Effective Date: 07/02/2022
This service is offered by Harvey Pence Pty Ltd (“Harvey Pence”, “we”, “us” or “our”) in collaboration with third parties. We respects your privacy. To be transparent, we’ve set out here what personal information we collect, what we do with it and your choices and rights.
Our Cookie section describes what we do in that regard. We also host and process User Content for our Users. Our Users tell us what to do with User Content, and we follow their instructions. If you want to know about what we do for our own purposes, read on.
3. Personal information we collect
We collect various personal information regarding you or your device. This includes the following:
a. Information you provide to complete a loan health check, specifically name, email address, type of loan, loan amount and interest rate.
b. Information we get from our partners to support our Services and better monitor, manage and measure our marketing campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
c. Information from your use of the Services, including: IP addresses, preferences, web pages you visited before coming to our or our Users’ sites, information about your browser, network or device (such as browser type, browser version, operating system, internet service provider, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, load times, and problems you may encounter).
d. Your marketing preferences and information you share with us from marketing activities.
e. The communications you send us or otherwise contribute, such as customer support inquiries or posts to our customer forums.
f. Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Account (based on your privacy settings with such Third Party Service).
4. How we collect personal information
We obtain personal information from various sources in three main ways:
a. Personal information you provide
When you use our Services, we collect information from you during your usage of the Services. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute. You might also provide us with information in other ways, including by responding to marketing surveys and promotions by submitting a form.
b. Personal information obtained from your use of our Services
When you use our Services, we collect information about your interactions with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission, we may collect your location information.
c. Personal information obtained from Third Party Services
If you use a Third Party Service (such as Google) to assist with running a Loan Health Check, the Third Party Service may provide us with publicly available information about you, your company, your address and customer reviews. Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.
5. How we use your personal information
We use the personal information we obtain about you to:
a. Communicate with you about your usage of our Services and send you tailored marketing offers and promotions.
b. Provide and personalize our Services, process payments and respond to your inquiries.
c. Review interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you.
d. Customizing, improve the services we offer and developing new services by understanding how these are accessed and used.
e. Secure your information and integrity of our Services overall.
f. Enforce our Terms and other legal terms and policies.
g. Administer surveys, contests and other promotions.
h. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
i. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.
j. Manage our vendor and partner relationships.
6. We process your personal information for the above purposes when:
a. Consent has been given to use your personal information in a particular way. You may update your consent at any time.
b. We need your personal information to provide you with Services requested by you, or to respond to your inquiries.
c. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
d. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
i. To operate the Harvey Pence business and provide you with tailored advertising and communications to develop and promote our business.
ii. To review and improve the safety and security of our Services, including but not limited to enhancing security measures and protections and protecting against fraud, spam and abuse.
iii. To share your personal information with other Harvey Pence Pty Ltd divisions that help us provide and improve the Services.
iv. To anonymize and subsequently use anonymized information.
v. To provide and continuously improve the Services.
e. To protect your vital interests, or those of others.
f. Protect others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness.
7. How we share your personal information and that of your customers?
We share personal information in the following ways:
a. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
b. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party
Services, but only when you have been informed or would otherwise expect such sharing. c. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.
d. We transmit your personal information via an encrypted connection to our payment processor.
e. We share your personal information with the business you have requested us to refer you to.
f. Following the law or protecting rights and interests by disclosing your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or prevent fraud or abuse of Harvey Pence or our Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
g. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness.
h. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred.
8. Your rights and choices
Where applicable law requires (and subject to any relevant legal exceptions) you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information by contacting us at email@example.com to request the required changes. You can exercise your other rights (including deleting your information) by contacting us.
To elect not to receive marketing communications unsubscribe from the relevant communications you wish to no longer receive.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law.
You can take your complaint to the Office of the Australian Information Commissioner, whose contact details are as follows:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
If you are subject to EU data protection laws, which is a jurisdiction we do not offer our services in, we suggest you lodge any such complaints with our lead supervisory authority:
Irish Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 57 868 4757
Fax: +353 57 868 4757
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
Our Cookies Section explains how you can manage cookies and similar technologies.
9. How we protect your personal information
While no service is completely secure, keeping personal information safe and secure is built into everything we do. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as protecting against vulnerabilities, using firewalls and building redundancies throughout our network to secure and maintain our Services.
10. How we retain your personal information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include recommended as best practice and the required retention periods detailed by law, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria.
We keep your personal information for a reasonable period of time, so it will be there for you when you return.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.
11. Data transfers
Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, from Australia to our servers in the U.S. We also store personal information locally on the devices you use to access the Services. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
13. Who is Harvey Pence?
When we say “Harvey Pence” (or “we”, “us” or “our”), we mean: (a) Harvey Pence Pty Ltd.
d. We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or browser to gather information about your activities on the Services.
e. You can set your browser to not accept cookies, but this may limit your ability to use the Services. We currently don’t respond to DNT:1 signals from browsers visiting our Services. You can also opt out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).
f. We may use and manage third party tags on the website and associated domains of www.loantools.com.au. Third party tags may take the form of pixels or tracking snippets. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience. We use tracking snippets to capture data from your browser, make requests to a third party partner or set cookies on your device to store data. This may cause other tags to be activated which may, for their part, collect data and set cookies under certain circumstances.
15. How to contact us
Harvey Pence Pty Ltd
Attention: Legal - Privacy
PO Box 628
Sydney, NSW 1360