1. Who we are
In this policy, "we", "us" and "our" refer to EEZY Finance Pty Ltd ABN 99 677 798 604, Australian Credit Representative 560512, authorised under Australian Credit Licence 384704 held by Finsure Finance and Insurance Pty Ltd ABN 72 068 153 926 ("Finsure").
We are a mortgage and finance broker located in South East Queensland, serving clients Australia-wide. We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and, where it applies to us, Part IIIA of the Privacy Act and the Credit Reporting Code.
This policy explains what personal information we collect, how we use and protect it, the technology and service providers we use (including online forms, online booking, website tracking and artificial intelligence tools), and how you can access your information or make a complaint.
2. What personal information we collect
Personal information is information or an opinion about you, from which you are identified or reasonably identifiable. The kinds of personal information we collect depend on the services you use and may include:
- Identity and contact details: name, date of birth, address, phone number, email address and identification documents such as a driver licence or passport.
- Financial information: income, employment details, assets, liabilities, expenses, bank statements, tax returns and other information needed to assess your borrowing capacity.
- Household information: marital status, the number and ages of dependants, and residential history.
- Credit information: information about your existing credit, repayment history and defaults, and credit eligibility information obtained from credit reporting bodies by lenders.
- Property and asset information: details of properties, vehicles or assets being purchased or offered as security.
- Business information: for business finance, your ABN, business structure, financial statements and BAS.
- Communications: records of our emails, messages, calls and meetings with you, including file notes, and recordings and transcripts of calls and video meetings (see section 9).
- Booking information: details you provide when booking an appointment online.
- Job applicant information: if you apply to work with us, your resume, work history, qualifications, referee details and any information you provide during the recruitment process.
- Website and device information: information collected through cookies and similar technologies when you visit our website, as described in section 8.
Sensitive information. We only collect sensitive information (such as health information) with your consent, and only where it is reasonably necessary, for example when assessing financial hardship.
3. How we collect personal information
Where reasonable and practical, we collect personal information directly from you, including when you:
- meet or speak with us by phone, video or in person;
- complete our secure online application and document collection form (provided by Middle, see section 6);
- book an appointment through our online booking page (provided by Microsoft, see section 7);
- email us, upload documents or complete forms on our website; or
- interact with us on social media.
We may also collect personal information about you from third parties, including lenders and lodgement platforms, Finsure, identity verification services, valuers, your employer or accountant (with your authority), referrers, and other people you ask us to deal with, such as a co-borrower, solicitor or conveyancer.
If you give us personal information about another person, such as a co-applicant, guarantor or dependant, please make sure they are aware of this policy.
4. Why we collect, use and hold personal information
We collect, use and hold personal information to:
- understand your needs and objectives and develop a lending strategy with you;
- assess which credit products may be suitable and not unsuitable for you, as required by the National Consumer Credit Protection Act 2009 (Cth), and to meet our Best Interests Duty;
- prepare, lodge and manage loan applications with lenders, and liaise with them through to settlement;
- verify your identity and meet our legal obligations, including under anti-money laundering and counter-terrorism financing laws where they apply;
- meet our obligations to Finsure as our licensee, including compliance monitoring, audits and record keeping;
- provide ongoing service, including annual loan reviews and reminders such as fixed rate expiry;
- manage appointments, communications and our relationship with you;
- improve our services, website and client experience;
- send you information about our services, where permitted (see section 13); and
- assess and manage applications from people who apply to work with us.
If you do not provide the information we request, we may not be able to assist you or arrange finance for you.
5. Technology and service providers we use
We use trusted third-party providers to deliver our services. These providers handle personal information on our behalf, and we only share what they need to perform their service.
| Provider | What we use it for | Where data may be held |
|---|---|---|
| Middle (Middle Technology Australia) | Secure online application (fact find) and document collection. Information you enter is transferred into our CRM. | Hosted on Google Cloud. Middle is independently certified to the SOC 2 Type 2 security standard. Middle may disclose information to its staff located in Hong Kong. |
| Finsure (Infynity, and its successor platform Metanoia) | Client relationship management, loan lodgement, compliance records and document generation, including our Statement of Credit Assistance. | Held by our licensee Finsure, as described in Finsure's privacy policy (www.finsure.com.au). |
| Offshore support staff | Administrative support, such as data entry and document processing, through our secure systems under confidentiality and privacy obligations. | The Philippines |
| Quickli | Serviceability and borrowing capacity calculations. | Australia (Sydney region) for core hosting, databases and document storage. Some processing by third-party services may occur outside Australia. |
| Microsoft 365 (Outlook, Bookings, Teams), supplied through GoDaddy | Email, calendar, online appointment booking, video meetings and secure file storage. GoDaddy manages our subscription and billing. Our data is held by Microsoft. | Australia (Microsoft's Sydney datacentres) |
| Lenders, lodgement platforms and mortgage insurers | Submitting and assessing your application. | Australia, and as set out in each lender's privacy policy |
| Hostinger | Hosting our website. The website does not collect application details; these are entered through Middle. Our host keeps standard server logs, such as IP addresses and pages requested, for security and performance. | Indonesia (Hostinger's Asia data centre) |
| Google (Analytics, Ads, Search Console) | Website analytics and advertising measurement (see section 8). | United States and other countries |
| Meta (Facebook and Instagram) | Social media, advertising and advertising measurement (see section 8). | United States and other countries |
| Claude (Anthropic) | AI assistant for drafting, summarising and administrative support, as described in section 9. | United States. We use Anthropic's business Team plan, under which our data is not used to train its models by default. |
| Finsure AI tool (within Finsure's broker platform) | AI features within our CRM and broker platform, as described in section 9. | Processed within Finsure's platform. The AI tool does not store personal information. |
| Quickli AI features | AI-assisted features within our serviceability software, as described in section 9. | Quickli's AI providers are configured for zero data retention and do not use our data to train their models. Some AI processing occurs outside Australia. Documents uploaded to Quickli's AI features are stored temporarily in Sydney and deleted within 24 hours by default. |
We take reasonable steps to ensure our providers protect personal information, including reviewing their security and privacy terms. Each provider also has its own privacy policy.
6. Online application and document collection
Our "Apply now" button takes you to a secure online form provided by Middle. Information and documents you submit through this form are collected by us, stored by Middle on our behalf and transferred into our CRM so your broker can assess your needs.
Submitting the form does not lodge an application with a lender. Your broker will review your information, discuss your options and only submit an application to a lender with your agreement.
7. Online booking
When you book a consultation through our online booking page, Microsoft Bookings collects your name, email address, phone number, preferred time and any notes you add. We use this information to schedule and confirm your appointment, send reminders and prepare for our meeting.
Please do not include sensitive or detailed financial information in booking notes. We will collect what we need securely during or after your consultation.
8. Website, cookies and tracking technologies
Our website uses cookies, pixels and similar technologies to understand how it is used and to measure and improve our advertising. These may collect information such as your IP address, device and browser type, approximate location, pages visited, how you arrived at our website and actions taken, such as clicking "Apply now" or "Book a consultation".
- Google Analytics: to understand website traffic and usage.
- Google Ads conversion tracking: to measure whether our ads lead to enquiries.
- Meta Pixel: to measure our Facebook and Instagram advertising and, where enabled, to show our ads to people who have visited our website.
Google and Meta may combine this information with other information they hold about you, in line with their own privacy policies. We do not send your loan application details, financial information or identity documents to advertising platforms.
Your choices. You can manage non-essential cookies through our cookie settings banner, block or delete cookies in your browser, install the Google Analytics opt-out browser add-on, and adjust your advertising preferences in your Google and Meta account settings. Blocking cookies will not prevent you from using our website.
9. Use of artificial intelligence
We use artificial intelligence (AI) tools to help us work efficiently. The tools we currently use are Claude (provided by Anthropic), the AI tool within Finsure's broker platform, and AI features within Quickli. Examples of how we use them include drafting and proofreading correspondence, summarising meeting notes, organising documents, researching lender policies, supporting serviceability calculations and preparing marketing content.
When we use AI tools:
- we only use business-grade tools with contractual privacy and security protections, and where available we choose settings that prevent the provider from using our data to train its models;
- we limit the personal information we enter to what is necessary, and de-identify information where practical;
- we do not enter government identifiers, such as tax file numbers, or identity document numbers into general-purpose AI tools;
- a broker reviews all AI-assisted work before it is relied on or sent to you; and
- we routinely record and transcribe calls and video meetings, including with AI transcription tools, to create accurate file notes and meet our compliance obligations. We will ask for your consent at the start of each call or meeting before recording. If you prefer not to be recorded, we will take written notes instead. Recordings and transcripts are stored securely and handled in line with this policy.
Decisions about you. AI does not decide which loan we recommend or whether we can assist you. Those decisions are made by your broker. We do use computer programs that help inform these decisions. Our serviceability software (Quickli) uses personal information such as your income, expenses, liabilities, household details and loan requirements to estimate your borrowing capacity, and our online application and CRM systems (Middle and Finsure) organise your information and may obtain your credit report with your consent. These tools help your broker assess which loans may be suitable for you and prepare your application. Your broker reviews their results and makes the recommendation. Lenders also use their own systems, which may be automated, when assessing applications, as described in their privacy policies.
10. Who we disclose personal information to
We may disclose your personal information to:
- lenders, lodgement platforms, mortgage insurers and valuers involved in your application;
- Finsure, as our licensee, for compliance, audit, commission administration and record keeping;
- the service providers described in section 5;
- people acting on your behalf, such as your solicitor, conveyancer, accountant or financial adviser, with your authority;
- your employer, referees and identity verification services, to verify information you have provided;
- a referrer who introduced you to us, limited to the status of your enquiry and only with your consent;
- government agencies, regulators and courts where required or authorised by law; and
- a prospective purchaser of our business, under confidentiality arrangements, if our business is sold or restructured.
We do not sell your personal information.
11. Disclosure outside Australia
Some of our service providers store or access information outside Australia, including in the United States (for example Microsoft, Google, Meta and Anthropic), Hong Kong, where our online application provider Middle has staff, Indonesia, where our website is hosted, other countries where AI providers used within our serviceability software Quickli process requests, and the Philippines, where offshore support staff assist us with administrative tasks, and where some of our licensee Finsure's contractors and outsourcing partners are located. These staff access information through our secure systems and are bound by confidentiality and privacy obligations. Where we disclose personal information overseas, we take reasonable steps to ensure the recipient handles it in a way that is consistent with the Australian Privacy Principles, including through contractual protections, and we remain accountable for that information as required by the Privacy Act.
Please be aware that overseas recipients may not be subject to privacy laws that offer the same protection as Australian law, and could be required by the laws of their country to disclose information to authorities there.
12. Credit information and credit reporting
With your consent, we may obtain your credit report from a credit reporting body to help assess which loans may be suitable for you. This may be done through Middle, which can obtain your credit report on our behalf when you complete its online application journey and authorise it to do so. Lenders also obtain credit reports when assessing your application. When we handle credit information, we comply with Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code.
The main credit reporting bodies in Australia are Equifax (equifax.com.au), Experian (experian.com.au) and illion (illion.com.au). Each has a credit reporting policy explaining how it handles credit information, and you can request a free copy of your credit report from them.
Our licensee Finsure's credit reporting policy sets out how credit information is collected, used and disclosed, how to access and correct it, and how to complain. It is available at www.finsure.com.au or by calling Finsure on 1300 346 787.
13. Direct marketing
We may use your contact details to send you information about our services, loan reviews, market updates and offers we think may interest you. Every marketing email includes an unsubscribe link, and you can opt out at any time by contacting us. We comply with the Spam Act 2003 (Cth) and will action opt-out requests promptly, at no cost to you.
14. Storage, security and retention
We store personal information electronically using secure cloud-based systems. We take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure, including multi-factor authentication, access controls, encrypted transmission and staff training.
We keep personal information for as long as needed for the purposes described in this policy and to meet our legal and licensee record-keeping obligations, including under the National Consumer Credit Protection Act 2009 (Cth) and anti-money laundering and counter-terrorism financing laws. Our licensee Finsure requires records of all credit assistance to be kept for seven years. When information is no longer needed, we take reasonable steps to destroy or de-identify it.
Data breaches. If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.
15. Accessing and correcting your information
You can ask to access the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 17.
Access requests may be handled together with our licensee Finsure, which may ask you to complete a Privacy Access Request form to confirm your identity. We will respond within a reasonable period, usually within seven days and no later than 30 days. We do not charge for a request, but we may charge a reasonable fee for the cost of providing access. If we refuse access or correction, we will explain why in writing and tell you how to complain.
16. Government identifiers, anonymity and sensitive information
Government identifiers. We do not use government identifiers, such as tax file numbers or Medicare numbers, to identify you, and we only use or disclose them where required or authorised by law.
Anonymity. You can make general enquiries without identifying yourself. To arrange credit, we will need to identify you.
Sensitive information. Sensitive information includes information about your health, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record and membership of professional or trade associations. We only collect it with your consent and where reasonably necessary.
17. Contact us and complaints
For privacy questions, access or correction requests, or to make a complaint, contact our Complaints Officer:
- Email: admin@eezyfinance.com.au
- Phone: 0422 257 418
We will acknowledge your complaint within one business day and aim to resolve it as soon as possible. We will provide a final response within 30 calendar days.
If you are not satisfied with our response, you can contact:
- Australian Financial Complaints Authority (AFCA): www.afca.org.au, 1800 931 678, GPO Box 3, Melbourne VIC 3001.
- Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au, 1300 363 992, enquiries@oaic.gov.au, GPO Box 5288, Sydney NSW 2001.
18. Changes to this policy
We review this policy regularly and may update it to reflect changes in law, technology and our practices. The current version is always available on our website, and you can request a copy in another format by contacting us.