Huffle Privacy Policy

Huffle Pty Ltd ("Huffle") was incorporated for the purpose of developing and operating a platform for grouping together borrowers as they seek a loan in Australia.

This policy explains how Huffle handles personal information relating to individuals, whether or not they are customers.

Terminology

In this policy the expressions "we", "us" and "our" are a reference to Huffle.

The expression "personal information" is used in this policy to refer to information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. The kinds of personal information we collect includes your name, address, date of birth, bank account details, copies of identification documents.

Any reference to Huffle assuming an obligation under the Privacy Act or other privacy legislation can be interpreted as a reference to Huffle also procuring its subcontractors to undertake a reciprocal obligation to the extent relevant.

Information Collection

We only collect personal information to the extent that this is reasonably necessary for one or more of our functions or activities.

We only collect personal information about an individual direct from that individual unless it is unreasonable or impracticable for us to do so.

Purposes for which we may collect personal information include, but are not limited to:

(a) developing a business case to secure funding for the building and operation our platform;

(b) conducting such study, research and consulting as may be necessary to ensure the business case is as comprehensive and accurate as possible;

(c) liaison with stakeholders which may include, without limitation, financiers, information brokers, legal practitioners, revenue offices, financial institutions, the Council of Australian Governments and individual Australian Governments;

(d) establishing and conducting an email/e-newsletter subscriptions process;

(e) any other activity relevant to the construction, development, integration, maintenance and implementation of a national mortgage exchange system;

If we collect personal information about an individual from any other third party, such as a bank, we endeavour to handle that information in a manner which is consistent with the third party's own privacy policy and which is consistent with the third party's own obligations under the Privacy Act. We will work with the third party organisation in order to address any security or related privacy issues which may arise in relation to personal information which they have provided to us. Ultimately, however, it remains the third party's responsibility to ensure that it is complying with the Privacy Act and its own privacy policies when dealing with us.

Information Use and Disclosure

For the most part, the primary purpose of collecting personal information will be for use in connection with the preparation, digital signing, financial settlement and match-making and development of instruments and other documents relevant to a mortgage transaction, in part from matching a borrower to a lender.

We will not use or disclose personal information that we collect for any secondary purpose other than the primary purpose of collection without your consent unless:

(a) the secondary purpose is related to the primary purpose (directly related if sensitive information) and you would reasonably expect us to use or disclose the information for that secondary purpose;

(b) without limiting paragraph (a), the secondary purpose involves direct marketing and:

(i) we collected the information from you and you would reasonably expect us to use that information for direct marketing; or

(ii) we did not collect the information from you, or you would not otherwise reasonably expect us to use the information for direct marketing, but you have nevertheless consented to receive direct marketing communications or it is impracticable for us to obtain your consent in the circumstances, but in each case only if we provide you with a simple means to opt out; or

(c) the use or disclosure is otherwise permitted under the Privacy Act.

Your consent to receive direct marketing material will remain current until you advise us otherwise, however you can opt out of receiving direct marketing material at any time by contacting HuffleÕs customer database management (contact details below).

By using our website, you will be deemed to consent to us using your personal information in a manner consistent with this privacy policy, including monitoring your use of our website.

Cross-border access to data

We may make your personal information (including land information) available for access by Huffle participants in other countries (e.g. to banks with overseas processing arrangements). It is not practicable for us to specify in advance all of the countries from which your personal information may be accessed.

Data Security

We will take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. We will destroy or de-identify personal information once we no longer require it for our business purposes.

When using our website you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you transmit to us over the Internet and you do so at your own risk.

Openness

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website. You may obtain a copy of our current policy from our website or by contacting us on the details below. It is your responsibility to check the website from time to time in order to determine whether there have been any changes.

Access, Correction and Further Information

We will take such steps as are reasonable to ensure that the personal information which we collect remains accurate, up to date and complete.

We will provide you with access to your personal information held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us on the details below if you:

(a) wish to have access to the personal information which we hold about you;

(b) consider that the personal information which we hold about you is not accurate, complete or up to date; or

(c) require further information on our personal information handling practices.

You are entitled to complain if you believe that we have breached our obligations under the APPs or an applicable code. If you have a privacy complaint, you can contact Huffle:

Huffle Pty Ltd, 5/155 Clarence Street, Sydney, NSW, 2000

email us at: help@huffle.com.au

There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.

If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information if you so request.