PRIVACY POLICY

This is the privacy policy for FTA Data Solutions Pty Ltd (ACN 670 814 221) trading as Cigno (hereinafter referred to as ‘we’, ‘us’ ‘Cigno’). The privacy policy applies to the Cigno’s website (www.cignoloans.com.au) (Cigno Website).

Cigno respects your right to privacy and are committed to protecting the privacy of our customers and website visitors.

We are, or will be bound, by the Privacy Act 1988 (Cth) (Privacy Act), which sets out a number of principles concerning the privacy of individuals and businesses.

The purpose of this Privacy Policy is to tell you what kinds of ‘Personal Information’ (defined below) we may gather or hold about you, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of that information, your ability to access or correct that information and how you may complain, if you believe that we have breached our privacy obligations.

Please read this Privacy Policy carefully. Please contact us if you have any questions on the contact details provided at the end of this Privacy Policy.

By providing us with your Personal Information, you indicate to us that you have had sufficient opportunity to access this Privacy Policy and that you have read and accepted it. If you do not wish to provide your Personal Information to us, then you do not have to do so. However, it may affect our ability to provide services to you.

1. Collection of Personal Information
We may collect and store Personal Information from you directly or via your use of our application services.   We will only collect Personal Information which is reasonably necessary for, or directly related to, the provision of our services or activities in regards to your file.

1.1 What is Personal Information?
“Personal Information’ is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

1.2 What kinds of personal information do we collect and hold?
The Personal Information we may collect and hold varies and is dependent on the nature of our dealings with you. The kinds of Personal Information can include but is not limited to:

1. full name;
2. date of birth;
3. residential address;
4. email address;
5. home phone number;
6. mobile phone number;
7. loan amount sought;
8. loan term sought;
9. purpose for the Loan;
10. identification verification information such as Drivers Licence and Medicare Card;
11. bank account transaction history;
12. employment information; and
13. financial information such as income types, income frequency, whether receiving government benefits, immediate expenses.

By providing us your information you are giving your express consent for us, our intermediary partners and our network partners (including any associated credit providers) to contact you by way of email, SMS, Phone (including pre-recorded and computer-generated messages), push notification, user portal message, fax and other forms of communication for the purposes of customer service, debt collection, marketing and promotion.

In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing our services to you.

1.3 How do we collect your Personal Information?
Generally, when providing services to our customers, we collect Personal Information directly from the individuals where reasonable and practical.

We collect Personal Information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you.

We may receive Personal Information from third parties, such as from publicly available sources of information and our related companies. If we do, we will protect it as set out in this Privacy Policy. We will only collect your Personal Information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.

Further, by ticking the consent button or tick box, provided on the Cigno Website Information Form submission page, Cigno explicitly informs you and requires you to actively indicate your consent to the specific use of their personal information through our intermediary partners and network partners (including any associated credit providers). You may withdraw your consent at any time by contacting us.

2. Use of Personal Information
We may use Personal Information collected from you to provide you with information, updates and our services.

We may also make you aware of new and additional products, services and opportunities available to you. We may use your Personal Information to improve our products and services and better understand your needs. As our services include acting as an intermediary between you, our intermediary partners and our network partners (including any associated credit providers) to help find you an entity who can assist you with your financial or other needs, your Personal Information may be used by us and/or an entity within our intermediary partners or network partners (including any associated credit providers) in order to provide services to you,

We may use your Personal Information in the following ways:

1. to identify you, conduct customer identification procedures required by law and to communicate with you;
2. for internal record-keeping;
3. to provide our services to you;
4. to analyse customer needs, develop customer strategies and improve customer experiences;
5. for our market research and business development activities;
6. for marketing, including direct marketing;
7. to protect you and us from fraud;
8. to run competitions or offer additional benefits to you;
9. to comply with the our legal obligations;
10. to respond to any queries or complaints you may have; and
11. to forward to our intermediary partners and network partners so that they can use your Personal Information to select possible credit providers or providers of other goods or services which may be suitable for you.

We may contact you by a variety of measures including, but not limited to telephone, email, SMS, push notification or mail.

3. Disclosure of personal information
We may disclose your Personal Information insofar as reasonably necessary for the purposes set out in this Privacy Policy. Personal Information is only supplied to a third party when it is required for the delivery of our services. As our services include acting as an intermediary between you, our intermediary partners and our network partners to help you find an entity who can assist you with your financial or other needs, we may provide your Personal Information to an entity within our intermediary partners and network partners in order to provide our services to you,

We may also disclose your Personal Information to:

1. our intermediary partners for the purposes of lead generation to both financiers and non-financier entities;
2. third party businesses, including our network partners, that offer financial and other products or services that may be of interest or suitable to your needs;
3. the persons or entities from whom you are purchasing goods or services (including to entities who are part of our network);
4. other companies related to us;
5. external service providers who assist us in providing products and services to customers including operating trade promotions on our behalf;
6. professional service providers and advisors who perform functions on our behalf, such as lawyers; and
7. government, regulatory authorities and other organisations as required or authorised by law.

Organisations providing professional services to us are required to keep those dealings and Personal Information provided by us confidential unless required to disclose such direct information by statute or law.

In the case of contracted service providers and entities within our intermediary partners and network partners, we may disclose Personal Information to the contracted service provider or an entity within our intermediary partners and network partners and the contracted service provider or entity within our intermediary partners and network partners may in turn provide us with Personal Information collected from you in the course of providing the relevant products or services.

By providing us with Personal Information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Privacy Policy. Where we disclose your Personal Information to third parties (including entities within our intermediary partners and network partners), we will request that the third party follow this Privacy Policy regarding handling your Personal Information.

4. Sensitive information
The Privacy Act describes ‘sensitive information’ as information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information.

We do not collect sensitive information about our customers, however if you elect to provide sensitive information it will also be captured and stored by us in accordance with the terms of this Privacy Policy.

5. Holding your personal information
Information that we collect may from time to time may be stored, processed in or transferred between entities located in countries outside of Australia. In the event of this, you will be notified via email. For example, information may be stored, processed or transferred to our external service providers in Singapore and the Philippines.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any Personal Information and non- Personal Information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances. 

6. Communication and direct marketing
We may communicate with you by phone, email, SMS or push notification, to inform you about existing and new products and services that may be of interest to you.

We will ensure that any email we send as direct marketing complies with the SPAM Act 2003 (Cth) and contain an ‘unsubscribe’ option so that you can remove yourself from any further marketing communications. To opt-out of communications via SMS, reply with “STOP”. You may decline marketing messages sent by push notifications by refusing the relevant permission in your phone or tablet settings, however this setting will prevent you from receiving other messages from us via push notification. You may also opt-out of receiving marketing materials from us using the contact details set out below.

You can also call or write to us to request that your details be removed from our direct marketing list. We will endeavour to remove your details from our direct marketing list within a reasonable time (ordinarily 5 working days).

Our direct marketing list may be operated by software and servers located overseas and your Personal Information may be sent overseas as part of our marketing. For example, our marketing activities may be managed by our external service providers located in Singapore and the Philippines.

We will also send communications that we are required or necessary to send to users of the Cigno Website that contain information about important changes or developments to, or the operation of, the Cigno Website as well as other communications you request from us. You may not opt out of receiving these communications but you may be able to adjust the media and format through which you receive these notices.

We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.

We may use your Personal Information for direct marketing purposes.  If you do not wish to receive direct marketing communications from us or from other organisations (including entities within our lender network), or wish to know the source of the information being used, you may submit a request via email too: [email protected] We will respond to your request as soon as possible.

7. Information Form
When you send a completed Information Form to us, we retain the information contained in that form.  We (and entities within our intermediary partners) are able to then use that information to provide any services that you require. Our intermediary partners may then send your Personal Information to their network partners, including credit providers or providers of other goods or services.

You can also suspend and save the online Information Form, so you can complete and send the Information Form to us at a later time. If you suspend or save your Information Form, the information that you have entered will be retained in our systems so that you may recover the information when you resume your Information Form. Online Information Forms that have been suspended or saved may be viewed by us.

8. Overseas disclosure
We may disclose your Personal Information to our third party service providers for them to help us provide services to you. Our third party service providers may store or access your Personal Information overseas. For example, information may be stored, processed or transferred to our external service providers in Singapore and the Philippines.

9. Retaining personal information
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, or as required by law.

We will take reasonable steps to destroy or permanently de-identify Personal Information that is no longer needed for any purpose that is permitted by the Privacy Act.

10. Use of government related identifiers
We will not use government related identifiers (such as driver’s licence numbers) as our own identifier of individuals. We will only use or disclose such identifiers in the circumstances permitted by the Privacy Act.

11. Security of your personal information
We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that Personal Information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Our servers have SSL certificates, so all data transferred electronically between you and us is encrypted.

If we no longer require your information, and we are legally permitted to, we will take all reasonable steps to destroy or de-identify the information.

We take reasonable steps to preserve the security of cookies and Personal Information in accordance with this Privacy Policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).

For complaints, you can contact the Office of the Australian Information Commissioner (OAIC) and file a formal complaint with them. They can be contacted by phone on (07) 5644 3500, via email at [email protected] or in writing to GPO Box 5218 Sydney NSW 2001.

You can also visit the OAIC website at: www.oaic.gov.au

12. Access to your personal information
You may request details of Personal Information that we hold about you in accordance with the provisions of the Privacy Act. A small administrative fee may be payable for the provision of information, to cover our reasonable costs of retrieving that information.

If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected]. We will respond to any request within a reasonable time.

We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date. If we cannot take reasonable steps to correct the information because such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you. In these cases, we will provide reasons for denial of your correction request.

If we refuse to correct your Personal Information you have the right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take such steps that are reasonable in the circumstances to associate that statement with all records containing the relevant information.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. If we cannot provide access to your information, we will generally provide you with the reasons why and the mechanisms to complain about that refusal.

There is no cost involved for you to make a correction request or for the correction of your information.

13. Market Research
We on occasion will embark on market research to better understand your needs and views with regards to our services and therefore allow us to provide you with the best product or service for your needs.  We may use a third party polling, survey and research company such as Australian Survey Research (for ASR’s privacy policy, visit: aussurveys.com/privacy-policy/) or Survey Monkey (for Survey Monkey’s privacy policy, visit: surveymonkey.com/mp/legal/privacy-policy/) We may provide your name and contact information including phone numbers, mail and email address to these parties for the purpose only of contacting you and conducting the market research.  Your information will not be used by these companies for any other purpose.

14. Making a complaint and how it will be handled
If you believe that we have breached any obligation under Part IIIA of the Privacy Act from when it applies to us and wish to make a complaint about that breach, please contact us by email at [email protected] setting out details of the breach. We will promptly investigate your complaint and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint.

It would assist us to ensure we properly understand your complaint, and allow us to respond more promptly, if complaints are made in writing and include as much detail as possible.

We will deal with any complaint in a timely, effective and consistent manner.  We will acknowledge the receipt of your complaint within 7 days, and endeavour to make a decision on the complaint within 30 days after it is received.  If we need more time to resolve your complaint, then we will notify you as to the delay.

If you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the OAIC by visiting www.oaic.gov.au, emailing [email protected] or writing to GPO Box 5218 Sydney NSW 2001.

15. Changes to Privacy Policy
Please be aware that we may change this Privacy Policy in the future. We may modify this Privacy Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

16. Website
When you visit the Cigno Website, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

17. Advertising and tracking
When you view our advertisements on a third party website, the advertising company uses ‘cookies’ and in some cases ‘web beacons’ to collect information such as:

• the server your computer is logged onto;
• your browser type;
• the date and time of your visit; and
• the performance of their marketing efforts.

When you access our website after viewing one of our advertisements on a third party website, the advertising company collects information on how you utilise our website (eg which pages you view) and whether you complete an Information Form.

18. IP addresses
Your IP address is the identifier for your computer when you are using the internet.

As you interact through our website, your IP address will be collected.

19. Cookies
We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

20. Third party sites
The Cigno Website may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects Personal Information.

21. Enquiries
If you have any concerns or queries about our Privacy Policy, or if you would like more information about privacy-related issues, please contact us at:
Email: [email protected]
Mailing address: PO Box 1810, Southport BC, QLD, 4215