Privacy Policy - Australia

This Policy is effective from 3 September 2025. We’ll update this Policy from time to time, and the latest version will always be available here.

Anonymity and pseudonymity

You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific to an account with us or relates to your Personal Information, we will need to identify you before we can engage in further discussions and correspondence.

• 1. Background

  At Branded Financial Services Pty Limited, we understand privacy is important, and we are committed to managing your Personal Information in a way that is both secure and consistent with relevant legislation, including the Privacy Act 1988 (Cth) (Privacy Act) as well as the Credit Reporting Privacy Code (CR Code) (where applicable).

  We have created this Privacy Policy to outline and help you understand how Branded Financial Services Pty Limited and its related companies (including as named below) collect, disclose, use, store, or otherwise handle Personal Information:

  • Avanti Finance Limited and its related subsidiary Companies referred to as 'us', 'we', 'our', and ‘BFS’.

  This Policy explains:

  • the kinds of Personal Information we collect as covered by the Privacy Act, and the purposes for which we do that;
  • how we manage and share Personal Information once we collect it;
  • how you can seek access to and correction of Personal Information; and
  • where required, how you can make a complaint concerning our handling of Personal Information.

  This Policy applies to any individuals who deal with BFS whether in relation to the provision of credit or otherwise, including in relation to our finance products and services such as borrowers, guarantors, and introducers (for example, our brokers, advisers, and motor vehicle dealers), and employees, contractors and anyone you authorise to manage your account for you. As such, not all of this Policy will necessarily be applicable to everyone.

• 2. Information in our Privacy Policy

  This Privacy Policy should be read in conjunction with:

  • Our Credit Reporting Policy
  • Our Statement of Notifiable Matters
  • Our Privacy Disclosure Statement and Consent
  • Any privacy collection notice that we may provide to you
• 3. What is personal information?

  “Personal Information”, as referred to in this policy, has the meaning set out in the Privacy Act. It means information about an individual who is identified or reasonably identifiable (for example, name and date of birth), and it also includes:

  “Credit information” includes credit information, credit eligibility information and any information from a credit report about you (or information which is derived from that report), for example, your repayment history for loans from other credit providers, the amount of credit provided to you, and the kinds of credit products you have applied for.

  “Sensitive information” is information, which is sensitive in nature, such as political opinions, membership of a profession or trade, biometric information, and health information. We only collect sensitive information from you if it is necessary in the circumstances and you have consented to that collection.

  “Behavioural Information” relates to behaviour analysis information, for example the use of Artificial Intelligence (AI) behavioural scoring to assess financial behaviours like spending patterns, payment consistency, digital engagement, information on how you use our products and services or how you manage your loan account.

  “Performing analytics information” is where we may sometimes combine personal information we have about you and other customers, for example transaction information, with data from other sources such as third-party websites.

• 4. Personal information we collect

  The Personal Information we may collect about you will depend on the circumstances, including, for example, your relationship with BFS (e.g. whether you are a customer or an employee ) and (if applicable) the type of financial product or service being applied for or provided (e.g. a consumer or business loan).

  The information we may collect could include:

  • key personal Information such as your full name (and any other previous names you have been known by), date of birth, residential, business and postal addresses, telephone numbers, email and other electronic addresses, driver licence details, passport details and other alternative identification methods (for example, photo identification card or other Government issued identification documentation/methods.);
  • financial, credit and related information such as:
    • your occupation, income and type of employment or the type of work you do, your expenses, assets and liabilities (including those over which we may take security), dependants, financial and business position and dealings, and other relevant events;
    • bank account details;
    • your transaction/repayment history with us or relevant third parties (and the capacity in which you dealt with us or them); and
    • information about your credit history, the amount of credit extended by other lenders, credit scores and any information obtained in order to carry out a credit check.
  • other relevant information – depending on the circumstances, this may also include health and medical information (e.g. if it is relevant to a hardship request), membership of professional bodies, tax file number information, other government identifiers (e.g. to verify your identity), and any other information you share with us about your personal or business situation;
  • transactional information – for example, information relating to:
    • your use of our product(s); and
    • your interactions with us, including when you call or otherwise correspond with us;
  • your payment history.
  • behavioural and/or biometric data that includes behavioural analytics on how you use and access our websites and any mobile apps that we use now or may develop for use in future including also use of biometric information (such as face), where this information is collected and used for the purpose of automated biometric verification, biometric identification, or behavioural profile information (such as your keystroke typing patterns, facial recognition movements, scrolling or swiping activity) while you interact with us digitally, to detect suspicious financial and cyber activities, including fraud; and
  • online/device information – information collected if you use our websites, customer portal and/or apps (if available) and social media profiles, which can include: your social media handles; session data that is automatically collected and transmitted by our apps, such as your device IP address and geolocation data (using GPS data of your device, the nearest Wi-Fi access points and mobile networks), the operating system and browser your device used to view our website or app, brand and model of your device, unique identifiers of your device, name and parameters of your network connection, time, duration and date of your visit and pages you viewed, device call history, and information and metadata about other applications installed on your device including application names, application identifiers and version, device identifier and checksum.

  If you do not wish to provide us with your Personal Information (including Credit Information and Sensitive Information), we may not be able to provide our products or services to you, respond to or assist with your queries or be able to provide you with full access to all features of our products or services.

• 5. How we collect your personal information

  We will generally collect your Personal Information directly from you or from someone who is acting on your behalf. This may include collecting information from your device/s when you access our websites, portals or apps (if available), or social media profiles and when you contact our call centre(s). Some of this information may be collected using cookies (please see section 12) or other tracking technology. However, there are also certain instances in which we’ll collect information about you from third parties, particularly where it’s unreasonable or impracticable to collect it directly from you. Third parties from whom we may collect your information from include:

  • third parties you authorise to act on your behalf or that are otherwise connected with you (such as a financial adviser, your accountant, executor, administrator, trustee, guardian, consumer advocate or legal representative);
  • introducers, such as advisers, brokers, and motor vehicle dealers;
  • any co-applicant, co-borrower and/or guarantor or security provider;
  • your past or present employers, accountant, referees, banks, landlords, lawyers, financial advisers, or others with whom you have previously had dealings or persons assisting you, who you direct to provide information to us;
  • our related companies;
  • credit reporting agencies and other credit providers who may have Credit Information about you, relevant to us, including to check your credit and assess your creditworthiness, on an ongoing basis;
  • identification service providers who may have identification information about you for the purpose of fulfilling our requirements under Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) legislation (AML/CFT Legislation) in some circumstances, your personal information may be transferred between our New Zealand parent company(Avanti Finance Limited) and BFS to assist with AML/CFT compliance purposes;
  • other agencies involved in (or in partnership with us in connection with) the provision of a relevant product or service being obtained from us;
  • publicly available sources (e.g. internet sources);
  • other service providers we may deal with, including external mail houses, debt collection agencies, private investigators, professional advisers;
  • data and analytics product providers who provide us with access to credit related data;
  • research agencies;
  • public and subscriber-only databases;
  • any person considered necessary in our view to carry out your instructions; and
  • government agencies including, but not limited to, the Department of Home Affairs, the Attorney General’s Department, Australian Police, the Department of Employment and Workplace Relations. The Office of the Australian Information Commissioner, The Australian Taxation Office, Australian Financial Security Authority, and the Australian Competition and Consumer Commission.
• 6. How we use your personal information

  Personal Information we collect about you will only be held, used and disclosed as is reasonably necessary for our business purposes and as permitted by law. Purposes for which we’ll usually hold, use and disclose your Personal Information, depending on the circumstances and the nature of the products and services you’re obtaining from us, include:

  • providing products and services to you;
  • deciding whether to provide a product or service requested or applied for, including verifying your credit history, evaluating your creditworthiness, or deciding whether to accept you as a guarantor (if applicable);
  • the ongoing monitoring of creditworthiness, including relating to your current credit obligations and financial position, your payments and any defaults;
  • register security interests on the Personal Property Securities Register (PPSR)
  • detecting and preventing instances of fraud, unlawful conduct, and other risks to you or our products and services;
  • providing other related products or services to you, by us and/or relevant and trusted third parties;
  • responding to certain enquiries relating to any insurance policy or other credit related policy offered by a third-party service provider in connection with our products or services;
  • ensuring fast and accurate approval and processing of applications and requests;
  • the administration and management of the products and services that we provide to you and managing any account you have with us;
  • dispute and complaint resolution, and assisting other credit providers to do the same;
  • enforcing our rights, including the collection of outstanding payments and, where necessary, initiating legal proceedings;
  • complying with our obligations, including ongoing participation in the credit reporting system by providing Credit Information to credit reporting agencies – (information disclosed by us to credit reporting agencies may be listed in their systems, used by them to provide their credit reporting services or other information services, and supplied to their customers on an ongoing basis in line with Part IIIA of the Privacy Act and Credit Reporting Code);
  • assisting customers in meeting their credit related obligations;
  • dealing with serious credit infringements and assisting other credit providers to do the same;
  • verifying your identity as may be required from time to time by AML/CFT Legislation;
  • providing your behavioural biometric data to a third party for the purposes of digital identity protection and fraud prevention;
  • verifying your identity using electronic sources. To do so, we’ll ask you for your details (such as your name, address and date of birth) and details of your identification documents, which will be passed to external organisations to electronically match your information with identification data on their databases;
  • complying with Australian Laws and regulations that may specifically require us to collect your Personal Information and any overseas laws where collecting your information is necessary for us to comply with our obligations;
  • use of performing analytics information to help us understand trends in customer behaviour including how products and services are used, improve the products and services we offer, improve the quality of our data, develop products and services that better meet our customers’ needs and behaviours and understand and manage our risks better;
  • sharing Personal Information with law enforcement agencies where we reasonably believe it’s necessary to comply with the law or to assist in the prevention, detection or investigation of fraud, money laundering or other criminal offences;
  • assisting us in managing our businesses, undertaking review and maintenance of our systems and infrastructure, complying with our internal operational requirements, such as for credit or risk management, product or system development and planning, insurance, audit and administration purposes;
  • undertaking securitisation activities (selling or assignment of loans) and other activities relating to capital and funding requirements, including fulfilling reporting requirements;
  • improving the quality of and ensuring the safety of our websites, portals and apps (where applicable) and of the services provided;
  • identifying you and your device so that we can make our services available to you;
  • customer data analytics, which may be provided to or shared with third parties which we have an alliance, partnership or arrangement with;
  • improving the products and services we provide you. This may include, for example, using Personal Information, including transaction data, to obtain customer insights and monitor customer trends;
  • undertaking research and development regarding potential future products and services;
  • compiling statistical data, e.g. credit scoring information;
  • for training, quality control and verification purposes;
  • for recruitment purposes, including assessing a candidate’s suitability for a position with us;
  • reporting to state/federal including police where we believe that you or us are at risk of fraud;
  • developing an understanding of the products and services you may be interested in receiving from us, our related entities, and trusted partners or third parties with which we do business; and
  • Marketing products and services provided by us, our related entities, and trusted partners or third parties, including by sending notifications, requests, and other information (including, for example, by mail, email, telephone (including SMS), in portal or app messages/notifications and social media platforms) about the products and services we or they provide, unless you tell us, or them, not to.

  Opting out/unsubscribing from marketing or promotional communications

  If you don’t want BFS to send you any marketing or promotional materials by email or SMS, you can opt out of these services by following the unsubscribe instructions in the promotional message itself or by calling our Customer Service team. Soon, we hope to provide you with the ability to change your marketing preferences in our customer portal. We’ll let you know if and when this service is available.

  If you don’t want one of our trusted parties or third parties (such as a credit reporting agency) to send you marketing or promotional materials, you will need to opt out of these services with them directly.

  If you want to stop receiving notifications on certain websites or social media, you may need to adjust your device or online privacy settings.

  Important note on service communications:

  Even if you opt out of marketing and promotional communications, there are certain service, operational and other correspondence that we are required to send you about our products and services (e.g. to advise you of changes to certain terms and conditions).

• 7. Who we share your personal information with, including overseas

  Where the Privacy Act and Credit Reporting Code permits, we may share your Personal Information (including Credit Information) with third parties for the purposes outlined above. These external organisations will record, use and disclose your information in accordance with their own privacy policies and legal obligations. Some organisations to whom we may disclose your Personal Information (including your Credit Information or credit eligibility information) will be located overseas (known as cross border disclosure).

  We may disclose your information to entities outside of Australia. These entities include our related entities and service providers located in New Zealand.

  We only disclose your information to entities outside of Australia for our business functions or for the purposes of providing services to you. Where we do so, we ensure that the disclosure of and access to that information is secure and appropriate controls are in place. Third parties that we may share your Personal Information with include :

  • as applicable, any co-applicant, co-borrower and/or guarantor or security provider, or to the extent required by law, any other party who otherwise has an interest in the product or the service we have provided to you, or the security related to that product or service;
  • third parties you authorise to act on your behalf or that are otherwise connected with you (such as a financial adviser, your accountant or legal representative, a referee or an access seeker acting on your behalf to obtain your credit report);
  • for the avoidance of doubt, any members of the Avanti group of companies, including those identified in this privacy policy;
  • our related entities and trusted partners or third parties with which we do business, including with which we have a partnership, affiliation, arrangement or agreement;
  • entities who wish to be involved in our business or acquire an interest in our business;
  • entities or persons involved in arrangements that provide funding to us, including investors, advisers, trustees and rating agencies (including whom we may be required to provide reporting to periodically);
  • credit reporting and rating agencies, including on an ongoing basis;
  • entities that provide services to us, such as external communication providers (i.e. mailing, email or SMS services), social media platforms, IT providers, professional advisers, providers of financial services to us, market research and data providers, and insurance providers;
  • introducers (including advisers, brokers, motor vehicle dealers and retailers);
  • the supplier of any goods or services financed with credit and/or services we provide;
  • our assignees or potential assignees, or where we act as an agent for, or otherwise on behalf of, another person, to the principal or that other person;
  • other financial institutions or entities such as banks and other credit providers;
  • insurers, assessors, underwriters;
  • identification service and fraud prevention providers;
  • debt collection agencies and other enforcement bodies;
  • external dispute resolution schemes, for example, if a complaint is made about us;
  • government regulatory bodies in Australia and overseas;
  • other relevant authorities or third parties if we are authorised or required by law or otherwise permitted under the Privacy Act, such as to comply with mandatory reporting requirements in relation to suspected cases of domestic violence or abuse; or to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety; and
  • law enforcement agencies (where we do so we will provide written notice of disclosure outlining that your personal information has been disclosed for enforcement related activities).

  We may disclose your information to entities or persons involved in arrangements that provide funding to us, including investors, advisers, trustees and rating agencies (including whom we may be required to provide reporting to periodically) that are based in New Zealand and United States of America (USA).

  We may also disclose your information to third parties that are based overseas other than New Zealand and United States of America (USA) for the purposes listed above when permitted to do so by the Privacy Act. Where we do so, we will advise you and will make sure there is appropriate privacy, data handling and security measures in place to protect your information.

• 8. Credit reporting

  As described above, your Credit Information may also be shared where relevant. Where the Privacy Act and Credit Reporting Code permits it, we may disclose your Credit Information to credit reporting agencies for the purposes outlined above. Credit reporting agencies may include the information we provide to them in their reports in order for them to assess your creditworthiness. If you fail to meet your payment obligations to us or commit a serious credit infringement, we may be entitled to disclose that information to credit reporting agencies.

  You are entitled to opt out of direct marketing assessments, including pre-screenings with credit reporting agencies. If you do not want a credit reporting body to use your information in this manner, the Privacy Act gives you a right to request you be excluded from being contacted. You should contact the relevant agency directly if this is the case. You also have a right to request non-disclosure where you believe that you are a victim of fraud or are likely to be a victim of fraud under the Privacy Act. You should contact the relevant credit reporting agency if you wish to request this (please refer to our Credit Reporting Policy for further details).

• 9. How we hold and protect your personal information

  We will hold your Personal Information in electronic form on our systems, but we may also hold some paper or other physical records. Service providers may also hold Personal Information for us.

  Your Personal Information is protected by various physical, electronic and procedural safeguards. We have in place both technical and organisational measures to protect your privacy. Where a service provider holds your information, we require those service providers to adhere to our approved standards of security and confidentiality to ensure your Personal Information is protected. Staff who handle your Personal Information are provided with training on how to do so appropriately.

  Our procedures ensure that your Personal Information is only available to staff where necessary. We will also only keep your Personal Information for as long as necessary to achieve the purpose for which it was collected or as required by law. If we no longer need your Personal Information, we’ll destroy the information or remove any identifying information so it can no longer be linked to you.

• 10. Access and correction of your personal information

  You have the right to request access to and correction of any Personal Information we hold about you, subject to certain exceptions under the Privacy Act. You’re entitled to specify how you wish to access your Personal Information so long as this is reasonable and practicable. We verify the identity of anyone requesting access to Personal Information to ensure that we don’t provide that information to a person or people who don’t have the right to access that information.

  We take every reasonably practicable step to ensure that the Personal Information we collect, use and disclose is accurate, complete and up to date.

  If you want access to your Personal Information or make a request for correction of Personal Information, you can contact us via the channels outlined below in Section 14 of this privacy policy. You may also request for us to provide an associate statement with that information to the effect that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading so that it is apparent to users of the information. We usually provide you with access within thirty (30) days of your request, but in some circumstances, it may take longer, and we will advise you where this is the case.

  We may charge you our reasonable costs of providing you copies of your Personal Information and/or attaching a statement of correction to your Personal Information.

  Please note, that under Australian law, we are entitled to refuse you access to your information in the following circumstances:

  • access would be unlawful;
  • denying access is required or authorised by or under an Australian law or a court/tribunal order; or
  • access would prejudice enforcement activities or the taking of appropriate action in relation to unlawful activity or serious misconduct .

  There may be other reasons that we refuse to provide you access to your information.

  If we don’t agree to your request for correction or are unable to provide you with access to certain Personal Information we hold about you for legal reasons, we’ll give you notice of this, outlining our reasons and what next steps you can take.

• 11. Personal information about other persons

  If you provide us with Personal Information about any other person, for example, a referee, a co-applicant, a person authorised to speak with us on your behalf, another director, a shareholder or beneficial owner, you confirm that, prior to disclosing information about them to us, you have received their consent to do so. You also confirm that, prior to disclosing their Personal Information to us, you have made them aware of:

  • The fact you’re providing this information to us;
  • The reason you’re providing their information to us; and
  • This Privacy Policy, including, in particular, our reasons for collecting, using and disclosing Personal Information and our contact details.
• 12. Cookies, remarketing and web analytics

  A. Cookies

  A cookie is a small text file placed on your internet-connected device by a website to capture information about your visit. Cookies allow us to recognise you when you return. They also help us provide a customised experience. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to Personal Information. For example, we use the information we collect about website users to optimise our websites and to understand website traffic patterns. Third-party vendors, including Google, use cookies to serve ads based on your prior visits to websites. Google’s use of the DART cookie enables it and its partners to serve advertisements to you based on your visit to sites on the Internet. You may opt out of the use of the DART cookie by visiting Google’s advertising opt-out page (alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. You can use Ads Settings to manage the Google ads you see and opt out of interest-based ads. Even if you opt out of interest-based ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search).

  B. Use of cookies for advertising and analysis

  Our websites and mobile apps may use a range of third-party cookies, such as digital platform plugins and Google Analytics, as remarketing tools to advertise to you online or understand your website browsing behaviours.

  The information may be used to serve you relevant ads or content in relation to our products or services when you visit our websites and third-party websites and apps. The information we collect and share with third parties is anonymous and aggregated. It does not include personal information which is likely to identify you.

  We do not use third party tracking pixels on our website.

  C. Opting out

  You can control the tailored advertising you see online by changing the cookie settings on your social media accounts or the websites you visit.

  You may need to turn cookies off separately on each device and browser you use to access online content. You can generally do this via your browser settings.

  It’s worth knowing that turning cookies off may mean the websites you visit have limited functionality and the advertising you see is generic (or less relevant to you).

• 13. Links to other websites

  Our websites or communications you receive from us may contain links to other websites. These websites may have their own privacy policies in relation to your Personal Information, and we have no responsibility for linked websites or their communications with you and provide them solely for your information and convenience. We encourage you to be aware when you leave our websites and to read the privacy policy or statement of each website you visit.

• 14. Privacy complaints, disputes and queries

  If you have any questions about this privacy policy and/or a concern or complaint about the way we have handled your Personal Information, including obligations relating to consumer credit information under Part IIIA of the Privacy Act and Credit Reporting code, please contact us using the details below :

  Email:
  Phone:	1300 549 166
  Post:	Branded Financial Services Pty Ltd Attention: Privacy Officer Level 1, 20 Hunter Street, Sydney, NSW 2000

  Once we receive your complaint, we’ll respond to you within a reasonable period of time, usually within 30 working days. Where it is a legal requirement to do so, then if we need more time to investigate and resolve your complaint, we will notify you as to the reasons why and seek your agreement to extend this thirty (30) day period (if you do not agree we may not be able to resolve your complaint).

  Please note, that where your complaint relates to your Credit Information, we may consult with a credit reporting body or other credit provider(s) to investigate and resolve your complaint. Depending on the type of complaint, it may also be necessary for us to consult with other third parties. If we don’t satisfactorily handle your complaint, you may wish to contact the external dispute resolution scheme, the Australia Financial Complaints Authority at info@afca.org.au, or make a complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au. Please also refer to our Credit Reporting Policy and Statement of Notifiable Matters for further details.