Privacy Policy

About this policy

This policy explains how Brokerology collects, uses, holds and discloses personal information.

Brokerology provides compliance support and analytics services to Australian credit licensees. We do not provide credit, we do not arrange credit for consumers and we do not obtain credit reports.

This policy applies to our website at brokerology.ai and to the personal information we hold in the course of running our business.

Our commitment

We handle personal information in line with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

We collect only what is reasonably necessary for our business, we tell you what we do with it, and we give you a way to see it, correct it or ask us to remove it.

What we mean by personal information

Personal information is information about an identified individual, or an individual who is reasonably identifiable. A name, an email address or a professional profile link can be personal information. Information about a company, such as its name, licence number, website or size, generally is not.

Information we collect from you

Assessments. Our website offers two short assessments. If you complete one and choose to receive your results, we collect your name, business name, email address, phone number where you provide it, and your answers to the assessment questions.

Email updates. If you subscribe to our Insights articles, we collect your email address and any name you provide.

Enquiries. If you contact us by email or phone, we collect the information you choose to give us.

Website usage. We collect technical information about visits to our website, including pages viewed, referring website, browser type, device type, IP address and time of visit. Where you arrive from a marketing link, we record the campaign details for that visit.

Information we collect about businesses and their principals

We maintain a list of Australian credit licensees that may be a fit for our services. Most of what we hold about these businesses is not personal information: the licence number, entity and trading name, website, business location, the number of credit representatives, the company's LinkedIn page and a description of what the business does.

Where a business publicly identifies the person who runs it, our records may also include that individual's name, their business role, a link to their public professional profile and, less often, a business email address. This is information about people in their professional capacity, not their private lives.

We collect this from two kinds of source:

• Public registers maintained by ASIC, specifically the published credit licensee and credit representative data
• Publicly available online sources, including the businesses' own websites and public professional profiles

If you are named in these records and would prefer not to be, you can ask us to remove you. See "Removing your details from our business list" below.

Cookies, analytics and advertising

Analytics. We use Plausible Analytics to understand how our website is used. Plausible sets no cookies and collects no personal information. Data is processed in the European Union.

Campaign attribution. When you arrive from a marketing link, we store the campaign details for the length of your visit using your browser's session storage. This is cleared when you close your browser and is not shared with anyone.

LinkedIn Insight Tag. Our website uses the LinkedIn Insight Tag on every page. This places cookies, including third-party advertising cookies, and allows LinkedIn to record that a visit occurred, the page visited, the referring site, your IP address, your device and browser, and the time of the visit. Where LinkedIn can match that visit to a LinkedIn member, it does so. We use this to understand how our advertising performs and to show our advertising to people who have visited our website. We do not receive the identity of individual visitors from LinkedIn.

You can manage cookies through your browser settings. LinkedIn also offers its own advertising controls in your LinkedIn account settings.

How we use information

We use personal information to:

• provide your assessment results and respond to your enquiry
• send you the Insights articles you subscribed to
• deliver and support our services to clients
• identify businesses that may be a fit for our services
• understand how our website and advertising are performing
• meet our legal and record-keeping obligations

Who we share information with

We use a small number of service providers who handle information on our behalf. We do not sell personal information and we do not disclose it for anyone else's marketing.

Google (Sheets, Apps Script)

Assessment submissions and our business records

Zoho (CRM)

Contact records and our sales pipeline

Kit

Email subscriber addresses and article delivery

Netlify

Website hosting and server logs

Plausible

Website analytics, no personal information

LinkedIn

Advertising measurement and audiences, as described above

We may also disclose information where we are required or permitted to by law.

Information held overseas

Some of our service providers hold information outside Australia. Kit, Netlify and LinkedIn process information in the United States and other locations. Plausible processes information in the European Union.

Where we disclose information to an overseas recipient, we take reasonable steps to satisfy ourselves that it will be handled appropriately, but you should be aware that overseas privacy laws may differ from Australian law.

Direct marketing

We may use your contact details to send you information about our services. Every marketing email includes an unsubscribe link, and you can also ask us to stop at any time by getting in touch through our contact page.

We do not use or disclose sensitive information for direct marketing.

Sensitive information

Sensitive information includes information about a person's racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or practices, criminal record, health information, genetic information and biometric information.

We do not ask for sensitive information and we have no business reason to collect it.

Security

We take reasonable steps to protect the information we hold from misuse, interference, loss and unauthorised access, modification or disclosure. Our records are held electronically in access-controlled systems.

No transmission of information over the internet can be guaranteed as completely secure.

Where we no longer need information and are not required to keep it, we take reasonable steps to destroy or de-identify it.

Access and correction

You can ask us for a copy of the personal information we hold about you, and you can ask us to correct it if it is wrong or out of date. Get in touch through our contact page.

We will acknowledge your request within seven days. We will usually provide the information or make the correction within 30 days, and we will tell you if we need longer.

There are limited situations where we may not be able to give you access, for example where the information relates to legal proceedings or where giving access would unreasonably affect someone else's privacy. If we refuse, we will tell you why.

Removing your details from our business list

If we hold your name or contact details as the principal of a credit licensee and you would prefer we did not, get in touch through our contact page and we will remove them. You do not need to give a reason.

Complaints

If you are unhappy with how we have handled your personal information, get in touch through our contact page and tell us what happened. We will acknowledge your complaint within seven days and aim to resolve it within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

Changes to this policy

We may update this policy from time to time. The current version is always available on this page, with the date it was last updated.

Contact us

For anything in this policy, including access, correction, removal and complaints, use the details on our contact page.