Privacy Statement

The Manager and the Lender may collect personal information about you to provide you with information about financial products or services; to assess your application and eligibility for a financial product or service; to provide you with the financial products and services that you’ve requested (including arranging, providing or insuring credit); the administration of their relationship with you; and for direct marketing of products and services offered by the Manager, the Lender or any organisation the Manager or Lender is affiliated with or represents. The Manager and the Lender may also collect any personal information necessary for the purposes of complying with legal and regulatory obligations, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

If you do not provide personal information, the Manager and Lender may be unable to provide you with their products and services, including any credit that you request.

The information provided by you will be held by the Manager and/or the Lender. You have the right to request not to receive direct marketing material from either or both of the Manager and Lender.

The general rule is that neither the Manager nor the Lender will use or disclose your personal information other than for the purposes stated at the time of the collection. If Manager or the Lender want to use your personal information for another purpose, either the Manager or the Lender (as applicable) will seek further consent from you, unless that other purpose is related to one of the original purposes of collection and you would reasonably expect them to use your personal information for that other purpose.

It may be necessary for the Manager or the Lender to disclose your personal information to certain third parties in order to assist in providing, managing and administering your products or services or for other related purposes. These include:

1. Other financial institutions
   Other financial institutions, such as banks, credit unions and building societies, in order to set up and manage your account and manage banking transactions.
2. Other organisations
   Other entities such as:
   • Lender's Group companies in order to service other of the Lender's products you may have within the Lender's Group and portfolio analysis;
   • Lender's Group entities located in the Netherlands and Singapore for account administration, security purposes or to comply with Australian and global regulatory requirements that apply to us or the ING Group;
   • any third party product and service supplier that either the Manager or the Lender have an arrangement with (so that either the Manager, the Lender or they may provide you with the product or service you have requested or in which you have expressed an interest);
   • Organisations undertaking reviews of the integrity of the Manager's or Lender's operations, including the completeness of information;
   • Authorised organisations providing services or functions on the Lender's or Manager's behalf (including mailing services, document storage services, direct marketing, data verification services, information technology support and printing standard documents and correspondence);
   • the Manager's or the Lender's solicitors, valuers and insurers;
   • credit reporting or information verification bodies (or their affiliated entities) in order to obtain and provide details about your credit history or status, to verify other information about you including your identity, to carry out your request to correct your credit information or to resolve your complaint about the handling, use or disclosure of your credit information;
   • Any person acting on your behalf including mortgage intermediaries, your financial adviser, power of attorney, solicitor or accountant.

Any example used above to indicate when personal information might be disclosed may not be limited to those examples (or examples of a similar kind).

Personal information will only be disclosed to third parties other than those listed above if you have consented; if you would reasonably expect disclosure of information of that kind to those third parties; if authorised or required to do so by law; or it is necessary to assist with law enforcement.

You also agree that the Manager, the Lender, any lenders mortgage insurers, any mortgage broker, mortgage originator, mortgage manager, and any other person or company who at any time provides or has any interest in the credit can, subject to that party's obligations under the Privacy Act, do any of the following at any time.

1. Commercial credit information
   Collect any commercial credit information from a business that provides commercial credit worthiness information and use that information to assess an application for consumer credit or commercial credit.
2. Consumer credit information
   Collect consumer credit information from credit reporting bodies and use that information to assess an application for commercial credit or consumer credit.
3. Collection of overdue payments
   Collect and use a credit report about you provided by a credit reporting body to collect overdue payments.
4. Provide information to mortgage insurer
   Disclose information to a mortgage insurer to assess the risk of providing mortgage insurance; to assess the risk of default; to assess the risk of a guarantor being unable to meet a liability arising under a guarantee; to administer and vary the insurance cover including for securitisation and hardship applications; to verify information that the Lender and Manager collect about you; to deal with claims and recovery of proceeds including, among other things, to enforce a loan in place of a lender if the mortgage insurer pays out an insurance claim on your loan; for a mortgage insurance purpose relating to you; and for any other purpose under the insurance policy issued to the Lender relating to your loan, as well as for other management and risk purposes.
5. Exchange of information between credit providers
   Collect, use or disclose to another credit provider (including without limitation any other credit provider who has lent money on the same security) any information or opinion about credit worthiness, credit standing, credit history or credit capacity.
6. Exchange of information with originators
   Seek from and use or give, personal information and details of your account to any mortgage broker, mortgage originator, or mortgage manager.
7. Exchange of information with advisers
   Seek from and use or give to any originator, financial consultant, accountant, lawyer, or other adviser acting in connection with any financing provided or proposed to be provided to you any personal information, consumer or commercial credit information.
8. Provide information to credit reporting body
   Give to a credit reporting body personal or commercial credit-related information about you. The information may include identity particulars; the fact that credit has been applied for, the amount and type of credit and the applicable terms and conditions; repayment history information; the fact that the Manager is a current credit provider to you; payments which become overdue more than 60 days, and for which action has been commenced; advice that payments are no longer overdue; in specified circumstances that in the opinion of the Manager you have committed a serious credit infringement; and the credit provided to you by the Manager has been paid or otherwise discharged and the date on which this occurs.
9. Provide information for securitisation
   Disclose any report or personal information about you to another person in connection with funding financial accommodation by means of an arrangement involving securitisation, or any other proposed transfer of or proposed dealing with your loan.
10. Provide information to Guarantors
    Provide information to any person who proposes to guarantee or has guaranteed repayment of any credit provided to you.
11. Provide information in relation to disputes and enquiries
    Disclose consumer credit information, commercial credit information, and personal information to any industry body, tribunal, or court or otherwise in connection with any complaint regarding the approval or management of your loan – for example if a complaint is lodged about any mortgage broker or lender who dealt with your loan.
12. Disclose personal information
    Disclose personal information about you as required by law, or to organisations involved in providing credit to you, or any associate, or contractor of the Manager or Lender, (including, for example, stationery printing houses, mail houses, lawyers, accountants), or people considering acquiring or taking an interest in our business, or our assets.
13. Authority in relation to a mortgage insurer
    You also agree that this authority applies to any mortgage insurer, who may have to use, hold and disclose to third parties any personal information they collect about you from us or a credit reporting body in order to assess whether to insure the risk of providing mortgage insurance; or to assess the risk of default; to assess the risk of a guarantor being unable to meet a liability arising under a guarantee; to administer and vary the insurance cover including for securitisation and hardship applications; to verify information that we collect about you; to deal with claims and recovery of proceeds including, among other things, to enforce a loan in place of a lender if the mortgage insurer pays out an insurance claim on your loan; for a mortgage insurance purpose; and for any other purpose under the insurance policy issued to us relating to your loan, as well as for other internal management and risk purposes.

The Manager's and the Lender's Privacy Policy contains information about how you:

• can access your personal information that they hold and seek the correction of that information; and
  
• may complain about a breach of the Australian Privacy Principles, Part IIIA of the Privacy Act, or the Credit Reporting Privacy Code, and how they will deal with such a complaint.

The Lender's website includes information about credit reporting, including details of the credit reporting bodies that the Lender deals with, what information the Lender provides to credit reporting bodies (including if you fail to meet your payment obligations or commit a serious credit infringement) and what information credit reporting bodies provide to other credit providers, your right to request credit reporting bodies not to use your credit reporting information for the purposes of direct marketing and information about your right to initiate a ‘ban period' in cases of actual or suspected identity fraud.

If you would like further information regarding privacy you can review the Manager's and the Lender's Privacy Policy online at their respective websites or request a copy by either calling or writing to them.