Privacy & Credit Reporting Policy
How FRONT Financial collects, uses and protects your personal and credit information.
PRIVACY & CREDIT REPORTING POLICY
Part A is our general Privacy Policy, explaining how FRONT Financial handles personal information across our business. Part B is our Credit Reporting Policy, which applies specifically to credit information and credit eligibility information about individuals in connection with an application for business finance. Part B forms part of, and should be read together with, Part A, where a topic (such as security, access and correction, or how to contact us) is common to both, it is addressed once, in the Shared Information section at the end of this document.
part a | privacy policy
A.1 | ABOUT THIS POLICY
This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our www.frontfinancial.com.au website (Site). In this Policy, “we”, “us” or “our” means FF Loan Manager Pty Ltd (ABN 85 702 441 414, ACN 702 441 414), trading as FRONT Financial (“FRONT”).
As a direct provider of credit, we are bound by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) in full, regardless of annual turnover — credit providers are not eligible for the small business exemption that applies to some other small businesses. Where we collect, use or disclose credit information about you, we are also bound by Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code 2014 (CR Code), addressed in Part B below.
FRONT provides credit only to companies, corporate trustees, and individuals borrowing wholly or predominantly for business or investment purposes — we do not lend to consumers. Loans provided by FRONT are not “credit contracts” for the purposes of the National Consumer Credit Protection Act 2009 (Cth), and are not eligible for determination by the Australian Financial Complaints Authority (AFCA). See the Shared Information section for how to make a complaint.
Under Australian anti-money laundering and counter-terrorism financing laws, we must verify the identity of every borrower and guarantor before providing funds, including screening against politically exposed persons and sanctions databases (administered by AUSTRAC). We may decline to proceed on anti-money laundering grounds without further explanation.
A.2 | PERSONAL INFORMATION WE COLLECT
About you and your business:
- Your name, date of birth, and contact details, including email address, phone number, and residential or business address;
- Your role in the business (e.g. director, partner, sole trader) and your ownership or shareholding interest;
- Identity verification documents, such as your driver's licence or passport, for the purpose of meeting our anti-money laundering and counter-terrorism financing (AML/CTF) obligations;
- Your financial position, including income, expenses, assets and liabilities, where relevant to assessing a personal guarantee;
- Your credit history and credit information, obtained from credit reporting bodies, where you are an applicant or guarantor (see Part B);
- Where you are a PAYG borrower or guarantor: your employment details, including employer name, position, length of employment, and employment status (full-time, part-time, casual);
- Your income information, including payslips, PAYG payment summaries or income statements, and Single Touch Payroll data;
- Your bank statements and transaction history, where provided to verify income and assess living expenses;
- Your superannuation details, where relevant to assessing your financial position;
- Your business name, ABN/ACN, industry, and trading history;
- Business financial information, including bank statements, tax returns, BAS lodgements, financial statements, and accounting records;
- Details of existing business debt, assets, and security arrangements; and
- Details of the finance product you have enquired about or applied for, and our response to you.
About your use of our website and marketing preferences:
- Your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries, and browsing behaviour;
- Information about your access to and use of our Site, including through cookies, your communications with our Site, browser and operating system type, and internet service provider domain;
- Your preferences regarding the marketing communications you'd like to receive from us; and
- Additional personal information you provide directly or indirectly through your use of our Site, associated applications, and associated social media platforms, or accounts from which you permit us to collect information.
We may collect these types of personal information directly from you or from third parties, including credit reporting bodies, your accountant or broker, employers, and publicly available sources.
A.3 | COLLECTION AND USE OF SMS AND PHONE NUMBERS
We may collect and hold your phone number to send SMS updates related to your enquiries, application status, and customer support, and, where you have consented, to send promotional information about our products, services or promotions that may be of interest to you.
By providing your phone number, you consent to receive SMS communications, including marketing messages if opted in, in compliance with the Spam Act 2003 (Cth). You can withdraw consent at any time by replying ‘STOP’ or contacting us using the details in the Shared Information section — we will action opt-out requests promptly and update our records.
Where we make outbound calls for marketing purposes, we check numbers against the Do Not Call Register in accordance with the Do Not Call Register Act 2006 (Cth), and will not call numbers on the Register unless an exemption applies.
We may disclose your phone number to third-party service providers solely to enable them to send SMS messages on our behalf. These providers must follow security practices consistent with the APPs and cannot use your phone number for any other purpose.
A.4 | WHY WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
We may collect, hold, use and disclose personal information to:
- Enable you to access and use our Site, associated applications, and associated social media platforms;
- Contact and communicate with you;
- Keep internal records for administrative purposes;
- Conduct analytics, market research and business development, including to operate and improve our Site and associated platforms;
- Run competitions and/or offer additional benefits to you;
- Advertise and market to you, including sending promotional information about our products and services and third-party offers we consider may be of interest;
- Comply with our legal obligations and resolve any disputes;
- Consider your employment application, where you apply to work with us;
- Assess applications for finance, including verifying your identity, assessing capacity to repay, and making lending decisions;
- Manage and administer any finance we provide, including collecting repayments and managing arrears or default; and
- Meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and other applicable financial services laws.
A.5 | DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose personal information to:
- Third-party service providers who enable us to provide our services, including IT, data storage, web-hosting and server providers, debt collectors, maintenance providers, marketing or advertising providers, professional advisers, and payment systems operators;
- Our employees, contractors, and/or related entities;
- Our existing or potential agents or business partners;
- Sponsors or promoters of any competition we run;
- Anyone to whom our business or assets (or any part of them) are, or may in good faith be, transferred;
- Courts, tribunals, and regulatory authorities, in connection with any actual or prospective legal proceedings, or to establish, exercise or defend our legal rights;
- Third parties, including agents or subcontractors, who assist us in providing information, products, services, or direct marketing to you — this may include parties located, or that store data, outside Australia (see A7);
- Credit reporting bodies, for the purpose of obtaining and providing credit information in connection with assessing applications for finance (see Part B);
- Identity verification service providers, for the purpose of confirming your identity in accordance with our AML/CTF obligations;
- Loan funders, warehouse or wholesale funding partners, and their trustees, servicers, custodians, and advisers, for the purpose of funding and administering finance we provide;
- Valuers, quantity surveyors, real estate agents (where relevant), and our loan managers, in connection with assessing or administering finance secured against property or other assets; and
- Government bodies, regulators and law enforcement, including AUSTRAC, where required or authorised by law.
A.6 | OVERSEAS DISCLOSURE
We may store personal information overseas. Where we disclose your personal information to the third parties listed above, those third parties may also store, transfer, or access personal information outside Australia.
The countries in which our overseas service providers are currently likely to store or access personal information include: the United States and Nepal. Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose it to countries with laws that protect personal information in a way substantially similar to the APPs, and/or we will take reasonable steps to ensure overseas recipients protect your personal information in accordance with the APPs.
A.7 | HOW WE TREAT SENSITIVE INFORMATION
Sensitive information is a subset of personal information given a higher level of protection under the APPs. It means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information.
We only collect, hold, use, and disclose sensitive information for:
- The primary purpose for which it is collected;
- Secondary purposes directly related to the primary purpose, including disclosure to the third parties listed above as reasonably necessary to provide our services to you;
- Contacting emergency services, or speaking with your family, partner, or support person, where we reasonably believe there is a serious risk to the life, health, or safety of you or another person and it is impracticable to obtain your consent; and
- Where otherwise required or authorised by law.
A.8 | YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Choice and consent
By providing personal information to us, you understand that we will collect, hold, use, and disclose it in accordance with this Policy. You do not have to provide personal information to us; however, if you do not, it may affect your use of this Site, or our ability to assess or provide finance to you.
Restrict and unsubscribe
You may choose to restrict the collection or use of your personal information for direct marketing, or unsubscribe from our email database or other communications, at any time by contacting us using the details in the Shared Information section, or via the opt-out facility in the relevant communication.
Access and correction
See the Shared Information section at the end of this document, which covers access and correction requests for both personal information (Part A) and credit information (Part B).
A.9 | DATA, QUALITY, SECURITY AND BREACH NOTIFCATION
We are committed to ensuring thepersonal information we collect, including phone numbers and creditinformation, is secure. We have put in place suitable physical, electronic andmanagerial procedures to safeguard it and protect it from misuse, interference,loss, unauthorised access, modification and disclosure.
Transmission of information iscarried out at your own risk. While we take reasonable steps to safeguard yourpersonal information, we cannot guarantee it will not be disclosed in a mannerinconsistent with this Policy.
We have processes in place toidentify, contain and assess suspected data breaches. If we experience a databreach likely to result in serious harm to affected individuals, we will notifythem and the OAIC in accordance with the Notifiable Data Breaches scheme underPart IIIC of the Privacy Act 1988 (Cth).
A.10 | COOKIES, WEB BEACONS AND RETARGETING
We may use cookies on our Site tostore your preferences and improve your experience. Third parties (for example,Google and Meta) may also place our advertisements on social media and otheronline media feeds as part of our retargeting campaigns.
A.11 | LINKS TO OTHER WEBSITES
Our Site may contain links to other websites. We do not control these sites and are not responsible for the protection or privacy of any personal information you provide while visiting them; they are not governed by this Policy.
A.12 | CHANGES TO PART A OF THIS POLICY
We may update this Policy at any time by publishing the amended version on our Site. We recommend checking our Site regularly to stay aware of our current Policy.
part b | credit reporting policy
B.1 | ABOUT THIS POLICY
This Credit Reporting Policy explains how we manage credit information and credit eligibility information about individuals under Part IIIA of the Privacy Act 1988 (Cth) and the CR Code. It applies in addition to Part A above, and applies to individuals only — including sole traders, partners in a partnership, and any individual who provides a personal guarantee in connection with a business finance application — as Australia's credit reporting regime does not apply to information about companies or trusts in their own right.
B.2 | CREDIT REPORTING BODIES WE DEAL WITH
We currently disclose credit information to, and may obtain credit reporting information from, the following credit reporting bodies (CRBs): illion Pty Ltd, Equifax Pty Ltd and Experian Australia Credit Services Pty Ltd.
These CRBs may include the information we provide in reports to other credit providers, to assist them in assessing your credit worthiness. Each CRB has its own credit reporting policy explaining its handling of credit information, including your rights to access and correct information it holds, and your right to ask a CRB not to use your credit reporting information for pre-screening direct marketing by credit providers, or not to use or disclose it if you reasonably believe you have been, or are likely to be, a victim of fraud. Copies of illion's, Equifax's and Experian's credit reporting policies are available on their respective websites, or on request from us.
B.3 | WHAT WE DISCLOSE AND COLLECT
In connection with assessing an application for finance, or managing finance we have provided, we may disclose to, and/or collect from, credit reporting bodies information including:
- Identification information;
- Consumer credit liability information;
- Repayment history information;
- Default information, including overdue payments;
- Court proceedings and insolvency information; and
- Information about credit applications you have made with other credit providers.
B.4 | HOW WE COLLECT THIS INFORMATION
We generally collect credit information directly from you — for example, through an application form, supporting documents you provide, or in conversations with our lending team. We may also collect it from the credit reporting bodies named above, other credit providers (where you have consented or the law permits), your referees, guarantors, accountants, brokers, or authorised representatives, publicly available sources including ASIC registers, and fraud-checking and identity verification services.
B.5 | WHY WE COLLECT, HOLD, USE AND DISCLOSE THIS INFORMATION
We only use and disclose credit information for the purposes for which it was collected, or other purposes permitted under the Privacy Act and the CR Code, including to:
- Assess applications for business finance, including your eligibility, capacity to repay and creditworthiness;
- Manage and administer credit we provide, including account servicing, arrears management and enforcement of our rights;
- Assess whether to accept a person as a guarantor, and to manage that guarantee (see B6);
- Comply with our obligations under the Privacy Act, the CR Code, AML/CTF law, and applicable ASIC guidance, including Regulatory Guide 234 and the Australian Securities and Investments Commission Act 2001 (Cth) (which continues to apply to misleading, deceptive or unconscionable conduct even though our lending is not regulated under the National Consumer Credit Protection Act 2009 (Cth) — see A1);
- Manage our relationship with you, including responding to enquiries and complaints; and
- Exercise our rights, and meet our obligations, in relation to any legal or regulatory proceedings.
B.6 | GUARANTORS
Where an individual provides a personal guarantee in connection with finance we provide to a business, we may collect and use that individual's credit information (including obtaining a credit report) for the purpose of assessing their suitability as a guarantor.
B.7 | DISCLOSURE OF INFORMATION
We may disclose credit information and credit eligibility information to:
- Credit reporting bodies (illion, Equifax and Experian), as described above;
- Other credit providers, for example to obtain or provide information relevant to assessing your credit worthiness or to exchange information about defaults, with your consent or as otherwise permitted by law;
- Guarantors, or prospective guarantors, and their advisers, to the extent necessary to assess or manage a guarantee;
- Our related bodies corporate, service providers and professional advisers who assist us to carry on our business (including IT, loan servicing, debt collection and legal service providers), on a confidential basis and only for the purposes for which we engage them;
- Regulators, and courts or tribunals, where required or authorised by law; and
- Any other person or organisation as required or authorised by law, or with your consent.
Overseas disclosure of credit information is addressed together with personal information generally in Part A, Section A7.
B.8 | RETENTION
We retain credit information and credit eligibility information for as long as reasonably necessary for the purposes described in this Part B and to meet our legal and regulatory obligations. As a general rule, we retain this information for seven (7) years from the date it is collected, or the date our relationship with you ends, whichever is later, after which it is securely destroyed or de-identified unless we are required or permitted by law to retain it for longer.
B.9 | DEFAULT LISTINGS
Before listing a default on your credit file, wewill comply with our obligations under the CR Code, including providing youwith prior written notice and a reasonable opportunity to make payment.
B.10 | HOW CREDIT DECISIONS ARE MADE
All credit decisions at FRONT are made by our in-house credit team and committees, who review every application — we do not use automated decision-making to approve or decline an application for finance. Credit information and credit eligibility information obtained from CRBs and other sources informs, but does not automatically determine, the outcome of an application; every decision involves review and judgement by our credit team and committee.
part C | ACCESS, COMPLAINTS AND CONTACT DETAILS
This section applies to both Part A (Privacy Policy) and Part B (Credit Reporting Policy).
C.1 | ACCESS AND CORRECTION
You may request access to the personal information, credit information, or credit eligibility information we hold about you, and ask us to correct it if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond to access requests within a reasonable period (and in any event within the timeframes required by the Privacy Act and CR Code), and will not charge a fee for making a correction request.
C.2 | COMPLAINTS AND EXTERNAL DISPUTE RESOLUTION
At FRONT, we take complaints seriously. If something hasn't gone the way you expected — including how we've handled your personal, credit, or credit eligibility information — we want to hear about it so we can put it right.
You can make a complaint verbally, in writing, in person, by phone, by email, or by post, using the details in Section C.3. You don't have to use a particular form of words — if you're unhappy with our service or our handling of your information, that's enough for us to treat it as a complaint. Making a complaint to us is free.
What happens next:
- We acknowledge your complaint within 1 business day;
- We investigate — reviewing files, listening to any calls, and speaking with the staff involved; and
- We give you a written response within 30 calendar days.
External Dispute Resolution
Front Financial provides credit only to companies, corporate trustees and individuals borrowing wholly or predominantly for business or investment purposes. Loans provided by Front Financial are not “credit contracts” for the purposes of the National Consumer Credit Protection Act 2009 (Cth). Front Financial is not a member of the Australian Financial Complaints Authority (AFCA), and disputes about our loans are not eligible for AFCA determination.
If we cannot resolve your complaint through our internal process, you may refer the dispute to mediation through a recognised commercial dispute-resolution scheme (for example, the Resolution Institute), or seek independent legal advice about your rights. Nothing on this page affects your rights under the Australian Securities and Investments Commission Act 2001 (Cth) in respect of misleading or deceptive, or unconscionable, conduct.
Complaints about your personal or credit information
If you're not satisfied with our response to a complaint specifically about how we've handled your personal information, credit information, or credit eligibility information, you may also complain to the Office of the Australian Information Commissioner (OAIC), which oversees compliance with the Privacy Act and CR Code.
Resolution Institute
Suite 602, Level 6, Tower B, ZenithCentre, 821–843 Pacific Hwy, Chatswood NSW 2067
1800 651 650 | infoaus@resolution.institute
OAIC
GPO Box 5288, Sydney NSW 2001
1300 363 992 | oaic.gov.au
C.3 | CONTACT US
For any questions, complaints, or notices regarding this Policy, or to make a request regarding your personal orcredit information, please contact our Privacy Officer and Complaints Officer:
• Entity: FF Loan Manager Pty Ltd, trading as FRONT Financial
• ABN 85 702 441 414 | ACN 702 441 414
• Privacy Officer and Complaints Officer: Ryan Sweeney, Chief Executive Officer
• Email: ryansweeney@frontfinancial.com.au
• Phone: 0466 634 494
• Address: 1 Market Street, Sydney, NSW, 2000
This Policy was last updated on 2nd September 2026 and may be updated from time to time. The current version is alway savailable on our website.