Privacy Policy

1. Introduction

Vertex Capital Pty Ltd (ABN 48 678 906 833) (“Vertex Capital”, “we”, “us” or “our”) is committed to protecting the privacy of personal information we collect, hold, use and disclose. We are bound by the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”) contained in that Act.

This Privacy Policy describes how we manage personal information and sets out your rights regarding access to and correction of your personal information. By providing your personal information to us, you consent to its collection, use and disclosure in accordance with this Privacy Policy.

2. What Personal Information We Collect

The types of personal information we may collect include, but are not limited to:

• Full name, date of birth, gender, marital status and contact details (address, email, telephone number)
• Identification documents (driver’s licence, passport, proof of age)
• Financial information including income details, assets and liabilities, bank statements, tax returns and financial statements
• Credit information obtained from credit reporting bodies (such as Equifax)
• Employment and business details, including ABN/ACN, directorship and shareholding information
• Property and security details, including valuations and title information
• Information about your dealings with us, including loan applications, account balances, repayment history and correspondence
• Information obtained from identity verification, anti-money laundering (AML), counter-terrorism financing (CTF) and sanctions screening checks
• Any other information you provide to us in connection with your loan application or ongoing loan facility

We may also collect sensitive information where required or authorised by law, such as information needed to verify your identity or comply with our AML/CTF obligations.

3. How We Collect Personal Information

We collect personal information in a number of ways, including:

• Directly from you — when you submit a loan application, provide documents, correspond with us by email, telephone or through our online portal
• From mortgage brokers, aggregators and other intermediaries who submit applications on your behalf
• From credit reporting bodies (e.g. Equifax)
• From publicly available sources, including ASIC registers, the Personal Property Securities Register (PPSR), bankruptcy registers, court records and sanctions lists
• From your accountants, solicitors, valuers, real estate agents and other professional advisers
• From existing or previous lenders and financiers
• From government agencies and regulatory bodies

Where it is reasonable and practicable to do so, we will collect personal information directly from you. If we receive unsolicited personal information that we do not require, we will destroy or de-identify that information as soon as practicable.

4. Purpose of Collection, Use and Disclosure

We collect, hold, use and disclose your personal information for purposes including:

• Assessing and processing your loan application
• Conducting credit checks, identity verification and background screening (including AML/CTF and sanctions checks)
• Establishing, managing, administering and enforcing your loan facility
• Communicating with you about your loan or application
• Monitoring loan performance, arrears management and collections
• Meeting our legal and regulatory obligations, including reporting to AUSTRAC
• Obtaining and maintaining insurance
• Managing our relationship with wholesale funding providers
• Internal management, audit, risk management and training purposes
• Resolving disputes and enforcing our rights
• Any other purpose you have consented to or that is required or authorised by law

5. Disclosure of Personal Information

We may disclose your personal information to the following third parties:

• Wholesale funding providers and investors — who fund or may fund your loan, including for credit assessment, loan settlement, ongoing monitoring and portfolio reporting
• Credit reporting bodies — such as Equifax, for obtaining credit reports and, where applicable, reporting credit-related information
• Mortgage brokers and aggregators — who introduced your application
• Valuers — engaged to provide property valuations
• Our legal advisers and solicitors — for loan documentation, settlement, enforcement and legal proceedings
• Accountants and auditors — for financial reporting and compliance
• Debt recovery agents and receivers — in the event of default
• Insurance providers — in connection with professional indemnity and other insurance coverage
• Government and regulatory bodies — including ASIC, AUSTRAC and the ATO, where required by law
• IT service providers — who host, maintain or support our systems and data, subject to contractual confidentiality obligations
• Identity verification and screening providers — for KYC, AML/CTF and sanctions compliance

We will not sell, rent or trade your personal information to any third party for marketing purposes.

6. Credit Reporting

We may obtain credit reports about you from credit reporting bodies such as Equifax Pty Ltd. We use credit reporting information to assess your creditworthiness and suitability for a loan. You have the right to request access to the credit reporting information we hold about you and to request correction of any inaccurate information. You may also request that a credit reporting body not use your credit reporting information for the purposes of pre-screening or direct marketing.

7. Overseas Disclosure

Vertex Capital stores all data within Australia. We do not ordinarily disclose personal information to overseas recipients. If it becomes necessary to disclose personal information to a recipient outside Australia, we will take reasonable steps to ensure that the overseas recipient handles your information in accordance with the APPs, or that you consent to the disclosure.

8. Data Security

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Our security measures include:

• Secure, encrypted storage of electronic data on Australian-hosted servers
• Multi-factor authentication (MFA) for access to our systems and portals
• Role-based access controls limiting access to personal information on a need-to-know basis
• Regular automated backups with appropriate retention periods
• Physical security measures for any paper records
• Confidentiality obligations on all staff and contractors

We will destroy or permanently de-identify personal information when it is no longer needed for any purpose for which it may be used or disclosed under the Privacy Act, unless we are required by law to retain it.

9. Access and Correction

You have the right to request access to the personal information we hold about you, and to request correction of any information that is inaccurate, incomplete, out-of-date or misleading.

To request access to or correction of your personal information, please contact our Privacy Officer using the details in Section 13. We will respond within a reasonable period (generally within 30 days). We may charge a reasonable fee for providing access to cover administrative costs. In certain circumstances, we may refuse to provide access — for example, if providing access would unreasonably impact the privacy of another individual. If we refuse access, we will provide you with written reasons.

10. Complaints

If you believe that we have breached your privacy or mishandled your personal information, you may lodge a complaint with our Privacy Officer. We will acknowledge receipt within 5 business days, investigate and provide a written response within 30 days, and take appropriate remedial action if your complaint is substantiated.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):

11. Notifiable Data Breaches

In the event of an eligible data breach (as defined under Part IIIC of the Privacy Act), we will comply with the Notifiable Data Breaches scheme and notify affected individuals and the OAIC as required.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The most current version will always be available on this page.

13. Contact Us

If you have any questions about this Privacy Policy, wish to access or correct your personal information, or wish to make a complaint, please contact our Privacy Officer: