Privacy Policy

 

1. About this Privacy Policy
At Coposit Investments Pty Ltd (ACN 652 246 169) ATF The Coposit Trust (ABN 64 287 723 140) (Coposit), your privacy is important to us and we are committed to ensuring the confidentiality and security of your personal information.

When we refer to our ‘Coposit Services’, we are referring to the Coposit website and backend portal located at www.coposit.com.au (Website) on any device and social media sites and the Coposit App (App), emails we send and any new technology we implement on any of these platforms or a combination thereof.

This Privacy Policy outlines how we collect, use, disclose and protect your personal information. It also sets out how you can access and change your information, how you can ask a question or make a complaint.

In addition to our Privacy Policy we are bound by the Australian Privacy Principles (APPs) and Notifiable Data Breaches Scheme set out in the the Privacy Act 1988 (Cth) (Privacy Act). A copy of the Australia Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.

2. Collecting personal information
We only collect and hold personal information that is reasonably necessary for Coposit’s business functions and activities.

Personal information is information about you that identifies you as an individual or from which your identity can be reasonably identified. It includes information you have provided to Coposit when creating an account with us, which includes, but is not limited to your:

• name;
• address;
• email address;
• telephone number;
• your date of birth;
• your driver’s licence number;
• location;
• bank account details;
• income;
• employment details;
• mortgage or other loan details;
• shareholder/investment portfolios;
• tax file numbers;
• payment methods; and
• other information of a personal nature that you disclose during communications with us, whether electronically in an app; in person, over the telephone, via email or in writing.

The information that Coposit collects about you depends on how you use our Coposit Services and interact with us.

You can use the App and visit and browse the Website without disclosing any personal information. Our system may record information such as the date and time of your visit, your computer’s IP address, the pages accessed, and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes. No Personal Information is collected if you are simply browsing the Website.

We collect personal information from you if you register for Coposit Services or update your profile, such as your name, email address, telephone numbers and social media profiles.

Once you have registered we also collect information about your use of Coposit services and information that you provide while you use Coposit services. This information may include your location and your device’s IP address. Your location is only recorded by Coposit while the App is running, although note that your device may have the ability to run apps in the background in which case you may need to specifically shut down the App to stop location recording.

We may combine the personal information we collect from you with information that we receive from and about you in other contexts and from other sources, including third parties.

We collect your personal information for the purpose of providing you with quality products and services in relation to streamlining the process of purchasing a property. This may include using your personal information to deliver Coposit services, process any requests you may have, notify you of important changes to our Coposit services, comply with record keeping requirements or to verify your identity.

We may also keep records of communications containing personal information (including recordings of emails and telephone calls) for the purpose of staff training.

If we do not collect your personal information, we may not be able to do these things. For example, we may not be able to communicate with you and deal with your enquiries.

3. Where your information is stored
We may store your information in hardcopy and/or in electronic form on servers that are located within Australia. We take reasonable steps to protect the Personal information we hold from misuse, interference and loss, and from any unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information

4. How do we collect personal information?
We can only collect personal information about you by a lawful and fair means. There are several ways that we may collect your personal information, which are set out below:

a) Directly from you
If it is reasonable and practical to do so, we will collect your personal information directly from you. We may do this when you register for Coposit services. But we may also collect your personal information directly from you in other ways, including when:

• we have a conversation with you over the telephone;
• you send an email or letter to us;
• you complete on online enquiry or application form; or
• you enter a competition with us.

b) Indirectly
If it is unreasonable or impracticable to collect your personal information directly from you, we may collect it from third parties. This may include collecting your personal information from third parties such as public sources, introducers or information service providers. We may also collect your personal information from credit reporting bodies, finance brokers, verification bodies and other people such as accountants, lawyers and referees.
If we receive personal information about you from someone else without having asked for it, we will only continue to hold it if it is personal information that we could have collected from you ourselves, in accordance with this Privacy Policy. If it is personal information which is not reasonably necessary for our business functions and activities, we will destroy or de-identify it.

c) From our Website and App
If you are using our Website, you may browse anonymously unless you have completed an online application form, except as set out in this Section

For all visitors browsing our Website or using our App, we use cookies to collect information such as the server your device is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), the time of visit, pages visited and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address. We also use cookies to manage online advertising.

Such information collected in this way is not capable of personally identifying you.

5. What is the purpose for collecting personal information?
Coposit’s main purpose for collecting your personal information is to facilitate your use of the Coposit services. We only hold, use and disclose personal information about you for the purposes outlined in Section 2, or for related purposes which might be reasonably expected, unless we otherwise obtain your consent.

However, Coposit may also use the information collected for the following:

(a) to provide, maintain, protect and improve Coposit’s services;
(b) for verification purposes;
(c) for credit checks;
(d) for billing purposes;
(e) to develop new services;
(f) for analysis of usage of the Coposit services;
(g) to improve the content offered; or
(h) for marketing and promotion purposes.

Coposit will not be disclosing personal information to overseas recipients.

When you have provided Personal information for a particular purpose, we may disclose your information to certain third parties that we have engaged to assist us in fulfilling your request and in maintaining our database records. This includes, but is not limited to, data management companies. These third parties are permitted to use the Personal information only for the particular purpose for which they were asked to assist.

Coposit does not use or disclose Personal information for purposes other than the identified purpose for which it is collected, except with the consent of the individual or as required or permitted by law. By providing your personal information, you agree to the use of your personal information in this manner.

6. Direct marketing
From time to time, we may use the personal information collected from you for direct marketing purposes, promotions, special offers and other information which we think you may find interesting.

We may contact you by telephone, electronic messages (eg. email), online (including websites, push notifications, and mobile apps) and other means for these purposes.

If we do contact you in this way, it will only be in relation to matters that customers would reasonably expect us to contact them directly about. And we will ensure that our marketing activities comply with applicable law.

If you no longer wish to receive any direct marketing communication from us, please follow the instructions for unsubscribing in our direct marketing communications. If there are no instructions, please contact us as set out in Section 14 below.

We do not sell personal information to other third party organisations to allow them to contact you for direct marketing purposes.

7. Disclosure of Your Personal Information
Coposit will disclose your personal information in the following circumstances:

(a) if required by law;
(b) if Coposit believes, in its absolute discretion, it is in the public interest;
(c) to seek feedback, or monitor or improve quality of service;
(d) to entities who assist Coposit in providing, administering, supporting, improving, promoting and marketing the Services; to suppliers, contractors, debt collectors, data storage and management companies (including providers of cloud services), website hosting service providers, and interactive advertisers;
(e) to companies that promote and market, or conduct research to help Coposit improve and target the Coposit services;
(f) to related corporate bodies; or
(g) where Coposit otherwise obtains your permission to disclose the information, for example, where you opt to allow unrelated third parties access to certain documents.
Coposit may share aggregated, non-personally identifiable information publicly, for example, to show trends about the general use of Coposit’s services.
8. Credit information

We may collect the following kinds of credit information and exchange this information with credit reporting bodies and other entities:

• credit liability information being information about your existing finance which includes the name of the credit provider, whether the credit provider holds an Australian Credit Licence, the type of finance, the day the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;
• repayment history information which is information about whether you meet your repayments on time;
• information about the type of finance that you are applying for;
• default and payment information; and
• court proceedings information.

We exchange this credit information for the purposes of assessing your registration and managing our services.

This credit information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit information we hold about you.

When we obtain credit information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.

9. Security
We seek to maintain reasonable security measures in order to attempt to protect against the loss, misuse or alteration of Personal information under our control. Unfortunately, there is no such thing as perfect security. As a result, although we strive to protect your personally identifying information, we cannot ensure or warrant the security of any information you transmit to us through or in connection with our Website or App or that we store on our systems or that is stored on our service providers’ systems. Furthermore, to the extent permitted by law, Coposit accepts no responsibility and/or liability for any such disclosures of your Personal information.

You agree that no transmission of data over the Internet is guaranteed as wholly secure and that any information you provide to Coposit through the Internet, including via email, is at your own risk.

You may also assist Coposit in keeping your personal information secure by maintaining the confidentiality of your account information and notifying Coposit immediately if there is any unauthorised use of your account, or any other breach of security relating to your account.

10. Links
The Website and App contain links to third party websites. Coposit is not responsible for the information on these sites, or their privacy policies. Coposit may keep track of your interaction with third party websites provided on the Website in order to improve Coposit’s services and to aggregate statistics for the benefit of Coposit and other third party service providers.

11. Cookies
Data collection devices, called “cookies”, are files placed on your hard drive to collect information. Coposit may use cookies to enhance the use of the Coposit Website and App, not to record personal information. The recording of information about your use of the Coposit Website and App is useful for an overall analysis of traffic. Your browser will generally be set to automatically accept cookies.

If you do not want any cookies to be placed on your hard drive, you can change your browser settings to refuse them. However, this may also limit the way you view the Coposit Website or App.

12. Accessing and correcting Personal Information
12.1 Access
You are entitled under the Privacy Act to access the personal information we hold about you and (provided that it is reasonable and practicable) to do so in a manner that you request. You can make a request in a letter, by email or by telephone if you prefer. Please see our contact details in Section 15 below.

We will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal information.

We will need to validate the identity of anyone making an access request, to ensure that we do not provide your information to anyone who does not have the right to that information.

We will acknowledge your request within 5 business days and we will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances it may take longer.

Your rights to access your personal information are subject to some limitations. For example, we do not have to provide you with access to the extent it would be illegal to do so, if it would have an unreasonable effect on the privacy of others or the request is frivolous or vexatious.

If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.

12.2 Correction
We take reasonable steps to ensure that all personal information we hold is as accurate as possible. From time to time your personal information may change. It is important that you inform Coposit of changes to your details as and when they occur.

If you feel that the personal details we hold for you are incorrect, you are able to contact us at any time to request that we correct that information.

If you would like to do so please contact our Privacy Officer using the contact details in Section 15 below.

We will normally try to resolve correction requests within 30 days of you making a request. There will be no cost to you if we correct your personal information held by us.

13. Complaints
If you have any questions or concerns or about our Privacy Policy or about the privacy of your Personal Information, or if you are concerned that your privacy has been compromised, please contact Coposit at the following email address info@coposit.com.au. If we do not resolve a complaint to your satisfaction, you also have the right to complain to the Office of the Australian Information Commissioner, Tel: 1300 363 992 or email: enquiries@oaic.gov.au

14. Amendments
Coposit may amend this Privacy Policy from time to time. If Coposit does make amendments, the amended Privacy Policy will be published on the Coposit Website and made available through the App.

You agree that it is your responsibility to check for updates to Coposit’s Privacy Policy. You further agree that your continued use of the Website and App are acceptance of Coposit’s amendments to the Privacy Policy.

15. Further information
If you have any questions, concerns or feedback about privacy, please contact:

Privacy Officer
Address: PO Box 2718, North Parramatta 1750
Phone: +61 (2) 9191 0621
Email: info@coposit.com.au

Last updated 1 October 2021