THE FUTURE. FOR BROKERS. BY BROKERS

MLAPP PRIVACY NOTICE AND POLICY

MLApp is committed to protecting the privacy of your personal information.

MLAPP Pty Limited ACN 167 873 967 of Level 1, 460 Church Street, North Parramatta NSW 2151 (MLAPP, we, us, our) is bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

If you have any queries about the privacy of your personal information, please contact our Privacy Officer by email (privacy@mlapp.com.au).

PRIVACY NOTICE

2. Legal requirements

We may be legally required to collect personal information under:

• the Corporations Act 2001 (Cth) (Corporations Act); or
• any requirements issued by the Australian Prudential Regulation Authority or the Financial Ombudsman.

4. What happens if can't collect your personal information?

Unfortunately, if we cannot collect your personal information your mortgage broker, lending services provider or bank may be unable to complete or process your financing application.

5. Who receives your personal information?

Generally we give your personal information to:

• your mortgage broker(s), lending services providers(s) and banks to which you wish to apply for financing (however, we do not pass on to these businesses any card or payment information provided by our customers when purchasing the MLAPP mobile app or any other product or service from us);
• our registered brokers and employees, but only as needed by them to perform their services (they have obligations to treat the personal information they access as confidential); and
• external providers of services we use to operate our business and manage our business systems, such as:
  1. software developers and providers of IT support services (including Sentia Australia Pty Limited);
  2. web server providers (including Anchor Systems Pty Ltd); and
  3. if you are a customer purchasing our products or services, providers of payment processing facilities (including Braintree, a division of PayPal, Inc.) and the financial institution(s) they partner with.

7. Access and correction

Part 4 of our Privacy Policy tells you how you can access the personal information we hold about you and request corrections.

8. Complaints

Part 5 of our Privacy Policy tells you how you may complain about a breach by us of the APPs or an APP code and explains how we will deal with your complaint.

9. Disclosing personal information overseas

We may disclose your personal information to third parties located outside Australia. For example, when our customers pay for the MLAPP mobile app (or another of our products and services) we may provide their payment information (including credit card details) to providers of payment processing facilities. These facilities are likely to be located in the United States.

PRIVACY POLICY

This Privacy Policy explains how we manage your personal information. Under the Privacy Act, ‘personal information’ is generally any information or opinion that identifies you personally.

By using our website at www.mlapp.com.au or the MLAPP mobile app, you confirm that you have read and accept this Privacy Policy. We may make changes to this Privacy Policy from time to time. If we do, we’ll post the updated version on our website, and make it available through the MLAPP mobile app.

1. KINDS OF INFORMATION WE MAY COLLECT AND HOLD

Information for your financing application

Name, contact details, date of birth, bank account details and other personal information requested by mortgage brokers, providers of lending services, banks or financial institutions.

Payment information

We may collect payment information (including credit or debit card details) from our customers when they pay for the MLAPP mobile app (or another of our products or services) through the payment processing service that we use.

Online behaviour

We may collect information about your online behaviour, including:

1. the time, date and URL of each request for a page from our web server; and
2. information from your mobile device allowing us to: analyse trends, administer the MLAPP mobile app and from time to time utilise aggregated demographic information.

To do these things, and to enable you to remain logged into the MLAPP mobile app, we may use cookies (pieces of data sent by a website and stored on the hard drive of your computer or mobile device). Cookies allow a website to identify and interact with your computer or mobile device.

You can set your browser to accept or reject cookies, or notify you when a cookie is sent. If you reject cookies, you may still use our website, but you may not have access to any restricted areas of it and you may not be able to use the MLAPP mobile app.

2. HOW WE COLLECT AND HOLD PERSONAL INFORMATION

We tell you how we collect Personal Information in section 1 of the Privacy Notice

We take reasonable precautions to protect the personal information we hold from:

• misuse, interference and loss; and
• unauthorised access, modification or disclosure.

We may use third party data storage providers (such as Anchor Pty Ltd and Braintree, a division of PayPal Inc.) to store personal information electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.

3. HOW WE USE AND DISCLOSE PERSONAL INFORMATION

We tell you our main reasons for collecting personal information in section 3 of the Privacy Notice. Our other reasons for collecting, holding, using and disclosing Personal Information are below.

• Service providers
  • provide, manage and administer products and services and business systems (including software developers, providers of IT support and web server providers);
  • securely manage processing of electronic payments and storage of credit and debit card details; and
  • analyse trends and aggregated demographic information, and target your interests.
  We confirm that we do not disclose any payment information that we may collect from our customers in connection with the purchase of the MLAPP mobile app (or any of our other products and services) to anyone other than the provider of our payment processing platform and the financial institution(s) it partners with. However, our provider may disclose the information to third party service providers and we may not be responsible for those disclosures. If the provider of our payment processing platform is located outside Australia, then under the Privacy Act:
  1. we may be required to take steps to ensure that provider handles personal information received from us in accordance with the APPs; and
  2. we may be liable for any breach of the APPs by that provider in relation to personal information received from us.
• Regulators

  We may disclose your personal information to:

  • regulators and law enforcement agencies; or
  • respond to an enquiry from a government agency under State or Federal laws.
• Marketing

  We may also use and disclose your personal information to:

  • let you know about our new products and services or other opportunities (for example, by direct mail, email or SMS);
  • send you product and service information on behalf of third parties;
  • enable mortgage brokers, providers of lending services and banks and financial institutions to market their products and services to you.

  Each time we send you a marketing communication, you will have the option of opting-out from future marketing communications. You can also opt-out from all future marketing communications at any time (email: admin@mlapp.com.au).

4. ACCESSING AND CORRECTING PERSONAL INFORMATION

We will take reasonable steps to ensure the personal information we hold about you is accurate, up-to-date and complete. Please let us know if there’s a change to any of the details you have provided to us.

You have a right to ask for access to the personal information we hold about you. You are also entitled to ask us to correct that information. Please contact our Privacy Officer with any access or correction request, at:

c/- MLAPP Pty Limited 183 Albion Street Surry Hills
email: privacy@mlapp.com.au

Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information.

In some circumstances we may not be able to grant access to your personal information (for example, (for example, if it would have an unreasonable impact on the privacy of an other person).

It is not always possible to remove or modify the information we hold, but we will take reasonable steps to correct your personal information so it is accurate, up-to-date, complete, relevant and not misleading.

If we decline to make a correction you have requested, you can ask us to attach to your personal information a statement that it is inaccurate, out-of-date, incomplete, irrelevant or misleading. If we disclosed the information to a third party before correcting it, you can request us to notify the third party of the correction we’ve made.

We will not charge you to request a correction, for making a correction or for attaching a statement.

5. MAKING COMPLAINTS

Please contact us our Privacy Officer with any concerns about how we handle your personal information:

Tel: 0404 098 133

c/- MLAPP Pty Limited 183 Albion Street Surry Hills
email: privacy@mlapp.com.au

We will do our best to address your concerns, but if you still wish to lodge a formal complaint, please send details to the Privacy Officer in writing. We will normally respond in 30 days, confirming the next steps in the process.

6. DISCLOSURE OF PERSONAL INFORMATION OVERSEAS

We may disclose your personal information to third parties located outside Australia. For example, when our customers pay for the MLAPP mobile app (or another of our products and services), we may provide their payment information (including credit card details) to providers of payment processing facilities. These facilities are likely to be located in the United States.

7. HOW LONG WE CAN KEEP YOUR PERSONAL INFORMATION?

Generally, we will hold your personal information for up to seven years (in accordance with applicable laws, regulations and Australian Tax Office guidelines).

If we:

1. no longer need to use or disclose your personal information for any purpose authorised by the APPs; and
2. are not legally required to retain that information

then we will take reasonable steps to destroy the personal information or have it de-identified.