Privacy Policy

Privacy Collection Statement

FundsConnect Platform Pty Ltd (ABN 53 700 705 451) collects your personal information (including name, contact details, financial information, and identification documents) for the purpose of facilitating business and investment purpose private credit lending through the FundsConnect platform. All borrowers are companies or corporate trustees. Your information may be shared with lenders on the Platform panel, valuation providers, solicitors, and regulatory bodies including AUSTRAC.
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We collect this information because it is reasonably necessary for us to provide our platform services. If you do not provide this information, we may be unable to facilitate your lending transaction.

You may access, correct, or request deletion of your personal information by contacting our Privacy Officer at Compliance@fundsconnect.com.au. If you are unsatisfied with our handling of your personal information, you may complain to us or to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

Our full Privacy Policy is set out below and is available at fundsconnect.com.au.

1. Introduction

FundsConnect Platform Pty Ltd (ABN 53 700 705 451) ("we", "us", "our") is committed to protecting the privacy and security of personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

FundsConnect provides technology platform services exclusively for business and investment purpose private credit lending. All borrowers accessing funding through the Platform are companies or corporate trustees. All transactions are entirely outside the National Consumer Credit Protection Act 2009 (Cth) and the National Credit Code.

2. Types of Personal Information We Collect

2.1 Identity Information

• Full name, date of birth, and gender (for authorised representatives of borrowing entities)
• Residential and business addresses
• Contact details (phone, email)
• Government-issued identification numbers (driver's licence, passport)
• Australian Company Number (ACN), Australian Business Number (ABN)
• Australian Credit Licence (ACL) or Credit Representative number (for brokers)
• Trust deed details (for corporate trustee borrowers)

2.2 Financial Information

• Income, assets, liabilities, and expenses
• Bank account details and transaction history
• Details of existing loans and credit arrangements
• Business financial statements and tax returns
• Property valuations and security details

2.3 Loan Transaction Information

• Loan applications and supporting documentation
• Credit memorandums and borrower profile documents
• Lender submissions and correspondence
• Settlement documents and directions to pay

2.4 Platform Usage Information

• IP address and browser type
• Login times and session duration
• Pages visited and features used
• Device information and operating system

2.5 Sensitive Information

We will only collect sensitive information (such as health information or criminal record) if it is directly relevant to a lending transaction and you have provided express consent, or if we are required or authorised by law to collect it.

3. How We Collect Personal Information

‍We collect personal information:

• Directly from you: Through the Platform, website forms, email, phone, or in-person meetings
• From brokers: When a broker submits a loan application on behalf of a borrowing entity through the Platform
• From third parties: Including valuers, solicitors, accountants, identity verification services, and credit reporting bodies
• From public sources: Including ASIC registers, PPSR, land title records, and court records
• Automatically: Through cookies and analytics tools when you use the website or Platform

We will not collect personal information by unlawful or unfair means (APP 3).

4. Why We Collect, Use, and Disclose Personal Information

4.1 Primary Purpose

• Facilitating business and investment purpose private credit lending through the Platform
• Processing loan applications and matching borrowing entities with appropriate lenders
• Preparing credit memorandums and borrower profile documents
• Facilitating loan settlement and post-settlement administration
• Managing broker and introducer relationships and commission payments

4.2 Related Secondary Purposes

• Verifying identity and conducting AML/CTF customer due diligence
• Complying with legal and regulatory obligations (Privacy Act, AML/CTF Act, ASIC Act, Corporations Act)
• Managing complaints and disputes
• Improving and developing the Platform
• Communicating with you about your transactions and our services
• Preventing fraud and managing risk

4.3 Direct Marketing

We may use your contact information to send you information about our services and platform updates. You may opt out of direct marketing at any time by contacting our Privacy Officer or using the unsubscribe function in our communications.

5. Data Flow: Who We Share Your Information With

5.1 Lenders and Service Providers

• Private credit lenders on the Platform panel (for loan assessment and approval)
• Property valuers (for security assessment)
• Solicitors and conveyancers (for settlement)
• Mortgage managers and servicers (for post-settlement administration)
• Identity verification service providers (for AML/CTF compliance)
• IT service providers (for Platform hosting and maintenance)

5.2 Regulatory Bodies

• AUSTRAC (AML/CTF reporting)
• ASIC (regulatory compliance)
• OAIC (in response to privacy complaints or investigations)
• Courts and tribunals (as required by law)

We will not sell, trade, or rent your personal information to third parties for marketing or commercial purposes.

6. Overseas Disclosure

We do not ordinarily transfer personal information to recipients outside Australia. All Platform data is stored on servers located in Sydney, NSW. If circumstances require an overseas disclosure, we will take reasonable steps to ensure the overseas recipient handles the information in accordance with the APPs, or that an exception under APP 8.2 applies.

7. Data Quality and Security

• 7.1 Data quality (APP 10): We take reasonable steps to ensure the personal information we collect, use, and disclose is accurate, up-to-date, complete, and relevant.
• 7.2 Data security (APP 11): We implement technical and organisational security measures to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures are detailed in Part C of our Platform Terms of Service (Data Security Policy).
• 7.3 Data retention: Personal information is retained for 7 years from the date of collection, in accordance with ASIC record-keeping requirements, the Corporations Act, and the AML/CTF Act. After the retention period, personal information is securely destroyed or de-identified.

8. Notifiable Data Breaches

In the event of an eligible data breach under Part IIIC of the Privacy Act 1988, we will:

• Notify the OAIC as soon as practicable
• Notify affected individuals as soon as practicable, including a description of the breach, the type of information involved, and recommended steps the individual should take
• Record the breach in our Data Breach Register
• Conduct a post-incident review and implement preventive measures

Our full Data Breach Response Policy is maintained separately and is available on request.

9. Your Privacy Rights

9.1 Access (APP 12)

You have the right to request access to the personal information we hold about you. We will respond to access requests within 30 days. We may charge a reasonable fee for providing access (e.g., photocopying costs) but will not charge for making the request.

9.2 Correction (APP 13)

You have the right to request correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading. We will respond to correction requests within 30 days.

9.3 Refusal of Access or Correction

We may refuse an access or correction request in limited circumstances, including where:

• Providing access would pose a serious threat to the life or health of any individual
• Providing access would have an unreasonable impact on the privacy of other individuals
• The request is frivolous or vexatious
• The information relates to existing or anticipated legal proceedings

10. Complaints

10.1 Internal complaints

If you believe we have breached the APPs or handled your personal information inappropriately, you may lodge a complaint with our Privacy Officer:

We will acknowledge your complaint within 5 business days and endeavour to resolve it within 30 days.

10.2 External complaints

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | Phone: 1300 363 992 | Email: enquiries@oaic.gov.au.

11. Cookies and Tracking

We use cookies and similar technologies to improve your experience on the website and Platform. For full details, see our Cookie Policy available at fundsconnect.com.au.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be notified via email or Platform notification.

Privacy Officer Contact