This is the Privacy Policy (Policy) of Stratton Finance Pty Ltd (ACN 070 636 903 / Australian Credit Licence no. 364340) and our wholly owned subsidiaries and franchisees (we, our, us, Stratton). Our Policy sets out how we collect, handle, use and disclose your personal information.  It also deals with how you can access the personal information we hold about you, ask us how to correct it, or make a privacy related complaint.

This Policy explains how we respect your rights to privacy in accordance with the Australian Privacy Principles (APPs) and Part IIIA contained in the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2024 and any other relevant laws.

 

OUR COMMITMENT TO PROTECT YOUR PRIVACY

We understand how important it is to protect the privacy of your personal information. This document sets out our commitment in respect of the personal information we hold about you and what we do with that information.

 

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which strives to protect the privacy and security of your personal information.

 

PERSONAL INFORMATION

When we refer to personal information, we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you. When you use our website or mobile applications, we may collect information about your location or activity including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used and other user location information. We collect some of this information using cookies.

 

If you are applying for finance or providing a guarantee we may also collect the number and ages of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses.

 

If you apply for an insurance product through us, we may also collect your health information.  We will collect health information from you only with your consent.

The personal information we hold about you may also include credit-related information. Credit-related information means:

  • Credit information includes your identity: the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information; default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and
  • Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.

We use your credit-related information to assist you with an application for finance.

 

SENSITIVE INFORMATION 

We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health and may include any information you tell us about any vulnerability you may have

 

HOW WE COLLECT YOUR PERSONAL INFORMATION 

Where reasonable and practical we will collect your personal information directly from you where you visit our website or lodge a loan enquiry through this webpage or through our credit representatives (brokers) and franchisees, and from competitions and promotions to which you choose to respond. We may also collect your personal information from employers and other people such as accountants and lawyers. 

We will not ask you to supply personal information publicly over Facebook, Twitter, or any other social media platform that we use.

 

COLLECTING THIRD PARTY PERSONAL INFORMATION

If you give us personal information about another person, you represent that you are authorised to do so and confirm that you have obtained consent from that person for us to use and disclose their personal information.   They may access any personal information we hold about them.

 

UNSOLICITED INFORMATION

Sometimes people share information (including sensitive information) with us which we have not requested.

If we receive unsolicited personal information (including credit-related information) about you, we will determine whether we would have been permitted to collect that information. If yes, then we will handle this information the same way we do with other information that we seek from you or in the manner described in this policy. If no, then we will destroy or de-identify it as soon as practicable, but only if it is lawful and reasonable to do so.

Often, it is not possible for us to neatly unbundle this information then destroy or de-identify only certain sections or parts of it, and we may need to store this information to assess future applications by you.

 

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the purpose for which it has been provided, for directly related secondary purposes, any other purpose you have consented to, and any other purpose permitted under relevant legislation. This may include using your personal information for the following purposes:

  • to establish your identity
  • to contact you
  • to submit to a credit provider an application to be a borrower or guarantor, or a lessee under a finance lease
  • to assess, process and manage an application for employment
  • for complaints handling or data analytics purposes
  • to assess, process and manage your application to be a broker or franchisee or other products, including to verify your details
  • to comply, where required, with the regulatory or legal obligations
  • to other organisations that are involved in managing or administering your finance, such as third-party suppliers, lenders, insurers and credit reporting bodies
  • to associated businesses that may want to market products to you
  • to anybody who represents you such as lawyers, accountants and employers
  • to anyone, where you have provided us consent to disclose
  • to other borrowers or guarantors (if more than one)
  • to our auditors and insurers
  • where we are authorised to do so by law
  • to any entity that has an interest in your finance or our business.

 

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

To enable us to maintain a successful business relationship with you, we may disclose your personal information to third parties for the purpose of delivering the products or services you require. Where possible, we will inform you, at or before the time of collecting your personal information, of the types of organisations to which we may disclose your personal information. 

We may disclose your personal information to:

  • potential credit providers as part of our credit assistance process
  • third parties to verify the details provided are correct, including with your employers
  • finance consultants, accountants, insurers and mailing services
  • our related body corporates, assignees, agents and contractors
  • law enforcement, government and regulatory bodies
  • any person who refers you to us for credit assistance
  • joint applicants and guarantors
  • any person considering acquiring an interest in our business or asset.

By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case-by-case basis.

Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office.

 

FINANCIERS

For more information on how the Financiers collect, hold, use and disclose your information, you should see their privacy policies (many of which are accessible via the websites listed in the table below), which include how you can access and correct the information that these Financiers hold about you and how you can complain about their treatment of your information. Financiers on Stratton’s lending panel include, but are not limited to, the entities listed below:

 

CREDIT RELATED INFORMATION

We exchange credit related information for the purposes of assisting you with your application for finance.  This may include obtaining a credit report about you as an applicant or guarantor as an authorised Access Seeker.

This credit related information may be held by us in electronic form on our secure servers.

When we obtain credit eligibility information about you for a credit reporting body, we may also seek publicly available information and information about any serious credit infringements that you may have committed.

 

TRANSFER OF INFORMATION OVERSEAS

Personal information (including credit related information) may be held by us in electronic form on our secure servers and in paper form. We may use cloud storage and IT servers to store the personal information we hold about you. These storage solutions may be located outside Australia, including with trusted third-party providers such as Salesforce, based in Australia and the United States.

 

By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, understanding that those entities may not be subject to privacy laws which provide the same level of protection as Australia privacy laws

 

INFORMATION COLLECTED WHEN USING OUR WEBSITE OR THIRD-PARTY WEBSITES

1.    Technical and usage data

When you visit our websites or use our mobile apps, we may collect information about your location or activity, including your IP address, telephone number, whether you have accessed third party sites, the date and time of visits, the pages that you viewed, information about the device used, and other user location information. We collect some of this information using cookies.

 

2.    IP Addresses

Your internet protocol address (or ‘IP address’) is the numerical identifier for your device when you are using the internet. It may be necessary for us to collect your IP address for your interaction with some parts of our website.

 

3.     Links to third party websites

Our website may contain links to the websites of third-party providers of goods and services (Third Party websites). If you have accessed Third Party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.

 

Where you access a Third-Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.

 

4.    Advertising and cookies

We use ‘cookies’ to provide you with better and more customised service and with a more effective website.

A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser. We use cookies for different purposes such as:

  • to allocate a unique number to your internet browsers;
  • to customise our website and offers for you;
  • for statistical purposes;
  • to identify if you have accessed a third party provider’s website for goods and services; and
  • for security purposes.

Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.

 

5.         Web beacons

A web beacon is typically a transparent graphic image invisible to the user that is placed on a website. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel.

 

We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and ‘advertising/ marketing personalisation’. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing Third Party Websites.

 

6.         E-consent 

By providing your email address and then clicking submit on any online form, calculator, tool or query, you consent to receiving notices and other documents from us by email to the email address provided, and you understand that that if you give this consent: we may no longer send you paper copies of notices and other documents; you should regularly check your email account for documents; and you may withdraw your consent to receiving documents by email at any time. You also confirm that you have the facilities to print any notice or document that we send you by email, if required. 

 

DIRECT MARKETING

From time to time, we may use your personal information to let you know about products and services from us and our business partners and affiliates that you might find of interest (such as by way of updates or newsletters), to run competitions or promotions and to communicate other offers or opportunities in which you may be interested.  We do not sell your personal information for direct marketing purposes.

 

We may conduct these marketing activities via mail, email, telephone, messaging such as SMS and MMS, or any other electronic means. We may also market our products and services to you through third-party channels (such as social networking sites).

 

Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.

 

If you do not wish to receive marketing information, you may decline, at any time, by telephoning us on 1300 787 288 or by emailing info@stratton.com.au.  If the direct marketing is by email you may also use the unsubscribe function included in these email communications.   We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity but no later than 5 working days.

 

UPDATING YOUR PERSONAL INFORMATION

It is important to us that the personal information we hold about you is accurate and up to date. During our relationship with you we will ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.

 

ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION

You may request access to any of the personal information we hold about you at any time.  We will respond to you within seven days of receiving your request.  We may need to properly investigate your request.  We will provide you with the outcome of our investigation within 30 days.  We may need to consult with finance providers or credit reporting bodies or entities as part of our investigation

To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings or if your request is vexatious.

 

An explanation will be provided to you if we deny you access to the personal information we hold about you.

If you ask us to correct the personal information we hold about you, if appropriate, we will correct the personal information at the time of the request. Otherwise, we will provide an initial response to you within seven days of receiving your request and will provide you with details about whether we have corrected the personal information within 30 days.

If we refuse to correct personal information, we will provide you with our reasons for not correcting the information.

 

BUSINESS WITHOUT IDENTIFYING YOU

In most circumstances, it will be necessary for us to identify you to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information – for example, if you make general inquiries about interest rates or current promotional offers.

 

SECURITY OF YOUR PERSONAL INFORMATION

We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.

If we no longer need to hold your personal information, it is securely destroyed or permanently de-identified.

 

CONTACTING US AND PROVIDING FEEDBACK

You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer on the contact details below.

The Privacy Officer
Stratton Finance Pty Ltd
PO Box 5012
South Melbourne, VIC, 3205
Telephone: (03) 9685 9759

 

We will acknowledge your complaint within seven days and aim to resolve the complaint as quickly as possible. We will provide you with a decision on your complaint within 30 days. If you are dissatisfied with our response to your complaint, you may make a complaint to the Australian Financial Complaints Authority scheme, which can be contacted on either www.afca.org.au or 1800 931 678, or the Privacy Commissioner who can be contacted on either www.oaic.gov.au or 1300 363 992.

 

CHANGES TO THIS PRIVACY POLICY

We may amend this Policy from time to time to comply with new laws or codes of practice that may be implemented.  We may also change this Policy to include any new products or services that we may provide from time to time.

You may request this policy in an alternate form by contacting the Privacy Officer on the above details.

 

This Privacy Policy was last updated on 17 February 2025.