacy Policy to reflect legal, technological, or business updates. The latest version is always available on our website. You may request it in alternative formats.