RateTraker by Sherlok Privacy Policy

At Sherlok, we believe that data and technology play a vital part in innovation. We practice responsible data collection, which means considering the privacy, security and ethical implications of working with data, all the way from collecting it, to managing, using and deleting it.

We believe how we collect, process, and store your data should be transparent and easy to understand. We have dedicated effort and resources to ensure we adhere to best practices or better when it comes to the safety, privacy, and security of your data.

1. Privacy and Security Policy
Sherlok Technology Pty Ltd (ACN 622 971 402) (we, us, or our) recognise the importance of your privacy and that you have a right to control how your personal information is collected and used.

By using our website at www.sherlok.com.au (including the Sherlok software portal and RateTraker) (Website) and/or providing your personal information to us, you consent to us handling your personal information in accordance with this Privacy Policy.

If you provide us with personal information about a third party (including any co-applicants) you represent, we collect it on the basis that you have that person’s consent for us to collect and handle their personal information in accordance with this Privacy Policy.

2. Collection of your personal information
We may collect personal information that we require for the purpose of our business activities and functions and as otherwise required or permitted by law.
We may collect personal information about you in the course of your dealings with us, such as when you submit an online enquiry or purchase products and services from us (including the Sherlok software portal).
The type of personal information we collect will depend on your dealings with us. It may include:
• contact details (e.g. your name, address, telephone number and email address);
• information about your employment (e.g. place of work, position, authority to transact with us, etc.);
• details of any properties that you own, including address, purchase price and value;
• details of your mortgage and financing arrangements, including details of your current rates and loan amounts;
• information required for you to do business with us including bank account details, credit card information and any other relevant financial information; and
• information about your use of the products and services that we supply.

We may also collect other personal and sensitive information from you.

We may collect personal information in a number of ways including, using forms, the telephone and via our Website. For example, we usually collect personal information through:
(a) our Website;
(b) orders for products and/or services;
(c) your bank, your broker and other financial institutions;
(d) employment applications;
(e) third party service providers;
(f) provision of customer service and support; and
(g) responses to surveys or research conducted by us or on our behalf.
(h) open banking/Consumer Data Rights Frame Work

Where practicable, we will collect personal information directly from you. From time to time, we may collect personal information about you from public sources and as otherwise permitted by law. The nature of our products and services also means that, in some cases, we collect personal information about you from third parties, including from your bank or your broker. For instance, we do this when your finance broker has provided us with your personal information so that you can benefit from our products and services.

If we are unable to collect the personal information we require, or the information provided is incorrect or incomplete, we may not be able to fulfil the applicable purpose of collection, such as to supply products and/or services to you or to assess your application for employment.

3. Purposes for which personal information is collected, held, used and disclosed
We will use and disclose your personal information for the purposes for which we collected it, and for other related purposes that you would reasonably expect.
Generally, these purposes include:
• providing you with products and services, including providing information to you about loan products that may be available;
• to monitor usage of our Website;
• handling payments and refunds;
• providing you with marketing information or special offers for our products and services;
• obtaining your feedback on your customer experience;
• improving our products and services;
• conducting market research;
• conducting marketing and other promotional activities;
• responding to your enquiries; and
• for our general business operations (for example, maintenance of our business records, compliance with our legal and insurance obligations and statistical purposes.)

By providing us with your personal information, you consent to us using your personal information for direct marketing purposes. You agree that we may send you such information by post or electronic means (including e-mail and SMS). You can opt-out of marketing and promotional communications at any time using an opt-out mechanism in one of our communications or by contacting us via the details below.

In carrying out those activities, we may need to share information about you with third parties, which may include:
(a) your broker;
(b) our related entities;
(c) agents and advisers;
(d) Alliance partners (including banks and other lenders);
(e) service providers (including cloud storage and IT providers);
(f) contractors and
(g) others as permitted by law.

In addition, if we are considering selling our business or any part of our operations or assets, we may disclose your personal information to a purchaser (or potential purchaser) in connection with that process or sale.

Apart from the above instances, we may also use and disclose your personal information with your consent and as otherwise required or permitted by law.

4. Sensitive Information
We will only collect ‘sensitive information’ with your consent. We will assume that you have consented to us collecting all information provided to us by you for use per this Privacy Policy, including any ‘sensitive information’, unless you tell us otherwise when you provide it to us.

5. Storage and security of your personal information
We may hold your personal information in electronic formats or in hard copy. We take reasonable steps to securely store your personal information to ensure it is protected from unauthorised access, modification and disclosure and from other types of misuse, interference and loss.
We will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes. Your personal information may also be retained in our IT system backup records.
Data transfer over the Internet is inherently insecure. During transmission, we cannot guarantee the security of any personal information provided to us via our website. However, our Website uses 256-bit encryption, and we have implemented security policies and processes to assist in managing these risks.

6. Access and correction of your personal information
You may lodge a request to correct the personal information we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading; in this case, please contact our Privacy Officer via the contact details below.
You may request that we provide you with access to the personal information we hold about you. We will generally provide you with access, except in limited circumstances where the law permits us to deny access. Any such requests must be made in writing to us via the details shown below. No fee will be incurred for requesting access, but if your request for access is accepted, we will inform you of the fee (if any) that will be payable for providing access if you proceed with your request.

7. Our Website
Our Website uses cookies. We do not use the information stored in those cookies to collect information about you or your computer. The cookies are used for statistical purposes and to assist with your use of the Website. We may also collect click-stream data when you use the website, such as the date and time of your visit, the pages you accessed, your IP address, the type of browser and operating system you are using and the websites you come from and move to. This information is collected for statistical purposes to assist us in finding out how our Website is used and navigated and to improve our Website.
Our Website may contain links to third-party websites. We are not responsible for the privacy, security, or handling of your personal information on those websites. You should review those websites’ privacy policies and terms of use each time you visit them.

8. Overseas disclosure of your personal information
Generally, we will not disclose your personal information to overseas recipients except with your consent or where we are required or authorised to do so by law.

9. Changes to our Privacy Policy
We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the policy on this website. You should review our Privacy Policy whenever you visit this website or provide us with Personal Information.

10. Complaints
If you have a complaint about the way in which we handle your personal information, please contact us at the details below. We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response, which generally will be within 14 days of receiving your complaint.
You can see our detail Credit Guide and Complaints Process here.

11. Contact us
If you would like further information about the way we manage your personal information or if you have a complaint, please contact our Privacy Officer by:
• telephone: 1300 664 886
• email: privacy@sherlok.com.au