Legal and Compliance

This privacy policy sets out how EdFin uses and protects any information that you give EdFin when you use this website.

1. DEFINITIONS
In this privacy policy, the term:

• “Partnership” means EdFin Group ABN 99284794040 which is a partnership registered in Australian with the Australian Securities and Investments Commission and “We” and “Us” means the Partnership;
• “Company” means Foresters Community Finance Pty Ltd ACN 107822766, which company is registered in Australian with the Australian Securities and Investments Commission; and “We” and “Us” means the company;
• “Content” means the text, databases, electronic images, photographic images, virtual tours, video, menus, business descriptions, business names and/or logo, the details of any proposed lending transaction or components of it, advertisements, sponsored information and any other information published on this Web Site;
• “Services” means Partnership’s products, software, Services, this Web Site and any other web site operated by Partnership; and
• “You” or “User” means each person who has logged onto this Partnership Web Site and is using it for any purpose whatsoever and “Your” has a corresponding meaning.

2. GENERAL
Partnership is committed to the protection of Internet users with regard to privacy and data protection. Partnership complies with the Privacy Act 1988 in relation to all processing of personal data supplied to Us by users and other personal data in our possession for any reason. This statement discloses the privacy policy for the Partnership website at https://www.edfin.com.au. This statement does not extend to sites that are linked to or which are not part of the Partnership Web Site.

3. PERSONAL INFORMATION
Personal information is any information that identifies You or by which Your identity can be reasonably determined.
At specific times Partnership may ask You to provide Us with personal information, including but not limited to Your name and email address. You may choose not to provide Us with this information. However, this may limit our ability to provide You with a specific service or offer You personalised Content. Please note that all the information You provide to Partnership will be stored and processed in Australia. Occasionally We will send You email communications to provide information, which We think You will find useful, including information about new products and Services from Partnership. It is our policy only to send email to customers who give Us permission to do so. Our site provides You with the opportunity to “opt-out” of receiving communications from Partnership at the time We ask You for this information. In addition, whenever We contact You via email, We will also have instructions on how to unsubscribe so that You will not receive any future emails from Us if You so choose.
Other companies that place advertising on our site may collect information about You when You view or click on their advertising or Content. Partnership does not control this collection of information. You should contact these advertisers or Content providers directly if You have any questions about their use of this information.

4. WHY WE COLLECT PERSONAL INFORMATION

The collection, use and disclosure of Your personal information by Partnership is essential to enable Us to conduct our business of offering and providing our range of financial products and Services.
By collecting your personal information We can generally administer our relationship with You which may include:
(a) establishing and administering our Services;
(b) determining Your requirements and providing the appropriate product or service;
(c) assessing Your service needs;
(d) improving our Services;
(e) identifying You and protecting You from unauthorised access to Your personal information, accounts or Services; and
(f) satisfying our legal obligations in respect to customer identification.

Without collecting and making use of Your personal information, We may not be able to interact or do business with you.

5. COLLECTION OF INFORMATION

Where possible We collect Your personal information directly from you. We also use Cookies to collect personal information.

A ‘cookie’ is a small amount of data, which often includes an anonymous unique identifier that is sent to Your browser from a web server and stored on You computer’s hard drive. Cookies do not damage Your computer. Each web site can send its own cookie to Your browser if Your browser’s preferences allow it, but (to protect Your privacy) Your browser only permits a web site to access the cookies it has already sent to you, not the cookies sent to You by other sites. You can decide if You want to accept cookies by changing the settings on Your browser to accept all cookies, reject all cookies, or notify You when a cookie is set.

The Partnership website uses cookies to assign identification to Your individual browser. This identifies Your browser – but not You – to our servers every time You visit our network. Cookies by themselves cannot be used to find out the identity of any user. Unless You voluntarily advise us, the Partnership website will never know who You are, even though We assign Your browser a cookie. The information gathered through the use of cookies, allows Partnership to offer a quality Internet service and easily accessible online Content to our users, and catalogue traffic patterns throughout the network in a manner that provides personal privacy protection.

We also keep track of Your IP address to help diagnose problems with our server and to administer our web site. Your IP address is also used to gather broad demographic information about you, such as Your location and Your Internet Service Provider. The Partnership Web Site may also collect and aggregate information on how our users are utilising the site. This might include information regarding traffic patterns through the sites. Other organisations that place advertising on our network also have the ability to assign a different cookie to Your browser in a process that Partnership does not control. Again, unless You voluntarily advise them, these advertisers will also never know who You are.

6. SHARING OF DATA

Partnership nor Company will not disclose any of Your personal information to a third party without Your consent, unless We believe, in good faith, that the law requires it or that the rights or property of Partnership need to be protected. Your consent to the disclosure of Your personal information may be given explicitly either in writing or verbally or it may be implied from Your conduct.

7. ACCURACY AND CURRENCY OF PERSONAL DATA

We rely on the personal information We hold about You to efficiently administer our relationship and conduct our business of providing Services.
For this reason, it is very important that the personal information We collect from or about You is accurate, complete and up-to-date.
During the course of our relationship with You We will ask You to tell Us of any changes to Your personal information however You can contact Us at any time to update Your personal information or to tell Us that the information We hold about You is inaccurate or incomplete.

8. ACCESS TO YOUR OWN PERSONAL INFORMATION
You may request access to any of the personal information We hold about you.
In most cases, a summary of personal information such as Your name and address details, contact telephone numbers, loan numbers and services You have with Us is freely available to You by emailing the request to us.
For more detailed requests for access to personal information, for example, access to information held in archives, a fee may be charged to cover the cost of retrieval and the supply of this information to you.
All requests for access to personal information will be handled as quickly as possible and We shall endeavour to process any request for access within 30 days of having received the request. Some requests for access may take longer than 30 days to process depending upon the nature of the personal information being sought.
We may refuse You access to personal information in a number of circumstances such as where the information may relate to existing or anticipated legal proceedings with you, where denying access is required or authorised by law, or where the request for access is regarded as frivolous or vexatious or is an unreasonable imposition on us.
If We deny Your request for access to, or refuse Your request to correct Your personal information, We will explain why.

9. LINKS TO OTHER SITES

The Partnership website contains links to other sites not affiliated with Partnership. These sites have their own policies and practices with respect to online privacy and Partnership cannot be responsible for the privacy practices or the Content of these unaffiliated websites.

10. COMMENT

We suggest that You practise reasonable discretion with any site when providing site operators/owners with personal information. It should also be noted that whenever You post personal information in publicly accessible places, such as chat rooms or message boards, this information becomes available to anyone with access to the Internet. Therefore, We recommend that You refrain from posting any information that You do not want seen in these public areas. You should feel free to contact any site that requests personal information from You if You have any questions regarding its policies.

We understand that sometimes people experience difficulty in meeting their financial obligations due a number of different, and often unexpected reasons — and we are here to help you get through this time.

If you have a loan with us and you find yourself unable to make your repayment and need to reschedule, please contact us for assistance.

Call us on (07) 3851 8000 to discuss your account today.

Our Commitment To You As A Responsible Lender:
Foresters Community Finance prides itself on being a responsible lender.
We always act in the best interests of our customers. We make sure that every loan we offer is affordable for our customers, and every loan meets their needs, objectives and requirements.
We are committed to responsible lending practices and follow these 6 guiding principles:
We make reasonable inquiries about the customer’s financial situation, and their requirements and objectives;
We take reasonable steps to verify the customer’s financial situation;
We make a final assessment (as the credit provider) about whether the credit contract is ‘not unsuitable’ for the customer (based on the inquiries and information obtained in the first two steps of the application process).
We encourage our customers to notify us if they find themselves in financial difficulty.
We may refer you to the government’s website www.moneysmart.gov.au if we believe that you might benefit from their sound financial guidance.
If we feel that your current situation may benefit from the services of a Personal Budgeting Specialist we may refer you to one.
EdFin Group is an Authorised Credit Representative of Foresters Community Finance. Foresters Community Finance holds an Australian Credit Licence and complies with the responsible lending conduct obligations in Chapter 3 of the National Consumer Credit Protection Act 2009.

Foresters Community Finance is a member of the Financial Ombudsman Service
Approved by the Australian Securities and Investments Commission (ASIC), the Financial Ombudsman Service (FOS) is the external dispute resolution scheme for the financial services industry.

FOS provides accessible and impartial support that is often used as an alternative to legal proceedings for resolving disputes with a participating financial service provider. This service is free to consumers.

If you have a complaint about any of our products and services, then we would like to hear from you first. We take pride in our ability to sort things out. In the event that you’re still not satisfied, FOS may be able to help. For further information call 1300 780 808 or visit www.fos.org.au

Financial Ombudsman Services Limited
GPO BOX 3
Melbourne Qld 3001
P 1300 780 808
F 03 9613 6399
W www.fos.org.au

All Foresters Loans will be set up for direct debit payment and will automatically be deducted from your Australian bank every fortnight from your nominated account.

Foresters does not accept cheques, international transfers or cash payments.

What Is Direct Debit?

When you set up a direct debit, you are allowing a Foresters to automatically withdraw money from your nominated account every fortnight to pay your loan repayments

At EdFin and Foresters we take your security and data privacy very seriously.

We have invested in the latest state-of-the art technology to ensure your information is always protected.

We encrypt all information passed between your browser and our web’s servers at the same level as the world’s biggest banks. We use strong 128-bit encryption with 2048 bit-root and Extended Validation. Extended Validation is the highest class of SSL (Secured Sockets Layer) available.

Always look for the 4 common indicators used globally on the web to indicate top-level security.

• The browser address bar changes to green confirming that the website is using Extended Validation.
  The standard HTTP changes to HTTPS (indicates server and browser is secured using SSL).
  The padlock symbol is displayed indicating your browser connection to the webserver is secure and encrypted.
  The Partnership’s legally incorporated name is displayed in the address bar. Only Extended Validation allows this.
• At EdFin our website is scanned automatically and daily to detect various threats, including malware. We also perform daily penetration testing of our entire site to prevent any vulnerabilities.

Responsible Lending requirements:
All small amount lenders must comply with ASIC’s responsible lending obligations. We use an external Partnership to form a fully secure connection with your bank. Much like PayPal, we never see your internet banking password and the connection is 100% read only so we can access your last 90 days of bank transactions and allow our latest technology to then get you a speedy decision.

At EdFin and Foresters, we’re committed to making sure our products and services meet your expectations. If you have any feedback about how we’re performing, we’re keen to hear it.

Whether you’d like to let us know about the fantastic service you’ve received from one of our consultants, or you have a suggestion on how we can do something better, let us know.

If you feel we haven’t met your expectations, please get in touch. It’s your comments and ideas that help us to continually improve our services.

How to send us your feedback:
Call us on 07 3851 8080
Email us at individuals@foresters.org.au
Write to us at
Foresters
PO BOX 742
Fortitude Valley Qld 4006

If you have a complaint, we’ll do our best to resolve it right away, but if your complaint is complex, it may take a little longer.

Here’s how you can resolve an issue:

Get in touch with us via one of the methods above to register your complaint. We’ll do our best to resolve it as quickly as possible.

If you’re not satisfied with our initial resolution, you can escalate your complaint to the Individual Finance Manager.

If you’re still concerned with the outcome of your complaint, you can contact the Financial Ombudsman Services (FOS). Please be aware that if you approach them before we have fully investigated your complaint, they will refer you back to us. You can contact the FOS by phone (1300 780 808), via their website (http://www.fos.org.au/) or write to them at:

Financial Ombudsman Services Limited
GPO BOX 3
Melbourne QLD 3001

Foresters is a leading Australian Community Development Finance institution providing financial support and services to individuals, social enterprises and not for profits who are under-served by mainstream financial institutions. Established in 1999, but with its origins dating back to the 1850’s, Foresters has been providing both lending and business development support to a range of Australian social enterprises for a number of years. Foresters has been a pioneer in the field of Social Investment in Australia through its Community Investment Fund, the establishment of Social Investment Australia Ltd and its leading research and publications.

When entering and using the Partnership Website, you are also entering and using Foresters’ program and subsidiary Partnership websites including but not limited to:

• Foresters Community Finance Ltd Australian Credit Licence No. 398639
• Social Investment Australia Ltd Australian Financial Services Licence No. 339844
• Foresters Members Ltd

1. Disclaimer

1.1. You agree that your access to, and use of, this website is subject to these terms and all applicable laws, and is at your own risk. This website and its contents are provided to you on an ‘as is’ basis, the website may contain errors, faults and inaccuracies and may not be complete and current.
1.2. EdFin makes no representations or warranties of any kind, expressed or implied as to the operation of this website or the information, content, materials or products included on this website, except as otherwise provided under applicable laws.
1.3. Neither EdFin, nor its affiliates, directors, officers, employees, agents, contractors, successors or assigns will be liable for any damages whatsoever arising out of, or in anyway related to, the use of this website and any other websites linked to this website. This limitation applies to the direct, indirect, consequential, special, and punitive or other damages you or others may suffer, as well as, but not limited to, damages for loss of profits, business interruptions or the loss of data or information.

2. Viruses

2.1. Foresters cannot guarantee that any file or program available for download and/or execution from or via this website is free from viruses or other conditions which could damage or interfere with data, hardware or software with which it might be used. You assume all risk of use of all programs and files on this website, and you release Foresters entirely of all responsibility for any consequences of its use.

3. Links

3.1. This website may contain links to other websites. Foresters is not responsible for the availability of, or any content or material contained in, or obtained through, any such websites. Any link to another website, and reference to third –party information, products or services linked to this website, is not, and should not be construed as, an express or implied endorsement by Foresters. Any questions for comments relating to such other websites should be addressed to the operator or operators of those websites.

4. Security

4.1. We use industry standard efforts to safeguard the confidentiality of your personally identifiable information. However, please keep in mind that ‘perfect security’ does not exist on the internet. Your information will be secured in both hardcopy and electronic format. Access to it will be controlled by passwords and locked storage cabinets to limit unauthorised use.
4.2. We can not ensure the security of information you may make public in an on-line chat room or similar forum. Accordingly, please exercise caution when disclosing information in this manner.
4.3. If at any time we identify unauthorised access to your information, we will immediately communicate with you to allow appropriate steps to be taken to protect your information.

5. Cookies

5.1. As with many websites, the EdFin site uses standard technology called ‘cookies’ which are small data files that are transferred to your computer when you allow your browser to accept cookies. Cookies automatically identify your web browser to the site whenever you visit the site, and make it easier for you by saving your passwords, purchases and preferences. By tracking how and when you use the site, cookies help us determine which areas are populated and which are not. Many improvements and updates to the site are based on data obtained from cookies. Accepting cookies allows you, among other things, to personalise your experience on the site. Cookies may also allow the site to present to you advertising which may be of interest to you.
5.2. If you do not want information collected through the use of cookies, you can generally opt out of providing this information by turning the cookies off in your browser; however, some areas of the site may not provide you with the personalised experience if you have disabled the use of cookies.

6. IP Addresses and Click-stream Data

6.1. We collect IP address and or/or click-stream data for purposes of system administration and to report aggregate usage for our internal use. An IP address is a number that is automatically assigned to your computer whenever you access the Internet. Our computers identify your number by its IP address. When you request web pages from the site, our computers log your IP address.
6.2. Click-stream data is information collected by our computers when you request web pages from our site. Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view and other such non-personal information. When analysed, this data helps us analyse how visitors arrive at the site, what type of content is most popular, what type of visitors in aggregate are interested in particular kinds of content.

7. Chat Rooms, Forums and Message Boards

7.1. The site may make chat rooms, forums and message boards available to its users. You are not required to provide any personal information when using these areas, but you may choose to do so. If you post personal information online, it will be publicly available, and you may receive unsolicited messages from other parties.
7.2. EdFin cannot ensure the security of any information you choose to make public in a chat room, forum or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.

8. Links to Other Websites

8.1. You should be aware that when you are on the site, you could be directed to other sites beyond our control. For example, if you ‘click’ onto a linked site it will take you off the Foresters site to a different website. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies.
8.2. If you visit a website linked to our site, you should consult that site’s Privacy Policy before providing any personal information.

9. A Note for Parents Concerning Privacy

9.1. We do not encourage children to participate in providing us with any personally identifiable information. We ask that children (18 years of age and under) do not submit any personal information to us. If you are a minor under the age of 18 years, please use our services only under the approval and supervision of your parents or legal guardian(s).
9.2. We support the guidelines and regulatory requirements provided in the Children’s Online Privacy Protection Act (COPPA): <a href=”http://business.ftc.gov/privacy-and-security/children’s-online-privacy”>http://business.ftc.gov/privacy-and-security/children’s-online-privacy</a>.

10. Links to Other Websites

10.1. You should be aware that when you are on the site, you could be directed to other sites beyond our control. For example, if you ‘click’ onto a linked site it will take you off the Foresters site to a different website. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies.
10.2. If you visit a website linked to our site, you should consult that site’s Privacy Policy before providing any personal information.

11. Limitation of Liability

11.1. By providing us with any personal information you expressly and unconditionally release and hold harmless EdFin and its subsidiaries, partners, affiliates, directors, officers, employees and agents from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected personal information.
11.2. While EdFin takes every effort to ensure the proper and appropriate use of data by third party companies (e.g., banks, credit unions) promotional partners or vendors, EdFin is not liable for any injuries, loss or damage of any kind arising from, or in connection with, the use and/or misuse of your collected personal information by Edfin nor Foresters or the above mentioned non-Foresters entities.

As an Authorised Representative of a licensed credit provider, we are required to give you a Credit Guide as soon as it becomes apparent to us that we may make a loan to you.

This guide includes information about our credit license provider, our responsible lending obligations to you, and our internal and external complaint handling procedures. Our credit license provider is Foresters Community Finance (Foresters).

Who is Foresters?

Foresters Individual Finance program is a personal lending program that aims to provide fair, safe and affordable personal loans to individuals who may be limited in their current lending choices. Foresters also aims to assist clients beyond financial matters alone by linking them to alternate assistance programs, if appropriate.

Foresters Responsible Lending Obligations

We have a legal obligation to you not to make or arrange a loan, or increase the limit of an existing loan, if the loan is unsuitable for you at the time we make the loan.

Loan Suitability Assessment

A loan or loan increase will be unsuitable for you if, at the time the loan is made it is likely that:
you will be unable to comply with your financial obligations (you can not afford to repay the loan) under the loan contract, or could only comply with substantial hardship; or the loan will not meet your requirements or objectives.

During the Loan Assessment, we will:

• make all reasonable enquiries about your requirements and objectives;
  make reasonable enquiries about your financial situation; and
  take reasonable steps to verify the information you have given us.
• You can request a copy of our loan assessment (at no charge to you). We must provide the assessment to you within the following timeframes:

Your Request Made:

• Before signing a loan contract –
• Within 2 years of the loan start date –
• Between 2 and 7 years from the loan start date

We Will Give You Your Assessment:

• As soon as possible after we receive your request, but before entering into the loan contract.
• Within 7 business days after we receive your request
• Within 21 business days after we receive your request

We are not required to give you a copy of the assessment if:

• your request is made more than seven years after the loan start date; or
• your loan application was declined.

Complaint Resolution
Internal Complaint Resolution – getting your complaint heard and resolved
Please talk to us first – we aim to resolve your complaint at your first point of contact with us and we encourage you to raise any matter directly with the Individual Finance team through any of the following channels:

Foresters Community Finance Ltd
PO BOX 742
Fortitude Valley Qld 4006

P 07 3851 8080
F 07 3857 0291
E individuals@foresters.org.au
W www.foresters.org.au

We will advise you of the complaint handling process and the timeframe for resolving your complaint. Please refer to our dispute resolution policy.
In the unlikely event that we can’t resolve your complaint at your first point of contact with us, we will refer your complaint to the Individual Finance Manager for further investigation.
If you are not satisfied with the outcome, or if we do not respond speedily, you may refer the complaint to our external dispute resolution centre.
External Complaint Resolution – if we cannot resolve your complaint internally
If we haven’t been able to deal with your complaint to your satisfaction, you can go to the Financial Ombudsman Service, or in such cases we will generally refer your complaint to the Financial Ombudsman Service on your behalf. Their contact details are:

Financial Ombudsman Services Limited
GPO BOX 3
Melbourne Qld 3001
P 1300 780 808
F 03 9613 6399
W www.fos.org.au