Privacy Policy

Your Privacy is Important to Us

This privacy policy applies to Ethical Finance Australia Pty Ltd (ABN 12 601 144 932) trading as Impact Brokers (Credit Representative No. 466398) and Yasmine Shah (Credit Representative No. 540047), who are Authorised Credit Representatives of QED Credit Services Pty Ltd (Australian Credit Licence 387856).

We want you to be confident that the personal information you provide to us is treated with the highest degree of integrity and privacy. At the same time, we are committed to delivering exceptional service and fulfilling our legal obligations to act in your best interests when providing credit assistance.

We recognise that any personal information we collect about you will only be used for the purposes outlined in this policy or as permitted by law. In handling your personal information, we are committed to complying with:

• Privacy Act 1988 (Cth)
• Australian Privacy Principles (APPs)
• National Consumer Credit Protection Act 2009
• All applicable Australian regulations and credit legislation

What is “Personal Information”?

Personal information is any information or opinion about you where you are identified, or your identity can reasonably be ascertained. This includes both true and false information, whether recorded or not.

Examples include your name, contact details, date of birth, financial details, employment information, and identification documents. Sensitive information (such as health or criminal history) is only collected with your consent or when legally required.

Why We Collect Personal Information

We collect personal information to:

Fulfil Our Best Interests Duty: Under the National Consumer Credit Protection Act 2009, we are legally required to act in your best interests when providing credit assistance. To do this, we must:

• Make detailed enquiries about your financial circumstances and goals
• Assess what products and credit assistance are in your best interests
• Consider your individual needs, objectives, and preferences
• Document how we have acted in your best interests

Meet Responsible Lending Obligations: We must make reasonable enquiries about your situation, requirements, and objectives to ensure any credit product is not unsuitable for you.

Provide Credit Assistance Services: We use your information to assess eligibility, compare loan options, prepare and submit applications, communicate throughout the process, and manage our ongoing relationship.

Comply with Legal and Regulatory Requirements: We are required to collect, use, and retain information to meet our obligations under credit laws, anti-money laundering legislation, and ASIC record-keeping requirements (RG 273).

Collection of Information

We collect personal information:

• When you apply for or enquire about our services
• During meetings, phone calls, or online interactions
• From third parties such as lenders, brokers, accountants, or credit reporting agencies

We aim to collect information directly from you and will always explain the purpose, use, and disclosure of any information we collect.

Use and Disclosure of Personal Information

We may use or disclose your information to provide credit assistance, manage our relationship with you, comply with legal obligations, or engage service providers that support our operations.

Specific Uses for Best Interests Duty Compliance: We use your information to assess your circumstances, compare lender options, manage potential conflicts, and document recommendations that demonstrate compliance with our legal obligations.

Credit Reporting: We may disclose your information to credit reporting bodies, including:

• Equifax Australia
• Experian Australia
• illion (formerly Dun & Bradstreet)

These bodies may include your information in reports to credit providers. You can access or correct your credit information by contacting these organisations directly.

Third-Party Disclosures: We may share information with lenders, mortgage insurers, legal or accounting professionals, auditors, regulators, or government authorities where required.

Some overseas disclosures may occur (e.g. with licensed audit teams in India) under privacy obligations equivalent to Australian standards.

Other Information We Collect

We may use cookies and tracking tools (such as Google Analytics and Meta Pixel) to analyse site traffic and improve website performance. These collect non-identifiable data.

You can manage cookie preferences or opt out of tracking via your browser or at
www.allaboutcookies.org.

Direct Marketing

We may contact you about finance products, services, or educational content. You can opt out at any time by contacting us or using the unsubscribe link in our communications.

Keeping Your Information Up to Date

Please notify us of any changes to your personal details. You may request corrections or updates at any time to ensure your information remains accurate and complete.

Security and Storage

We take reasonable steps to protect personal information from misuse, loss, unauthorised access, modification, or disclosure. Information is stored securely in electronic and/or physical form.

Record Retention

We are required by law to retain certain credit assistance records to demonstrate compliance with our Best Interests Duty and Responsible Lending obligations.

What We Retain:

• Records of enquiries about your financial circumstances
• Documentation of assessments and recommendations
• Product comparisons, loan applications, and correspondence
• Records of identified conflicts of interest

Retention Periods:

• Credit assistance and responsible lending records: minimum 7 years
• Other business records: as required by law

Records may be retained longer if a loan term exceeds seven years, a complaint or legal matter is ongoing, or regulatory obligations require extended retention.

Access and Correction

You have the right to request access to the personal information we hold about you. To do so, contact us using the details below.

Processing Requests:

• We will respond within 30 days
• A reasonable fee may apply if retrieval requires significant effort
• We will advise you of any applicable fees before processing

Reasons Access May Be Denied:

• If providing access poses a risk to life, health, or safety
• If it unreasonably impacts another person’s privacy
• If it relates to ongoing legal proceedings or law enforcement
• If the request is frivolous or vexatious

If we deny access or correction, we will explain why and inform you of your right to complain. You may also request corrections if you believe information is inaccurate, out-of-date, or incomplete.

Use of Government Identifiers

We do not use government identifiers (such as tax file numbers) to identify you. These are only used or disclosed as required by law.

Collection of Sensitive Information

Sensitive information (e.g. health or criminal history) is only collected with your consent or when legally required. If received from third parties, we will seek your consent before use or storage.

Changes to This Privacy Policy

This policy may be updated to reflect changes in law, technology, or business practices. Updates will be published on our website with an updated Effective Date.

Complaints

If you have concerns about how we’ve handled your personal information or believe we’ve breached the Privacy Act 1988 or Australian Privacy Principles, please contact us:

• Email: yasmine@ethicalgroup.finance

How We Handle Complaints:

1. Acknowledge your complaint within 1 business day
2. Investigate and aim to resolve within 30 calendar days
3. Keep you informed if delays occur
4. Provide written outcome and reasoning

External Review Options:

If unresolved, you may contact the following:

Office of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au
Mail: GPO Box 5218, Sydney NSW 2001

Australian Financial Complaints Authority (AFCA)
Phone: 1800 931 678
Email: info@afca.org.au
Website: www.afca.org.au
Mail: GPO Box 3, Melbourne VIC 3001

Effective Date: October 2025