Privacy Policy

Who this policy applies to

This Privacy Policy applies to Modern Home Loans (ABN 49 139 532 648), the website at modernhomeloans.com.au, our office phone line, and any digital tools we use to take and handle enquiries. Modern Home Loans is an Authorised Credit Representative (Credit Representative Number 000366901) of Purple Circle Financial Services Pty Ltd (Australian Credit Licence 486112).

We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) set out in that Act, including the changes introduced by the Privacy and Other Legislation Amendment Act 2024.

What personal information we collect

The personal information we collect depends on how you interact with us. It typically includes:

• Identity and contact details — name, email address, phone number, suburb;
• Situation context— what you're looking to do (buying, refinancing, etc), timing, and any background you choose to share;
• Financial details — when you ask us for credit assistance, we collect the financial information needed to assess a credit application (income, expenses, assets, liabilities, identification);
• Conversation content — messages you send via our website chat assistant, voicemails or recorded calls placed to our office line, and any free-text context shared via forms or calculators;
• Technical data— limited browser, device, and session information described under "Cookies and analytics" below.

AI tools and how they handle your data

We use AI-supported tools to help us respond to enquiries promptly and consistently. We're transparent about what they do:

• AI-powered chat assistant — the chat surface on our website is answered by an AI assistant that can qualify enquiries, answer general questions about our services, and route conversations to Danny. Your messages are processed by the AI in order to generate a response, and the conversation is stored in our records system.
• AI phone receptionist — calls to our office number outside business hours may be answered by an automated phone system. These calls are recorded and a written transcript is generated and stored. By continuing the call, you consent to the call being recorded for this purpose.
• Automated summaries and lead scoring — once an enquiry is captured, an AI service may generate a short summary of the conversation and a numerical indicator of urgency / fit. These outputs are decision support for Danny — they are not, by themselves, decisions that affect a credit application.

Human oversight

Modern Home Loans operates within the FinanceLocal platform, which applies a human-in-the-loop governance model: AI suggestions, summaries, transcripts, and lead scores are decision-support tools that Dannyreviews personally before any material action is taken on your enquiry. AI outputs do not, on their own, cause a credit-related decision. This approach is intended to align with ASIC's expectations for human oversight of automated tools in regulated financial services.

If you'd prefer your enquiry not be processed by AI tools at any stage, email us at hello@modernhomeloans.com.auand we'll handle the conversation manually.

Credit information

If you ask us for credit assistance, we'll collect credit information governed by Part IIIA of the Privacy Act and the National Consumer Credit Protection Act 2009 (NCCP). This includes information needed for a preliminary assessment — your income, expenses, assets, liabilities, and identification documents — and may include credit reporting information from a credit reporting body (with your consent). We use credit information only for the purpose of providing credit assistance and complying with our regulatory obligations.

How we use your information

We use personal information to:

• respond to enquiries you send us;
• provide credit assistance and arrange a credit contract through one of the lenders on our panel;
• follow up on enquiries (transactional emails, automated nudges, calls);
• comply with regulatory obligations including responsible-lending obligations under the NCCP Act and record-keeping obligations under both the NCCP Act and the Privacy Act;
• improve the quality and accuracy of the AI tools we use, in aggregate.

Who we share information with

We share personal information only with parties that need it to deliver the service you've asked for, and only to the extent necessary. The categories are:

• The credit licensee — Purple Circle Financial Services Pty Ltd, who supervises the credit representative arrangement;
• Lenders — when you ask us to arrange a loan, the lender(s) we submit an application to;
• AI processing services — providers that power the chat assistant, the phone assistant, the conversation summarisation, and the lead-scoring described above;
• Email delivery service — the provider that delivers transactional emails (confirmations, follow-ups, meeting prep);
• Online booking system — when you choose to book a meeting through our calendar link, the provider that hosts that calendar;
• Australian-hosted cloud infrastructure — for primary storage of enquiry records, transcripts, and conversation history;
• Website hosting and content delivery infrastructure — for serving the website and processing form submissions;
• Professional advisers and regulators — accountants, solicitors, auditors, AFCA, ASIC, the OAIC, and similar parties when we are lawfully required or authorised to disclose.

We do not sell personal information. We do not disclose personal information for direct marketing by third parties.

Where your information is stored

Primary storage of enquiry records, transcripts, and conversation history sits on Australian-hosted cloud infrastructure. Some of the AI processing services we use may process small portions of conversation content overseas under contractual safeguards equivalent to those required by the Privacy Act. We choose providers whose contractual terms commit them to handle your information in ways consistent with the Australian Privacy Principles.

Cookies and analytics

Our website uses session cookies to keep you logged into a chat session, to remember quick-form state, and to associate enquiries you submit with the page you were reading. We may also use limited analytics to count anonymous page visits and measure how the site is used in aggregate. We do not use third-party advertising cookies.

Data breach notification

We comply with the Notifiable Data Breaches scheme under the Privacy Act, including the stricter obligations introduced by the Privacy and Other Legislation Amendment Act 2024. If a data breach occurs that is likely to result in serious harm to you, we will:

• notify the Office of the Australian Information Commissioner (OAIC) as soon as reasonably possible and, in any event, within 72 hours of becoming aware;
• notify you directly of the breach, the kinds of information involved, and the steps you can take to protect yourself.

How long we keep information

We retain enquiry records, conversation transcripts, and credit assistance records for at least 7 years from the date of the relevant interaction or assessment, in accordance with the record-keeping requirements of the NCCP Act. Information not subject to a specific retention obligation is destroyed or de-identified once it is no longer needed for the purpose for which it was collected.

Accessing or correcting your information

Under Australian Privacy Principles 12 and 13, you have the right to ask us:

• for access to the personal information we hold about you; and
• to correct any personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading.

Email hello@modernhomeloans.com.auwith your request. We'll respond within a reasonable period, usually within 30 days. There's no charge for an access request, though we may charge reasonable cost recovery for unusual requests (we'll tell you in advance if so).

Complaints

We take privacy complaints seriously. The fastest way to a resolution is to tell us first.

Step 1 — internal complaint to Modern Home Loans

Email hello@modernhomeloans.com.au or call 07 3153 7761. We'll acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

Step 2a — credit / financial complaints (AFCA)

If your concern relates to credit assistance and we can't resolve it internally, you can refer it to AFCA: 1800 931 678 · info@afca.org.au · www.afca.org.au.

Step 2b — privacy complaints (OAIC)

If your concern relates specifically to how we've handled your personal information and we can't resolve it internally, you can refer it to the Office of the Australian Information Commissioner: 1300 363 992 · www.oaic.gov.au.

Updates to this policy

We update this policy from time to time, including when there are changes to law, our services, or the AI tools we use. The date at the top of this page reflects the most recent revision. Material changes will be flagged in our regular communications.

Contact us

Modern Home Loans
22 Shore Crescent, Bulimba 4171 QLD
Phone: 07 3153 7761
Email: hello@modernhomeloans.com.au