Fred Thomasian trading as Custom Mortgage Planning (ABN 76 110 509 670) (Credit Representative Number 501088) is authorised under National Lending Group Pty Ltd, Australian Credit Licence 412778.
We understand how important it is to protect your personal information. This Privacy Policy explains how Fred Thomasian trading as Custom Mortgage Planning (“CMP”, “we”, “us”) collects, holds, uses and discloses your personal information, and how you can access it, correct it or make a complaint.
This Policy also includes our credit reporting policy. It explains how we manage personal information collected in connection with a credit application or credit facility. We refer to this as “credit information”.
We are committed to complying with the Privacy Act 1988 (Cth), the Australian Privacy Principles, Part IIIA of the Privacy Act and the Credit Reporting Code when handling your personal information. A copy of the Australian Privacy Principles is available from the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
By providing personal information to us, you consent to its collection, use and disclosure in accordance with this Policy and any other arrangements that apply between us.
The types of information we collect and hold about you may include:
Over the course of our relationship, we may also collect transactional information and records of complaints or enquiries about products or services.
We may collect information about you because we are required or authorised by law to do so. For example, we need personal information to verify your identity under Australian anti-money laundering and counter-terrorism financing laws.
When you use our website, we may collect information you enter into forms and tools, and technical information such as your IP address, browser type and pages visited. Some features of our website are provided by third-party services, which collect information on our behalf:
| Website feature | Provider | What may be collected |
|---|---|---|
| Booking a consultation | Calendly | Name, email, phone number, booking details and any notes you provide |
| Workshop readiness questionnaire | ScoreApp | Contact details and your questionnaire answers |
| Mortgage and property calculators | LS Broker | The figures you enter and any contact details you submit |
| Client relationship management and email communications | GoHighLevel and Brevo | Contact details and records of our communications with you |
| Website hosting | Netlify | Technical information such as IP address and browser data |
Each provider also has its own privacy policy, which applies to the information it handles.
If you start but do not complete an enquiry or application, we may contact you using the details you have supplied to offer help completing it.
Some clients engage with us through social media. We may collect information about you when you interact with us through those channels. For confidential matters, we will communicate with you through a secure channel.
Unless it is unreasonable or impracticable, we will collect personal information directly from you. We may collect it when you complete a form, call us, email us, meet with us or use our website. We also use electronic means, such as email or SMS, to communicate with you and verify your details. Please help us by keeping your contact details up to date.
Sometimes we collect information about you from other sources, as the Privacy Act permits, where it is reasonably necessary. For example, where:
We collect credit information when you answer the enquiries we make about the credit assistance you are seeking. Other sources of credit information include:
With your authority, we may act as your agent (an “access seeker”) to obtain your credit information from a credit reporting body for the purpose of assisting you with your finance application. You authorise us to disclose credit information we obtain to prospective lenders in connection with your application.
If you do not provide the information we ask for, we may not be able to:
If we receive personal information about you that we did not ask for (“unsolicited information”), we will check whether it is reasonably necessary for our functions or activities. If it is, we will handle it in the same way as other information we collect. If it is not, we will destroy or de-identify it where lawful and reasonable to do so.
When we collect personal information from you, we will take reasonable steps to tell you how and why we collected it, who we may disclose it to, and how you can access it, seek its correction or make a complaint. If we collect information about you from a third party, we will take reasonable steps to notify you of that collection.
Sensitive information includes information about a person's racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or practices, criminal record, and health information.
We only collect sensitive information with your consent and where it is reasonably necessary for our services (for example, health information you choose to provide in support of a hardship request), or where the law requires or permits it.
We collect, hold and use your information so we can provide the products and services you have asked for, including to:
We may use your personal information to tell you about other products, services, events and educational resources offered by us or by third parties that may interest you. Every marketing email or SMS we send will include a simple way to unsubscribe, and you can ask us at any time to stop sending you marketing. We will process your request as soon as practicable.
With your consent, we may disclose your personal information to third parties to connect you with other businesses. You can ask us not to do this at any time. We do not sell your personal information.
We may share your information with others for the purposes described in this Policy, including:
National Lending Group may collect personal information about our clients to manage enquiries or complaints, pay commissions or conduct file reviews. You can read how it manages personal information at www.nlg.com.au/privacy-policy.
Some of the software providers we use store or process information outside Australia, including in the United States, the United Kingdom and the European Union. Because information held in cloud-based storage can be accessed from various countries, it is not always practicable to know exactly where your information is held.
Before disclosing personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles, or we seek your consent. Overseas recipients may be required to disclose information under foreign law.
Our website and the third-party tools on it may use cookies — small files stored on your device — and similar technologies. These help the website and tools work properly, remember your preferences, and help us understand how visitors use the site so we can improve it. Some cookies may record information such as your IP address, which can be personal information when combined with other details. We handle any personal information collected this way in line with this Policy.
You can set your browser to refuse cookies, although some parts of the website, such as the booking tool or calculators, may then not work properly.
We hold information in paper and electronic form and take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include:
Where we use third-party data storage providers, we rely on contractual arrangements and the providers' security measures to protect your information and restrict how it may be used.
We keep your information only as long as we need it for our purposes or as required by law. When we no longer need it, we take reasonable steps to destroy or de-identify it.
If we suspect a data breach that may cause you serious harm, we will take all reasonable steps to assess it promptly, and within 30 days. If we find an eligible data breach has occurred, we will notify you and the Office of the Australian Information Commissioner as required under the Notifiable Data Breaches scheme.
You can ask us in writing to access the personal information we hold about you. In some cases we may be able to deal with your request by phone. We will give you access in the form you request where reasonable and practical. We may charge a reasonable fee to cover the cost of providing access, but we will tell you first, and there is no charge to make a request.
We may refuse access in limited circumstances permitted by law, including where:
If we refuse access, we will tell you why in writing and how you can complain.
Contact us if you think information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, and we will take reasonable steps to correct it. If we have given incorrect information to others, you can ask us to tell them about the correction. If we cannot do this, we will let you know in writing.
Whether we or someone else made the mistake, we will help you ask for credit information to be corrected. To do this, we may need to consult others. The most efficient way to make a correction request is usually to send it to the organisation that made the mistake.
If you have a complaint about how we have handled your personal information, please contact us:
Fred Thomasian, Custom Mortgage Planning
Sydney NSW 2112
Phone: 0423 405 650
Email: fred@custommortgageplanning.com
We will acknowledge your complaint promptly. Most complaints are resolved quickly, and you should hear from us within five business days. We aim to resolve all complaints within 30 days. If we need more time, we will tell you why and how long we expect it to take.
If your complaint relates to how we handled a request to access or correct your credit information, you may take it directly to AFCA or the OAIC — you do not have to let us try to resolve it first. For other complaints about credit information, we will let you know how we will deal with the complaint within seven days, and give you our decision within 30 days or a longer agreed period.
If your complaint is not resolved to your satisfaction, you can contact our licensee, National Lending Group Pty Ltd, at complaints@nlg.com.au or on 1300 653 480. You can also contact:
Australian Financial Complaints Authority (AFCA)
Online: www.afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678 (free call)
Mail: GPO Box 3, Melbourne VIC 3001
Office of the Australian Information Commissioner (OAIC)
Online: www.oaic.gov.au/privacy
Phone: 1300 363 992
Enquiry form: www.oaic.gov.au/enquiry
Mail: GPO Box 5288, Sydney NSW 2001
For general enquiries, you can choose to deal with us anonymously or use a pseudonym. We will not be able to do this where it is impracticable, or where the law or a court or tribunal order requires us to deal with identified individuals, which is generally the case when providing credit assistance.
In some circumstances we may need to collect government-related identifiers, such as your tax file number or driver licence number. We will not adopt these as our own identifier, or use or disclose them, unless authorised by law.
We may update this Policy from time to time. The current version will always be available on our website. If you would like a copy of this Policy in another form, please contact us and tell us how you would like to receive it.
If you have any questions about this Policy or how we handle your personal information, please contact Fred Thomasian, Custom Mortgage Planning, on 0423 405 650 or at fred@custommortgageplanning.com.