FrontYa Australian Privacy Policy

1. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD ABOUT YOU AND HOW DO WE DO THIS?

The “personal information” (being information that is an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable), that we collect about you can vary depending on who you are and how we interact with you, but generally includes:

If you are an applicant:

> your name, contact details, date of birth, residency status and education;

> information about your intended property (the property which our services will relate to);

> details about your circumstances, including as to your dependents, borrowing capacity, lenders mortgage insurance status, income history, rental properties and job history; and

> other information required to be collected by us under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 or that will help us to comply with our obligations in relation to that Act.

You do not need to provide such information to us but we may not be able to accept your application if the information is not supplied.

In other more general circumstances (for example, where you are a representative of a business partner or supplier, apply for employment or communicate with us via our website or our other channels):

> your name and contact details;

> other details that you provide to us, including information contained in an application for employment or queries about our Services;

> comments, chat or opinions (including your preferences as to marketing or our Services); and

> any relevant billing or account information (including but not limited to bank account details, direct debit, credit card details, billing address).

We will always try to collect personal information from you directly but in some circumstances we may collect your personal information from a third party (for example, where a third party is making the application for you on your behalf).

“Sensitive information” is personal information which may include, but is not limited to, health information and information about your racial or ethnic origins or political or religious beliefs. We do not routinely collect sensitive information.

2. HOW DO WE HOLD, USE AND DISCLOSE PERSONAL INFORMATION?

We may use your information in the instances and for the primary purposes described below.

To fulfill your requests and provide our Services to you. We will use personal information to provide the Services to you, or respond to your customer service requests or feedback, including to process your application, purchasing the exposure, managing the investment and complying with relevant laws. Any information you provide to us may also be used by us for internal record keeping and administrative, invoicing and billing purposes.

For marketing purposes. We may send you communications about new features, updates, products and special offers. We may also use your information to serve you ads about products and special offers about our products or other products or services we think you might find interesting. We may also use individual and aggregate information about you to inform our marketing and advertising campaigns. For more information on how to adjust your communications preferences, see “Your Choices and Control Over Your Information” below.

To allow you to participate in promotions, competitions and other related activities. From time to time, we will run promotions, competitions, loyalty initiatives and conduct other activities relating to customer behavior. We will use information that we have collected about you to do this, including to provide you information about these initiatives, manage the initiatives and allow you to access any benefits you may have obtained through these initiatives.

To communicate with you. For example, we may communicate with you to handle enquiries and complaints and in relation to any application you make. If you register with us, we may enroll you in our email newsletter or other periodic electronic communications and may also send you user surveys and promotional communications. We may communicate with you by email, postal mail, telephone, text message, or other means. We may use push notifications. For more information on how to adjust your communications preferences, see “Your Choices and Control Over Your Information” below.

To monitor, improve and develop our products and services and relationship with you. We may use your information to understand you and our other customers, and improve our Services and tailor our product offerings accordingly.

To process and consider your applications for employment with us. We collect and use the personal information of applicants to evaluate their applications and their suitability. We may retain an applicant’s personal information for a reasonable time period after the date of application for the purpose of assessing an individual's suitability for other employment opportunities within our organization, though we have no obligation to do so.

To protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law. We may use information to protect our company, our affiliates, our customers, our franchisees and our websites. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations (including regulatory requirements) or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our services agreements, this Policy, or agreements with third parties, to detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law.

We may also use your personal information for other purposes not listed above which will be made clear to you at the time we collect your personal information, or for such purposes as may be required or permitted by law.

To the extent sensitive information is collected and held by us, we will only use and disclose this information for purposes you consent to or as otherwise permitted, required or authorized by law.

3. COOKIES

When you visit a website hosted by us, we may set a 'cookie' on your device (this is a small piece of system information stored on your device) so when you next visit, it links to your system and allows us to recognise that you have returned and remember your preferences. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie. If you do not wish for us to use a cookie, you can set your browser so it will not accept them. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or part of our website.

4. HOW WE SHARE YOUR INFORMATION

We may share, sell or disclose your information in the instances described below. For further information on your choices regarding your information, see “Your Choices and Control Over Your Information” below.

Our related entities: We may share personal information with our affiliates, who may use your information in the manner described in this Policy.

Third parties so that you can receive the benefit of the Services: We may share all or some of your personal information to share registries, custodians and certain software providers related to the operational management and settlement of the interests in deferred purchase agreements.

Third parties at your request: You may choose to share your personal information in relation to the Services with third parties and we may share your personal information with third parties for the purposes of providing the Services and/or enabling you to received related ancillary services. For example, we may share and receive personal information with and from your mortgage broker.

With your consent or at your direction: In addition to the sharing described in this Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

Service providers and advisors: Personal information may be shared with third party vendors, advisors and other service providers who perform services for us or on our behalf. This may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, product fulfillment, delivery services, payments processing, data enhancement services, fraud prevention, web hosting or analytic services. It will also include disclosure to our professional advisors and insurers in the course of obtaining professional advice or making claims under our insurance.

Purchasers and third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.

Law enforcement, regulators and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our services agreements or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of our organization, our customers, or others. Examples of when such a disclosure may occur, include in relation to ensuring compliance with regulatory reporting requirements and responding to regulator requests.

In connection with the above, in certain circumstances we may share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you.

5. YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

Your right not to provide personal information: You do not have to provide personal information to us, however, if you do not then it may affect our ability to provide our Services to you and your use of our Services.

Profile and settings: You may update your account information and adjust your account settings by logging into your account (if applicable) or contacting us. Please note that changes to your settings may require some time to take effect.

How to control your email preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications or by using the information in the “How to Contact Us” section below. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

Anonymity: You have the option of not identifying yourself, or to use a pseudonym when dealing with us. However, in some cases it will not be practicable to deal with you anonymously or using a pseudonym, including when you have elected to receive direct marketing materials or requested delivery of products or services from us, in which case we may be unable to provide you with materials, products or services if you do not identify yourself.

6. HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer: Your personal information may be stored and processed in Australia or any other country in which we or our affiliates or service providers maintain facilities. If you are located in regions with laws governing data collection and use that may differ from Australian law, please note that we may transfer information, including personal information, to a country and jurisdiction that have data protection laws that may be more or less restrictive than those required under Australian law. Please refer to the “Overseas Disclosure” section below for more information.

Data retention: We will retain your personal information as long as reasonably necessary to maintain the Services, to meet legal and accounting obligations, and for the other purposes described in this Policy. We may anonymize and/or aggregate personal information and store it in order to analyze aggregate metrics and trends.

Keeping your information safe: Security of your information is very important to us, and we have put in place safeguards to preserve the integrity and security of information we collect and share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems at all times. In the event that any information under our control is compromised as a result of a breach of data security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take additional steps, in accordance with any applicable laws and regulations.

7. TRANSFERRING PERSONAL INFORMATION OVERSEAS

Your personal information may be disclosed to employees, representatives, or other third parties operating outside of Australia who work for, or are engaged by us or our affiliates in other countries, including in Sri Lanka, and to our services providers who may be located outside of Australia, including in Sri Lanka. We note that these persons and third parties may also store, transfer or access personal information outside of Australia.

In disclosing your personal information overseas, we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.

8. LINKS TO OTHER WEB SITES AND SERVICES

The Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability resulting from you following a link to these websites. We strongly recommend that you read the privacy policies and terms and conditions of use of any third party website or service to understand how your information will be collected, used and shared.

9. ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION

You may, at any time, request access to and correction of any personal information we hold about you by contacting us (refer to the “How to Contact Us” section below).

If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons. We may charge a reasonable administration fee to cover the costs of meeting your request.

We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating our records whenever changes to the data come to our attention.

10. HOW TO CONTACT US

If you have any questions or complaints about how we handle your personal information or a breach of the Australian Privacy Principles or wish to access or correct personal information we hold about you, please contact us at:

The Privacy Officer, FrontYa - Email: hello@frontya.com

Our Privacy Officer will consider your question or complaint and endeavor to respond to you in a reasonable timeframe. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

11. CHANGES TO THIS POLICY

We may modify or update this Policy from time to time to reflect the changes in our business and practices, so you should review this Policy periodically. When we change this Policy in a material manner, we will so indicate by updating the “last modified” date in the heading of this Policy. If you object to any changes in this Policy, you may close your account associated with the Service.

Last modified: 26 April 2022