Privacy Statement And Policy

FAQ's - Your Data and AXTON Finance

These answers summarise our privacy statement and policy below. If anything here differs from the full policy, the full policy applies.

Where is my information stored?

Your loan file is securely held in Mercury Nexus, the platform provided by our aggregator, Connective Broker Services Pty Ltd. AXTON is authorised under Australian Credit Licence 389328. Connective publishes its security and compliance status in its Trust Centre.

We also use Microsoft 365 for email and secure file storage.

Is AXTON SOC 2 certified?

AXTON does not hold its own SOC 2 report. We use established platforms whose providers publish independent security attestations, and we apply the safeguards described below. We do not store client documents on personal devices or personal cloud accounts.

Who can see my information?

Only authorised AXTON team members working on your loan, the lender and insurers you apply to, our aggregator Connective, and the service providers listed in this policy. Some of our support team members work from overseas. They access your file only through Mercury Nexus, the Australian-hosted loan platform provided by our aggregator, Connective.

Do you use AI?

Like most businesses today, we do use AI to help our team work more productively and more accurately. We record and transcribe client calls and meetings, and use approved commercially paid AI tools to summarise them and prepare file notes and loan scenarios. Your broker reviews everything and makes every recommendation. AI does not decide whether you get a loan; lenders make that decision. We take steps to prevent your information being used to train AI models.

How long do you keep my information?

If we have given you credit assistance, the law requires us to keep your file for seven years. We then securely destroy or de-identify it. If we have only recorded your contact details, we keep them only while they are needed.

Can I ask you to delete my information?

Yes. We will delete anything we are not legally required to keep, and stop marketing to you straight away. Records that Australian law requires us to keep stay on file until the retention period ends.

Can I see or correct my information?

Yes, at any time. Contact our Privacy Officer using the details at the end of this policy.

Can I opt out of call or meeting recordings?

Yes. Tell your broker at the start of a call or meeting and we will not record it.

About this policy

This policy explains how AXTON Finance Pty Ltd (ABN 39 872 010 901), its brokers and team members collect, use, store and share your personal information. It also covers credit information we handle when helping you apply for credit.

AXTON is a credit representative (No. 471730) authorised under Australian Credit Licence No. 389328. We are bound by the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Privacy (Credit Reporting) Code and the National Consumer Credit Protection Act 2009 (Cth).

What we collect

We collect only what we need to give you credit assistance and meet our legal obligations. This usually includes:

• Identity and contact details: name, date of birth, address, phone, email and identity documents

• Financial details: income, employment, assets, liabilities, expenses, bank statements and tax returns

• Credit information: credit reports, repayment history and existing loan details

• Property details for the security you are buying or refinancing

• Records of our calls, meetings and correspondence with you

• Website and online form activity, such as IP address and pages visited

Tax File Numbers. Under the Privacy (Tax File Number) Rule 2015, Tax File Numbers (TFNs) may only be requested or collected where authorised by taxation, personal assistance or superannuation law. Mortgage brokers generally have no such authority, and lenders rarely require TFNs for credit.

Sensitive information. We do not ask for health or similar sensitive information unless it affects your loan, for example a hardship request or a medical profession policy with a lender. We collect it only with your consent and use it only for that purpose.

How we collect it

We collect most information directly from you, through meetings, calls, email, our client portal and online forms. We may also collect it from:

• Co-applicants, guarantors and your authorised representatives, such as your accountant, solicitor or conveyancer

• Your employer or other referees, to verify your details

• Lenders, mortgage insurers, valuers and credit reporting bodies

• The person or business that referred you to us

• Public sources, when we cannot reach you to update your contact details

If you choose not to give us information, we may not be able to help you find or apply for a loan.

How we use it

We use your information to:

• Understand your goals and assess which loans may suit you

• Prepare and lodge applications with lenders and insurers

• Meet our responsible lending and best interests regulatory obligations

• Verify your identity and help prevent fraud

• Manage your loan after settlement, including rate and structure reviews

• Handle questions and complaints

• Tell you about products and services that may interest you, unless you opt out

• Meet our legal, regulatory and audit obligations

We do not sell your personal information.

Who we share it with

We share your information only for the purposes above, with your consent, or where the law requires it. Recipients may include:

• Connective, our aggregator, through whose platform we submit applications

• The Australian Credit Licence holder that authorises us

• Lenders, mortgage insurers, valuers and other intermediaries involved in your application

• Credit reporting bodies and fraud prevention organisations

• Your authorised representatives, co-applicants and guarantors

• The person or business that referred you to us, limited to the status of your application

• Service providers that support our business, including technology, document, transcription and AI providers listed in this policy

• Regulators and dispute bodies, including ASIC, AFCA, the ATO and the OAIC, as required or authorised by law

• A buyer of, or investor in, our business, under confidentiality obligations

Overseas disclosure and offshore team members

Some AXTON support team members, engaged through our support partners, work from overseas, currently the Philippines and Nepal. They help with professional loan processing and administration work. They access your information only through Mercury Nexus, under contracts that require them to meet Australian privacy standards. They do not store client files on their own devices.

Most lenders and service providers also process or store information overseas. Cloud services may hold data in more than one country. Where we use them, we take reasonable steps to ensure the recipient protects your information consistently with the Australian Privacy Principles.

Where your information is stored and how we protect it

Your loan file is stored in Mercury Nexus, the loan platform operated by Connective. Connective publishes its security and compliance status in its Trust Centre.

System	What it holds	Hosting
Mercury Nexus (Connective)	Loan files, documents, application records	Australia
Microsoft 365	Email, Teams, secure file storage	Australia
Fireflies	Online meeting recordings and transcripts	United States
Aircall	Call recording and transcripts	United States
Claude (Anthropic), organisational account	AI drafting and analysis	United States
ChatGPT (OpenAI), organisational account	AI drafting and analysis	United States

Our safeguards include:

• Multi-factor authentication of all systems holding client data

• Access limited to team members working on your loan

• No client documents on non-approved personal devices, USB drives or personal cloud accounts

• AI tools used only through approved, AXTON-administered commercial accounts

• Written policies on data handling, acceptable use, AI and data breach response, with training for all team members

If a data breach is likely to cause you serious harm, we will notify you and the OAIC under the Notifiable Data Breaches scheme.

Call recording, AI and automated decision-making

Call recording. We record and transcribe phone and video meetings for compliance, training and file accuracy. You can ask us not to record a call at any time.

How we use AI. We use approved AI tools to:

• Summarise calls and meetings and prepare file notes

• Draft emails, loan summaries and compliance notes

• Compare loan scenarios, policies and pricing across lenders

• Check that application files are complete

These tools use the personal and financial information in your file, including income, expenses, assets, liabilities, loan requirements and our call transcripts.

Decisions about you. Some AI outputs help your broker decide which lenders and products to recommend. Your broker reviews every output and makes every recommendation. AI never decides on its own which loan you are offered. Lenders make credit decisions using their own systems.

Your information and AI providers. We use paid business versions of AI tools and, where available, select settings that stop providers using client information to train their AI models. We do not enter client information into personal or free AI tools.

If you have questions about how AI was used on your file, ask your broker or management at AXTON Finance.

How long we keep your information

We keep personal information only as long as we need it, or as long as an Australian law requires. When neither applies, we securely destroy or de-identify it.

Record	How long	Legal basis
Preliminary assessment, and the inquiries and verification behind it	Seven years from the date of the credit assistance quote	National Consumer Credit Protection Act 2009 (Cth), s 114 and s 120
Credit eligibility and credit reporting information	As set by the Privacy Act	Privacy Act 1988 (Cth) Part IIIA and the Privacy (Credit Reporting) Code
Identity verification (Know Your Customer) records	Seven years	Lender and licensee requirements. We verify your identity on behalf of lenders, who are subject to the AML/CTF Act 2006 (Cth).
Complaints and our responses	Kept on file	AFCA membership and ASIC RG 271
Do-not-contact record	Ongoing, so we honour your opt-out	Spam Act 2003 (Cth)
Contact details with no credit assistance given	Only while needed for the purpose collected	Australian Privacy Principle 11.2

You can ask for a copy of your preliminary assessment at any time within seven years, free of charge.

Requests to delete your information

You can ask us to delete your information at any time. What we can delete depends on the service we have provided.

• No credit assistance given (for example, you only enquired or booked a call, and no advice has been provided): we will delete your details, apart from a minimal record that stops us contacting you again.

• Credit assistance given (we provided you with our credit guide when credit advice has been supplied, we prepared an assessment, application or recommendation): we must keep the records listed above until their retention period ends. We will stop all marketing immediately upon request and delete anything we are not required to keep.

GDPR. The European Union's General Data Protection Regulation does not generally apply to AXTON Finance as an Australian business, as we provide services in Australia. Your rights are set by Australian privacy law, which we follow.

Accessing and correcting your information

You can ask for reasonable access to, or correction of, the information we hold about you. Contact our Privacy Officer. We will respond within 30 days, and there is no charge to make a request.

We may refuse access in limited cases allowed by law, such as where it would affect someone else's privacy or legal proceedings. If we refuse, we will explain why in writing.

Credit information. If you ask us to correct credit information, we will help even if another organisation made the error. We will tell you our decision within 5 business days of making it, and aim to complete corrections within 30 days unless you agree to a longer period. You can complain to AFCA or the OAIC without first coming to us about an access or correction decision.

Marketing and opting out

We may contact you about rate reviews, loan products and related services. Every marketing message includes a way to opt out, and you can also ask your broker. We act on opt-outs as soon as practicable. We NEVER sell your information. We provide you marketing content only for what you consent to.

Complaints and contact

If you have a question or complaint about how we handle your information, contact our Privacy Officer:

• Email: admin@axtonfinance.com.au

• Phone: 03 9939 7576

• Mail: 114 Auburn Road, Hawthorn VIC 3122

We will acknowledge your complaint within one business day and give you a final response within 30 calendar days. If we cannot resolve your complaint, you can also contact our licensee, Connective Credit Services Pty Ltd: Compliance and Complaints Handling Officer, 1300 656 637, compliance@connective.com.au, Level 29, 555 Collins Street, Melbourne VIC 3000.

If you are not satisfied, you can contact:

• Australian Financial Complaints Authority (AFCA): afca.org.au, 1800 931 678, info@afca.org.au GPO Box 3, Melbourne VIC 3001. Note that time limits apply to AFCA complaints.

• Office of the Australian Information Commissioner (OAIC): oaic.gov.au, 1300 363 992

Dealing with us anonymously. You can make general enquiries without giving your name. We need to identify you before we can give credit assistance.

Changes to this policy. We review this policy at least once a year and when our systems or the law change. The current version is always on this page.