XIN Group Privacy Policy

1. XIN Group's Commitment to Maintaining Your Privacy

XIN Group Pty Ltd ACN 697 905 034 (XIN Group, we, us or our) is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and any applicable privacy codes.

XIN Group owns and operates the website located at www.xin.com.au, including any client portal, customer relationship management interface, online forms, digital tools, documents and related systems made available through that website (Site).

This Privacy Policy explains how XIN Group collects, holds, uses and discloses personal information in connection with your access to and use of the Site and related systems.

This Privacy Policy does not, by itself, govern the provision of credit assistance, mortgage broking, lending, financial services, financial advice, wealth management or other regulated services by another service provider. If you request or receive those services, the relevant service provider may collect, use and disclose your personal information under its own privacy policy, privacy consent, credit guide, financial services guide, engagement terms or other client documents.

The Site may contain information about, or facilitate enquiries or referrals to, separate businesses that are authorised to use the XIN brand or access XIN Group's website, CRM, client portal or other shared systems under contractual arrangements (each a XIN Business, and together the XIN Businesses).

XIN Businesses may include mortgage, credit, financial services, wealth management or related service providers that use the XIN brand.

Unless expressly stated otherwise, XIN Businesses are separate legal entities and are responsible for the services they provide. XIN Group is not responsible for those services unless XIN Group is expressly identified as the service provider.

Nothing in this Privacy Policy should be read as stating or implying that any XIN Business is a subsidiary, franchisee, partner, agent or related body corporate of XIN Group, unless expressly stated.

Where you submit an enquiry, create a profile, request services or use the Site in a way that relates to a XIN Business, XIN Group may disclose your personal information to the relevant XIN Business so that your enquiry, request, application or service relationship can be managed.

This Privacy Policy should be read together with the XIN Group Website Terms and Conditions and any other terms, notices or consents made available through the Site.

When you register with us or a XIN Business, we create your profile in our CRM so you can log in to this website to view your information and access additional services.

Where a XIN Business provides you with credit assistance, financial advice or other regulated services, that XIN Business is responsible for its own handling of your personal information in connection with those services. XIN Group may also handle your personal information where it operates the website, client portal, CRM, shared systems, administration, marketing, client support or referral arrangements used by the XIN Businesses.

This Privacy Policy should be read together with any privacy policy, credit reporting policy, financial services guide, credit guide, terms and conditions or other disclosure documents provided to you by the relevant XIN Business.

We may, from time to time, review and update this policy, including to take account of new or amended laws, new technology and/or changes to our operations. All personal information we hold will be governed by the most recently-updated policy. The latest version of the policy will be available on our website. The updated version will apply from the date it is published, unless otherwise stated.

2. Collecting Personal Information

Personal Information is any information or opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is stored in a material form or not.

Personal information may include your name, contact details, date of birth, identification information, financial information and information about your interactions with us or a XIN Business.

Some information may also be sensitive information, such as health information, tax file numbers or information about memberships or affiliations. We only collect sensitive information where it is reasonably necessary for our functions or activities and where we are permitted by law to do so, including where you have provided consent.

We only collect personal information that is directly related to, or reasonably necessary for, our functions and activities.

The kinds of personal information we may collect include:

your name, address, phone number, email address;
your date of birth and identity verification information;
employment, income, asset, liability and expense information;
bank account, loan, credit, superannuation, investment or insurance information;
information about products or services you have requested, acquired or enquired about;
information submitted through our website, client portal, CRM, online forms, calculators or enquiry tools;
communications between you and us or between you and a XIN Business;
information required to support referrals, applications, onboarding, administration, compliance or customer support;
website usage information, including IP address, device information, browser type, cookies and analytics data;
records of consents; preferences and marketing communications;
any other information reasonably necessary for us or a XIN Business to provide services, operate systems, manage client relationships or comply with legal obligations; and
certain internet-related details (see below).

If you provide personal information about another person, you must only do so where you have authority to provide that information and, where required, have made that person aware of this Privacy Policy.

Wherever practicable, we will enable you to deal with us anonymously or pseudonymously, however, in many cases it is not practicable to interact in this way.

If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services or information you or they are seeking.

XIN Group registered members

As part of registering with us, we collect personal information about you in order for you to take full advantage of our services. The types of information we collect include your name, contact details (including phone numbers and physical and electronic addresses), as well as financial information including what products and services you receive, account numbers and bank account details.

Website users

We collect information about visitors to our website on an aggregated basis, including which sections of the site are most frequently visited, how often those sections are visited and for how long visitors spend on them.

This data is always used as aggregated, non-personal information. We utilise this information to improve and enhance our services by monitoring the areas on the site which are most popular to you. This aggregated information may be shared with our service providers, business partners and XIN Businesses to provide them with an overview of how our visitors use the website. This information is used for reporting, analytics and service improvement purposes and does not identify individual users.

IP Addresses

Our web servers may collect your IP address to assist with website administration, security monitoring, diagnosis of technical issues and support services. Where this information is collected for analytics or reporting purposes, it is generally used in an aggregated or de-identified form. However, in some circumstances, an IP address may constitute personal information if it can reasonably identify an individual.

Cookies & Applets

We use cookies and similar technologies to improve user experience. These cookies allow us to increase your security by storing your section ID and as a way of monitoring single user access. This aggregate, non-personal information is collated and provided to us to assist in analysing the usage of the website. You may disable cookies through your browser settings. However, some parts of the website may not function properly if cookies are disabled.

How we collect personal information

Where reasonable and practicable, we collect personal information directly from you.

We may collect personal information when you:

access or use the Site;
create an account or profile;
use the client portal or CRM interface;
complete an online form, enquiry form, calculator or digital tool;
upload documents or information through the Site;
subscribe to communications or request information;
contact us by email, telephone, website form or other communication channel;
provide feedback or make a complaint; or
otherwise interact with us through the Site or related systems.

In some circumstances, it may be necessary or appropriate to collect personal information from a third party, including where this is required to provide services, verify information, manage an application or comply with legal and regulatory obligations.

You consent to us collecting information from these third parties as part of our provision of services to you.

Third parties may include relevant XIN Businesses, referral partners, technology providers, identity verification providers, credit reporting bodies, professional advisers, regulators and other service providers.

3. Purpose of collection

We collect personal information from you for the purpose of providing our services to you, as well as for the purposes set out below:

operating, maintaining and improving the XIN website, client portal, CRM and related systems;
creating, administering and managing your XIN profile or account;
enabling you to access information, documents, services and features through the website or client portal;
referring you to, or communicating with, the relevant XIN Business;
assisting a XIN Business to provide services to you;
responding to enquiries, requests, complaints and feedback;
providing customer service and technical support;
managing client relationships and service history;
processing registrations, applications, instructions and transactions;
verifying your identity and information provided by you;
conducting analytics, research, reporting and business improvement activities;
sending service communications, administrative updates and information about changes to our website, systems or services;
sending marketing communications where permitted by law;
managing risk, security, fraud prevention and system integrity;
complying with legal, regulatory, licensing, contractual and compliance obligations;
assisting with audits, dispute resolution, investigations and enforcement of rights; and
any other purpose notified to you at the time of collection or otherwise permitted by law.

4. Use and disclosure

Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above). We may disclose personal information about you to third parties including:

XIN Businesses and their authorised representatives, credit representatives, employees, contractors and service providers;
lenders, aggregators, mortgage managers and credit providers;
financial product issuers, platform providers, insurers, superannuation funds and investment providers;
credit reporting bodies, identification verification providers and fraud prevention services;
professional advisers, including lawyers, accountants, auditors and compliance consultants;
technology, hosting, data storage, CRM, email, analytics, marketing and cyber security providers;
payment processors and administration service providers;
referral partners and business partners, where permitted by law;
regulators, government agencies, courts, tribunals and law enforcement bodies;
parties involved in a business sale, restructure, merger, acquisition or transfer of assets; and
any other person or organisation where you have consented or where disclosure is required or permitted by law.

We also provide you with selected information about our documents and website changes in our email communication. This free service is sent to registered users and provides the option of opting out of receiving these by unsubscribing. We may also make you aware of additional products and services which form part of your relationship with us.

5. Storage & Security of Personal Information

We hold personal information in electronic and, where applicable, physical form. Personal information may be stored in our website systems, CRM, client portal, email systems, document management systems, cloud storage platforms and other secure business systems.

We take reasonable steps to protect your personal information from misuse, loss, interference, unauthorised access, modification and disclosure. These may include:

access controls and user permissions;
password protection and authentication measures;
secure hosting and data storage;
encryption or other technical safeguards where appropriate;
confidentiality obligations for staff, contractors and service providers;
system monitoring and security controls;
data backup and recovery procedures; and
internal policies and procedures for handling personal information.

No method of transmission or storage is completely secure. You are responsible for keeping your login details, passwords and account credentials confidential and for notifying us promptly if you suspect unauthorised access to your account.

Any personal information we hold about you is stored on secure servers or in secure systems. Our employees, contractors and service providers who access or support our information systems are required to maintain the confidentiality of personal information held by us.

You also play an important role in protecting your personal information by keeping confidential any username, password, account details or other credentials used to access the XIN Group website, client portal or related systems.

6. Overseas Disclosure

Some of our service providers or technology providers may store, process or access personal information from locations outside Australia. The countries in which information may be stored or accessed may vary depending on the service providers used from time to time.

Where we disclose personal information overseas, we will take reasonable steps to ensure that the disclosure is consistent with the Privacy Act and the APPs, unless an exception applies.

7. Access and correction

We aim to ensure only required data is held and that all data is complete and accurate. If you are a registered user, you may be able to change and update your profile at any time through the website or client portal. We encourage you to do this to help us ensure that your personal information that we hold is up to date, accurate and complete.

Should you require assistance with updating your data or removing your details, this can be done by forwarding an email to: clientservice@xin.com.au. Users may unsubscribe from our services at any time also by contacting us (per the contact details below). We will respond within a reasonable time.

If personal information you have provided us has changed or your circumstances change, or you believe that the data we hold is not accurate, you can also contact us (as per the contact details below) and request access to, or correction of, your personal information. We will respond to your request within a reasonable time. If we refuse your request for access or correction, we will give you written reasons (unless it would be unreasonable or unlawful to do so) and, in the case of a request for correction, a statement setting out the mechanisms available to you to make a complaint.

8. XIN Group Partners & Advertisers

Our website may contain links and passes to third party websites and services. We are not responsible for the privacy practices, security or content of third party websites. You should review the privacy policy and terms of use of any third party website you access.

9. Complaints and Feedback

We welcome ideas and feedback about all aspects of the website. We store feedback that users send to us. This feedback will be used to administer and refine the service and may be shared with our partners either in aggregate form or with specific identifying characteristics removed.

If you have a complaint about how we have handled your personal information or a breach of this Privacy Policy or the Privacy Act, please contact us as set out below. We will investigate your complaint within a reasonable time. We may need to request further information from you to assess and respond to your complaint.

Contact Details:

XIN Group Client Service Team

Tel: 1800 896 817

Email: clientservice@xin.com.au

Postal address: Suite 502, 80 Mount Street, North Sydney NSW 2060

If you are not satisfied with our response to your complaint, you can contact the Office of the Australian Information Commissioner, at www.oaic.gov.au.