Privacy Policy

Who we are

ChapterTwo is a mortgage broker. We arrange residential and commercial home loans, and we specialise in refinancing for people who don't fit standard bank lending criteria — including people consolidating personal debts into a home loan.

We are a credit assistance provider. We do not lend money ourselves.

We hold our own Australian Credit Licence (number 531408) and arrange some loans under that licence. For other lenders we act under the credit licensing and aggregation arrangements of our aggregator, Outsource Financial (Australian Credit Licence 384324). Which arrangement applies depends on the lender for your particular loan; either way, the same privacy standards in this policy apply.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

What personal information we collect

When you make an enquiry or use a tool on our website, we may collect:

• Your name, email address and phone number
• The estimated value of your property
• Your current mortgage balance
• Your other debts
• Your income and employment type

If you proceed to a loan application, we will collect considerably more, including:

• Date of birth, residential address and marital status
• Details of your partner or co-borrower
• Full income, expense, asset and liability details
• Employment details and identification documents
• Your credit history and credit report information
• Bank statements and other financial records

Sensitive information

In some circumstances — for example where a health event has affected your finances — we may collect sensitive information. We will ask for your consent first, and only use it for the purpose you gave it to us for. If you send us sensitive information we did not ask for, you consent to us handling it in line with this policy and applicable law.

How we collect your information

Usually directly from you — through our website, our forms, over the phone, by email or text, or in a meeting. We also collect information from:

• Online advertising platforms (for example, an enquiry form submitted on Facebook or Instagram)
• Credit reporting bodies, once you have consented to a credit check
• Lenders and other financial institutions involved in your application
• Your accountant, financial planner or lawyer, where you have asked them to deal with us

You can deal with us anonymously or under a pseudonym where it is lawful and practicable to do so — but if you don't give us the information we ask for, we may not be able to help you.

The Capacity Check

Our website has a tool that gives you an indication of whether we may be able to help. It asks for four figures: what your property is worth, what's left on your mortgage, what else you owe, and roughly what you earn.

• We use those figures to calculate an indicative loan-to-value ratio and give you an immediate answer. That answer is generated automatically.
• We store your answers against your record in our customer relationship management (CRM) system.
• A member of our team may contact you about it by phone, email or text.
• It is not a loan application. It does not touch your credit file. Nothing goes to a lender and no credit check is performed unless and until you ask us to proceed.
• The answer is indicative only. It is not credit advice, not an offer of credit, and does not take account of your objectives, financial situation or needs.

If you would rather not use the tool, you can call or email us instead.

How we use your information

We use your personal information to:

• Assess whether we can help you, and how
• Prepare and submit a loan application on your behalf
• Communicate with you about your enquiry or application
• Meet our obligations under the National Consumer Credit Protection Act 2009, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, and our credit licence
• Improve our services

We will only use your personal information for the purpose you gave it to us for, a related purpose you would reasonably expect, a purpose you have consented to, or as otherwise permitted or required by law.

Marketing — including email and SMS

We may contact you with marketing communications by email and by SMS. We do this on the basis of your consent, or the existing relationship you have with us as a result of your enquiry.

You can opt out at any time and we will act on it promptly:

• Email — click Unsubscribe at the bottom of any email we send
• SMS — reply STOP to any text
• Phone — 1300 344 433
• Email us — admin@chaptertwo.com.au
• In writing — Level 6, 56 Pitt Street, Sydney NSW 2000

Opting out of marketing does not stop us contacting you about a loan application you have with us.

Who we share your information with

Unless you ask us not to, we may disclose your personal information to:

• Lenders and credit providers we approach on your behalf
• Outsource Financial, our aggregator, which provides credit licence arrangements, systems and compliance oversight for loans arranged under its licence
• Mortgage insurers and property valuers
• Credit reporting bodies, where you have consented to a credit check
• Service providers who help us run our business — CRM, email and SMS platforms, IT providers, lawyers and accountants
• Anyone else you have authorised us to deal with
• Anyone we are required or permitted to disclose to by law

We do not sell your personal information.

Where your information is stored

We use third-party technology providers, and some store or process data outside Australia. Our CRM system stores data in Australia. Some other providers — including advertising and analytics platforms — may store or process information in the United States or elsewhere. By providing your information to us, you consent to this disclosure. We take reasonable steps to ensure overseas recipients handle it in accordance with the Australian Privacy Principles, but we may not be able to control how it is handled once it leaves Australia.

Credit reporting information

If you proceed with a loan application, we will — with your consent — obtain your credit report from a credit reporting body to assess and arrange credit for you. We handle credit information and credit eligibility information in accordance with Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code.

We access credit files; we do not report to credit reporting bodies. We do not disclose your repayment history or other consumer credit information to credit reporting bodies. Because we do not participate in credit reporting in that way, we do not maintain a separate credit reporting policy — how we handle your credit information is set out in this policy.

How long we keep it

We are required to keep records for at least seven years under the National Consumer Credit Protection Act and the AML/CTF Act. Once our legal obligations end, we will take reasonable steps to destroy or de-identify your personal information.

Keeping your information secure

We take reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure, and we review our security procedures from time to time. If we become aware of a data breach likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme.

Government identifiers

We will not adopt a government-related identifier — such as a Tax File Number, Medicare number or driver licence number — as our own way of identifying you, and we will only use or disclose such identifiers where the law permits.

Accessing and correcting your information

You can ask us for a copy of the personal information we hold about you at any time, and we will respond within a reasonable time. We may refuse access in limited circumstances — for example where the law permits us to, or where giving access would unreasonably affect another person's privacy — and we will tell you why. If anything we hold is wrong, out of date or incomplete, tell us and we will correct it.

Cookies and our website

Our website uses cookies to understand how visitors use it and to improve it. You can decline non-essential cookies using the banner on our site. We use analytics and advertising tools (including Meta and Google) which may set cookies. Our website links to other sites; those sites are not subject to our privacy standards, and we are not responsible for their privacy practices.

Complaints

If you are unhappy with how we have handled your personal information, please tell us first so we can try to put it right:

We will acknowledge your complaint within a reasonable time (ordinarily within a few business days) and give you a written response within 30 days, in line with ASIC's internal dispute resolution requirements. If we need more time, we will tell you why.

If you are not satisfied with our response, you can take your complaint to the Australian Financial Complaints Authority (AFCA), our external dispute resolution scheme. AFCA is free to you and independent.

AFCA member number: 83211

You can also complain to the Office of the Australian Information Commissioner (OAIC): 1300 363 992 · www.oaic.gov.au

Changes to this policy

We may update this policy from time to time. The current version is always available at chaptertwo.com.au/privacy-policy.

Contact us

If you have any questions about this policy or your privacy, contact our Privacy Officer: