Privacy Policy
easycarloan.online is owned and operated by EMBR Group Pty Ltd (ABN 27 147 278 153) (“EMBR”, “we”, “us” or “our”).
We handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable Australian laws.
This Privacy Policy explains what information we collect, why we collect it, how we use and disclose it, how enquiries are qualified and referred, and how you can access, correct or complain about our handling of your information.
1. Who we are
EMBR Group Pty Ltd
ABN 27 147 278 153
Email: [email protected]
2. Personal information we collect
Depending on your interaction with the Website, we may collect:
- first and last name;
- mobile telephone number;
- email address;
- your state, postcode or general location;
- the amount of finance you are seeking;
- information about the vehicle or type of vehicle you are seeking to finance;
- information about your circumstances that you provide with your enquiry, such as whether you are 18 or over, whether you are an Australian resident, whether you own your home, your employment status, your household income and how you describe your credit rating;
- information you provide about your finance enquiry;
- information submitted through Website forms or communications with us;
- contact verification information;
- IP address, browser and device information;
- advertising and referral source information;
- Website and form interaction information; and
- any other information you voluntarily provide.
If a Referral Partner requires additional personal or financial information to assess a credit application, it may collect that information from you directly.
3. How we collect your information
We primarily collect personal information directly from you when you:
- complete a form;
- submit a car-loan enquiry;
- verify your telephone number;
- respond to questions on the Website; or
- communicate with us.
We may also collect technical and usage information through cookies, advertising pixels, analytics technologies and similar tools.
4. Why we collect and use your information
We may use personal information to:
- process your car-loan enquiry;
- verify your identity or contact information;
- determine whether your enquiry meets our minimum referral criteria;
- determine which Referral Partner may receive your enquiry;
- facilitate contact between you and a Referral Partner;
- maintain records of consent and referrals;
- identify duplicate, fraudulent or invalid enquiries;
- manage Referral Partner volume and availability;
- operate our Website, CRM and technology systems;
- measure and improve advertising and Website performance;
- communicate with you regarding your enquiry; and
- comply with applicable legal and regulatory obligations.
5. Automated qualification and routing
We use software systems and predefined business rules to assist in processing, qualifying and routing enquiries.
The personal information used in these systems may include:
- the amount of finance requested;
- information about the type of finance or vehicle enquiry;
- contact verification information; and
- other information submitted through the Website where relevant.
Our systems may determine:
- whether an enquiry meets the minimum loan amount required for referral;
- whether an enquiry is not referred;
- which Referral Partners are able to receive the enquiry; and
- which Referral Partner receives an enquiry where more than one Referral Partner is available.
Referral Partner volume limits, availability and other operational requirements may also influence routing.
These systems do not approve or decline your application for credit and do not determine whether a loan is suitable for you. Any decision regarding credit eligibility, suitability or approval is made separately by the relevant Referral Partner and/or lender.
6. Disclosure to Referral Partners
Where your enquiry meets applicable criteria, we may disclose your personal information to an independent lender, finance broker or other appropriately licensed or authorised credit service provider (“Referral Partner”).
Information disclosed may include:
- your name;
- telephone number;
- email address;
- state, postcode or general location;
- requested finance amount;
- vehicle or enquiry information; and
- other information provided through the Website that is relevant to your enquiry.
Where we refer an enquiry, we generally provide it to one Referral Partner only.
Different enquiries may be referred to different Referral Partners depending on applicable criteria and Referral Partner availability.
Once information has been disclosed to a Referral Partner, that organisation will handle it in accordance with its own privacy obligations and privacy policy.
7. Credit information
Easy Car Loan's initial Website enquiry process is intended to generate and refer a finance enquiry.
We do not obtain your consumer credit report when you submit the initial Website enquiry, and submitting it does not affect your credit score.
If you proceed with a Referral Partner, that Referral Partner or lender may collect, use or disclose credit information or credit eligibility information as part of assessing an application. Its own privacy and credit-reporting policies will apply to those activities.
8. Referral remuneration
EMBR receives a fixed fee from Referral Partners for qualifying and referring enquiries.
Our referral remuneration is not based on whether you are ultimately approved for finance, obtain a loan or achieve any particular lending outcome.
9. Contact about your enquiry
Where you have provided consent, EMBR and/or the Referral Partner selected for your enquiry may contact you by telephone, SMS or email about your car-loan enquiry.
You may withdraw consent or ask us to stop contacting you at any time.
For EMBR communications, you can:
- use the unsubscribe facility provided in an email;
- reply STOP to an SMS where that facility is available; or
- contact [email protected].
If a Referral Partner contacts you directly, you may also opt out directly with that organisation.
10. Service providers and other disclosures
We may also disclose personal information to organisations that assist us to operate our business, including:
- CRM and lead management providers;
- Website hosting providers;
- cloud storage services;
- SMS and telephone verification providers;
- email service providers;
- analytics and advertising platforms;
- IT and cybersecurity providers;
- contractors and professional advisers.
We may also disclose information where required or authorised by law.
11. Cookies, analytics and advertising
We use cookies, pixels and similar technologies to operate the Website, measure advertising effectiveness, understand Website usage and improve our services.
These technologies may collect:
- IP address;
- browser and device details;
- pages viewed;
- advertising or referral source;
- form interactions; and
- advertising identifiers.
When you submit an enquiry or verify your mobile number, we send details of that event to Meta Platforms, Inc. so it can measure our advertising. Your email address, mobile number, first and last name, country and an identifier we assign to your visit are sent as a one-way hash, not in readable form. Your IP address, browser user agent and Meta's own advertising cookies (_fbc and _fbp) are sent unhashed, as Meta requires.
You can generally control cookies through your browser or device settings.
12. Overseas disclosure
Some technology providers used by us may store or process information outside Australia.
The countries involved may vary according to the infrastructure used by those providers.
The overseas recipients we are likely to disclose personal information to are located in the United States (Meta Platforms, Inc. for advertising measurement, Google LLC for analytics, Twilio Inc. for mobile number verification, and Cloudflare, Inc. for Website hosting) and the United Kingdom (Databowl, our lead management provider). Cloudflare operates a global network, so information you submit may also pass through its data centres in other countries.
Where required by the Australian Privacy Principles, we take reasonable steps concerning the handling of personal information by overseas recipients.
13. Security
We take reasonable steps to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure.
No internet-based system can be guaranteed to be completely secure.
14. Retention
We retain personal information for as long as reasonably necessary for purposes including:
- administering and recording enquiries;
- maintaining evidence of consent;
- managing duplicate and fraudulent enquiries;
- meeting regulatory or record-keeping obligations;
- managing complaints and disputes; and
- legitimate business record keeping.
When information is no longer required, we take reasonable steps to destroy or de-identify it where appropriate.
15. Access and correction
You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.
Contact: [email protected]
We may need to verify your identity before processing the request.
16. Deletion or de-identification
You may ask us to delete or de-identify personal information.
We may need to retain some information where required or permitted by law or for regulatory, consent-record, complaint, suppression or other legitimate record-keeping purposes.
A request made to EMBR does not automatically delete personal information already held independently by a Referral Partner or lender.
17. Data breaches
If an eligible data breach occurs, we will comply with applicable obligations under the Notifiable Data Breaches scheme, including notifying affected individuals and the Office of the Australian Information Commissioner where required.
18. Complaints
Privacy complaints may be sent to:
Privacy Officer
EMBR Group Pty Ltd
Email: [email protected]
We will investigate complaints and respond within a reasonable period.
If you remain dissatisfied, you may be entitled to lodge a complaint with the Office of the Australian Information Commissioner.
19. Changes to this policy
We may update this Privacy Policy to reflect changes in our Website, technology, Referral Partner arrangements or legal obligations.
The current version will be published on the Website with its latest update date.