Privacy / complaints and compliments

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Privacy

Token Finance Pty Ltd | ACN: 676 594 700 is firmly committed to protecting the privacy and confidentiality 

of personal information. We take our obligations seriously to handle your personal information 

in accordance with the requirements of the Privacy Act 1988. This Privacy Policy sets out details 

about how we collect, use and manage your personal information.

Collection and use of personal information

We collect personal information to enable us to provide our products and services to you and 

otherwise as set out in this Privacy Policy. In addition, if we are required to comply with certain 

legislation to provide you with the products and services you choose, then collection of certain 

personal information will be mandatory. If you don’t want to or are unwilling to provide us with 

the information we need, we may be unable to provide services to you.

Personal information obtained and held

We only collect and hold personal information about you, which is reasonably necessary for 

our functions and activities, which include (but are not limited to):

● Providing you quality products and/or services and to improving how we operate and 

provide those services.

● Assessing an application for finance to ensure no financial hardship will occur because 

of assisting with the provision of a specific loan.

● Arranging finance and any related insurance.

● Maintaining your contact details.

● Fulfilling our legal obligations under applicable laws and rules, such as those relating to 

Anti-Money Laundering and Counter-Terrorism Financing.

Examples of personal information collected and held relating to our customers or loan 

applicants:

● Name, date of birth, address, telephone number, email address or other contact details.

● Information that we require to identify customers or loan applicants, including as 

required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, 

which may include details or copies of passports, birth certificates, driver licences, utility 

bills or other documentary evidence of applicants’ identities.

● Information relevant to the financial services that we provide or have been requested to 

provide, including information about customers' or applicant's financial position, such 

as:

○ details of assets and liabilities, including investments and any existing debts

○ details of income, including employment status, occupation and the name of 

our clients' employer; and

○ proof of financial position, including for example pay slips or tax statements.

● Other details relevant to a finance application that we require to assess that 

application, such as family details or the number of dependants.

● Credit information, including credit information contained in credit reports from Credit 

Reporting Bodies (CRB).

● Records of our interactions with you, including by telephone, email and online.

● Your enquiries or complaints.

● Information that may be required about other third parties (e.g., your spouse, a co 

borrower or dependents). Where we collect such information, you confirm that you 

have obtained the necessary consents from that third party to disclose such 

information to us and have informed the third party of the purpose for disclosure.

Credit information is personal information that relates to credit that a person has applied for or 

has been provided. The credit information that we will collect from you may include your 

records of credit that you have applied for (including the name of the credit provider, the type 

of credit and the amount of credit), default information or any other information that has a 

bearing on your credit worthiness used to determine your eligibility for credit. Credit 

information also includes credit reporting information supplied to us by a credit reporting body 

and any information that we derive from it.

We will collect, hold, disclose, and use your personal and credit information to:

● Assess and verify your identity and financial situation.

● Assess your credit application, or your suitability as a guarantor to a credit application.

● Provide such information to a guarantor or related applicant.

● Exchange your information with a credit reporting body.

● Disclose your information to credit providers as set out in our ‘Credit Provider Schedule’ 

to arrange credit.

● Disclose your information to our aggregation partners as set out in the Aggregation 

Partners section of this document.

● Disclose your information to an insurer to arrange insurance you wish to obtain.

● Disclose to, and collect information from, third parties such as your employer, landlord, 

real estate agent, lending institution and guarantor where deemed reasonably 

necessary to arrange finance and/or insurance on your behalf.

● Refer you to other organisations, service providers or business partners or obtain 

referrals from them to you.

We may not be able to provide you with products and/or services without the ability to collect, 

hold, disclose and use your personal and credit information.

We may also collect and hold sensitive information about you, including information 

relating to:

● Your citizenship or country of birth.

● Biometric information to be used for the purpose of identification or automated 

biometric verification.

● Criminal records.

● Information where you are a politically exposed person under the Anti-Money 

Laundering and Counter-Terrorism Financing Act 2006.

We may collect and hold Health Information:

● If we are assisting you with an insurance product. We do not use or share that 

information for any purpose other than acquiring the product on your behalf.

● To understand your financial situation, or any anticipated changes to your financial 

situation. We do not use or share that information for any purpose other than providing 

you with credit assistance and assessing your application for credit.

The purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information about customers or applicants in order 

to:

● Assess a customer’s suitability for a loan or financial product.

● If approved, to provide finance to customers through our network of lenders.

● Send customers marketing about other products and services that we think may be of 

interest to them.

● Respond to inquiries and complaints.

We also collect, hold, use, and disclose personal information about:

● Our customers seeking finance for any worthwhile asset finance product for business or 

personal use.

● Our customers seeking finance for any unsecured personal loans.

● Individuals or brokers who we provide aggregation services to or brokers operating 

under our license to manage our relationship with those persons, including to 

determine remuneration payable to such parties.

How personal information is collected, used, and disclosed

If you are a customer seeking a loan or insurance, we will collect personal information about 

you directly from you or from our brokers or Credit Representatives. We may also collect 

personal information about you from other persons, organisations and public sources as set 

out below.

We may use and disclose your personal information to, and collect personal information about 

you from:

● Any business which provides information about consumers or commercial 

creditworthiness of persons.

● A credit report obtained from a Credit Reporting Body. Information about your 

creditworthiness, credit standing, credit history or credit capacity, the status of your finances and any default by you in accordance with the Privacy Act.

● Any sources disclosed in your application for finance such as employers, past and 

present landlords etc.

● Service providers that assist in the processing of applications.

● Any joint applicants, co-applicants, guarantors or proposed joint applicants, coapplicants, guarantors in relation to an application for finance.

● Referrers, credit providers, insurance product providers.

● Our agents, contractors and external advisers.

● Government authorities (e.g., tax authorities in Australia and overseas) in connection 

with their lawful information requests or to meet legal obligations in any relevant 

jurisdiction.

● Our related bodies corporate (together referred to as "our Related Companies") and we 

may use this personal information for product development and research and to inform 

you about products and services in the future (see the section on Marketing below for

more information).

● Issuers of identification documents via the use of third-party systems.

● Intermediaries, including your agent, adviser, a dealer, a broker, a representative acting 

on your behalf, other Australian Financial Services Licensee or our authorised 

representatives, advisers and our agents.

● Mortgage insurers to assess the risk of providing mortgage insurance or to assess the 

risk of default.

● Accounting or finance specialists.

● Our external dispute resolution service.

● Legal and other professional advisers.

● Debt collection agencies, your guarantors, organisations involved in valuing, surveying 

or registering a security property, or which otherwise have an interest in such property, 

purchasers of debt portfolios.

We may also disclose your personal information in connection with funding financial 

accommodation by means of an arrangement involving securitisation, or any other proposed 

transfer of or proposed dealing with your loan.

We may collect and handle information that is in the public domain, such as from online 

forums, websites, Facebook, Twitter, YouTube, or other social media platforms (for example, if 

you use social media to make a complaint); or public registers (for example, those kept by the 

Australian Securities and Investments Commission).

Cookies

We may use “cookies”. A cookie allows our servers to identify and interact more effectively with 

you and your device(s). The cookie assists us in maintaining the continuity of your browsing 

session and remembering your details and preferences when you return.

Our systems record a variety of information relating to interactions with our website. This 

information may include the software versions used, device identifiers (e.g. IP addresses), 

location data (where available and not disabled by the user), dates, times, file metadata, referring website, data entered and user activity, such as links clicked.

We may automatically collect non-personal information about you such as the site from which 

you linked to our websites.

In some cases, third parties may use cookies and other technologies such as those described 

above. These technologies may be used in connection with activities like surveys, online 

behavioural advertising, website and usage analytics and email campaign management.

How we hold personal information

We use security procedures and modern technology to protect the personal information that 

we hold.

We store your personal information in several ways, including in physical paper files and 

electronic systems and devices. Much of the information we hold is stored electronically on 

servers that are in company premises or in secure data centres located in Australia. Access to 

and use of this information within our Related Companies is appropriately limited to protect 

from misuse or unlawful disclosure of the information.

How you can access and seek correction of your information

You can contact us to request access to the personal information that we hold about you. 

Subject to the provisions of the Privacy Act and the Australian Privacy Principles, we will 

generally give you access to your personal information. However, there may be exclusions that 

apply that permit us to not provide you with access in some circumstances. If access is denied, 

we will provide you with the reason why unless, having regard to the grounds for refusal, it 

would be unreasonable for us to do so. Where we do grant access to your information, we may 

charge you a fee for accessing your personal information.

You can also contact us to request that we correct personal information that we hold about 

you. If we are satisfied that the personal information is inaccurate, incomplete, irrelevant, or 

misleading then we will take reasonable steps to correct that information.

Any request to access or correct personal information should be made to our Privacy Officer 

using the contact details set out below and will be dealt with in accordance with the Privacy 

Act.

Disclosing your information overseas

Some of the parties with which we exchange your personal information, including our service 

providers and other third parties, may be located outside Australia including India, Singapore, 

the United States of America, the Philippines, Fiji, and South Africa. 

We may also need to send your information overseas to process transactions you have 

instructed us to make, such as international money transfers. The countries to which we 

disclose your information will depend on the transaction details.

Marketing

We may use and disclose your personal information to inform you about other products and 

services we think may be of interest to you in the future.

We respect your right to ask us not to use your information for direct marketing and we will not 

send you information about products and services if you so request by contacting us using the 

contact details set out below.

Changes to this Privacy Policy

We are constantly developing and enhancing our use of online technologies and make 

reasonable efforts to ensure we keep this Privacy Policy and related documents up to date in 

this regard. Please check back when you return to use our website or online services to ensure 

you are familiar with our current practices.

We reserve the right to change this Privacy Policy at any time and, should this occur, the 

amendment will be posted on our website.

Contact Us

If you have any questions regarding our privacy policy or handling of information, please 

contact our Privacy Officer using the details below:

Addressee: The Privacy Officer

Viking Asset Aggregation Pty Ltd

Address: Level 3, 12 Waterloo Road, Macquarie Park NSW 2113, Australia 

Phone: 1800 861 004

Email: privacy@vikingaggregation.com.au

Complaints Handling Policy

Internal Dispute Resolution (IDR) Process

This policy provides information about our internal dispute resolution (IDR) process. Our IDR 

service is provided to you free of charge.

VIKING ASSET AGGREGATION PTY LTD | ACN 661 296 457 | Australian credit licence 543046 

(we/us/our) believes that it is essential for us to have the ability, authority and proper training 

to hear and respond appropriately to any complaints or disputes raised by our customers.

How you may lodge a complaint or make a compliment

You can lodge complaints or make compliments by contacting:

Addressee: The Complaints Officer

Viking Asset Aggregation Pty Ltd

Address: Level 3, 12 Waterloo Road, Macquarie Park NSW 2113, Australia 

Phone: 1800 861 004

Email: complimentsandcomplaints@vikingaggregation.com.au

You may also lodge a complaint by speaking to any representative of our business who will refer 

you to the Complaints Officer. You should explain the details of your complaint as clearly as you 

can. You may do this verbally or in writing.

To assist complainants who might need additional assistance to lodge a complaint, we:

• offer multiple methods for lodging complaints, including phone, email, letter, social 

media, in person, or online;

• do not require complaints to be in writing;

• ensure that information provided to the public about our IDR process, including this 

policy, is available in a range of languages and formats (including large print and 

audiotape);

• provide training to all staff (not just complaints management staff) to enable staff to be 

able to identify, support and assist complainants who need additional assistance, 

including cross-cultural training; and

• allow representatives to lodge complaints on behalf of complainants, including 

financial counsellors, legal representatives, family members and friends.

Dealing with complaints

Our process for dealing with complaints is as follows:

Acknowledgement: We will acknowledge receipt of your complaint promptly – that is, within one 

business day of receiving it, or as soon as practicable.

Assessment and investigation: We will review your complaint carefully and promptly, taking such 

steps and reviewing such documents as reasonably necessary.

IDR response: We will provide an ‘IDR response’, which is a written communication that sets out 

the final outcome of your complaint through our IDR process and your right to take your 

complaint to AFCA if you are not satisfied with the IDR response. If we reject or partially reject 

your complaint, we will clearly set out the reasons for our decision.

Response timeframes

Generally, we will provide an IDR response to you no later than 30 calendar days after receiving 

the complaint. However, for some specific types of credit-related complaints, the following 

response timeframes apply.

• Credit-related complaints involving default notices: No later than 21 calendar days after 

receiving the complaint;

• Credit-related complaints involving hardship notices or requests to postpone 

enforcement proceedings: No later than 21 calendar days after receiving the complaint. 

Exceptions apply 

• if we do not have sufficient information to make a decision, or if we reach an agreement 

with you.

We do not need to provide an IDR response to you if we close your complaint by the end of the 

fifth business day after receipt because we have:

a) resolved the complaint to your satisfaction; or

b) given you an explanation and/or apology we can take no further action to reasonably 

address your complaint.

However, we must provide a written IDR response for complaints closed by the end of the fifth 

business day after receipt if:

a) the complainant requests a written response; or

b) the complaint is about hardship.

Our external dispute resolution scheme – AFCA

If we do not reach agreement on your complaint, you may refer your complaint to the 

Australian Financial Complaints Authority (AFCA). 

You can contact the AFCA scheme:

• by phone on 1800 931 678;

• by email at info@afca.org.au; or

• in writing to GPO Box 3, Melbourne VIC 3001.

The AFCA scheme is a free service established to provide you with an independent mechanism 

to resolve specific complaints