Effective Date: September 28, 2025
This is the Privacy Policy of CAPFLOW Pty. Ltd. (ABN: 689 915 580), located at Suite 130, 155 Clarence Street, Sydney, NSW, Australia, 2000 (“we,” “us,” or “our”). We are committed to ensuring the privacy of your personal information and are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“AU Privacy Act”). Our handling of personal credit information is also subject to the Privacy (Credit Reporting) Code 2014 (Cth).
This Privacy Policy is relevant to your dealings with CAPFLOW Pty. Ltd. and your use of our website. The Privacy Policy sets out how we manage your personal information and, if applicable, your personal credit information. The website is owned and operated by CAPFLOW Pty. Ltd. and is used to facilitate the provision of our business loan products and related services.
In this Privacy Policy, a reference to “we” or “us” is a reference to CAPFLOW Pty. Ltd. “Personal information” has the meaning defined in the AU Privacy Act and includes any information about an identifiable individual.
If you have any questions relating to this Privacy Policy, you may contact our Privacy Officer as described under the heading “Access and Correction” below.
Collection of Personal Information
The personal information we collect about an individual depends on the products or services being provided, or that may be provided, to you or another person connected to you. The information we may collect about you, where you are an individual, may include:
- Your name, address, date of birth, telephone number, marital status, nationality, and email address.
- Your business name, tax numbers, and unique identifiers (e.g., username, password, IP address).
- Information from personal identification documents (e.g., passport or driver’s license numbers) for identity verification.
- Bank account information and details about your financial situation, including income, assets, expenses, debts, bank statements, credit report information, and payment history.
- Details of any securities you have provided to us or another person.
- Information about your business, including its size and type.
- Details of specified transactions with which you are involved.
We may also process consumer credit-related personal information to develop a credit rating or score to assess your creditworthiness.
From time to time, we may request additional or updated information, for example, when you apply for a new loan, vary an existing loan, or to enable us to provide our products and services effectively.
Providing information is optional, but failure to provide certain information may prevent us from performing relevant services or limit the products or services we can offer.
We collect personal information for the purposes outlined in section 5 (Use and Disclosure of Personal Information).
Anti-Money Laundering and Counter-Terrorism Financing
Before providing a product or service to you or a person connected with you, we may be required to collect your personal information to comply with our customer identification obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AMLCTF Act”). This typically includes identification information such as your name, residential address, and date of birth. In some cases, we may need to collect information about political activities or opinions to determine if you are a politically exposed person under the AMLCTF Act. By providing this information, you consent to its use and disclosure for this purpose.
We may need to clarify or update previously collected information or collect further details, including financial information, directly from you or third-party sources. As part of our verification processes under the AMLCTF Act, we may take copies of your personal identification documents.
We may disclose your full name, residential address, and date of birth to a credit reporting body to assess whether this information matches their records. The credit reporting body may compare your details with other individuals’ information for this purpose.
You have the right to:
- Notify us by email at privacy@capflow.com.au if you do not want us to disclose your personal information to a credit reporting body for this purpose.
- Opt for an alternative means of identity verification under the AMLCTF Act. How We Collect Personal Information We may collect your personal information through:
- Application forms completed by you or a person connected to you.
- Information provided by you or someone seeking finance from us, including through our website.
- Information provided by our business partners or referrals.
- Site visits, external data providers (e.g., credit reporting agencies, other credit providers, or social media), or public databases (e.g., Australian Securities and Investments Commission).
- Verification from third parties, such as Equifax Australia Information Services and Solutions Pty Limited.
- Email or telephone contact with you.
We typically collect personal information directly from you unless it is unreasonable or impractical to do so. For certain information held by third parties (e.g., credit reporting agencies), we may collect it from the relevant third party. Information collected through our website may include IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
If you provide us with personal information about someone else, you must ensure you are authorized to disclose it and that we may collect, use, store, and disclose it for the purposes described in this Privacy Policy. You must take reasonable steps to ensure the individual is aware of and consents to these matters.
We will not collect sensitive information (e.g., race, political or religious beliefs, sexual preferences, criminal convictions, or health information) without your consent, except where authorized or required by law.
Use and Disclosure of Personal Information
We will only use or disclose your personal information:
- For the purpose for which it was collected.
- For related purposes you would reasonably expect.
- For promotion or marketing purposes, where permitted by law.
- For statistical and research purposes.
- With your consent.
- Where required or permitted by law.
We may use your personal information to:
- Identify you, conduct due diligence, or establish your tax status under Australian or foreign laws.
- Assess and process your application for a financial product or service or that of a connected person or entity.
- Assess your suitability as a guarantor.
- Operate, maintain, and improve our financial products or services.
- Open and maintain a business loan account for you or a connected person or entity.
- Complete and manage transactions, including deducting periodic payments.
- Communicate confirmations and account updates.
- Manage our relationship with you and respond to customer requests.
- Assess products suitable for your financial needs or those of a connected person or entity.
- Send marketing communications about products that may interest you.
- Audit and monitor our services.
- Investigate, identify, or prevent fraud or unlawful activity.
- Update your personal information or that of a connected person or entity.
- Meet legal obligations, including under the AMLCTF Act or Australian taxation laws.
- Post and review your comments on our blog, if requested.
- Produce anonymized data analytics and reports for sharing with business partners.
We may disclose your personal information to:
- Our related companies, business partners, service providers, subsidiaries, or affiliates assisting with credit applications or service provision (e.g., data storage).
- Our agents, introducers, contractors, or third-party service providers for administrative support.
- Credit reporting bodies or other credit providers.
- Other financial institutions in connection with your credit application or dealings with us.
- Your authorized agents, executor, administrator, or legal representative.
- Government agencies or regulatory bodies for statutory or law enforcement purposes.
- Parties acquiring an interest in our business or assets.
Third-party service providers are authorized to use your personal information only as necessary to provide services to us and must comply with the AU Privacy Act and our privacy standards.
Data Sharing with Business Partners
We may share personal information (including credit-related information) and business-related information with business partners with whom you have an existing relationship. These partners may refer you to us for a business loan. If you apply for a loan, we may disclose certain information collected during the application process or loan servicing to the relevant partner. This includes:
- Your business name and contact details.
- Loan approval or decline status, amount, and term.
- Your reported assets, liabilities, and turnover.
- Details about failed or late payments and arrears.
Business partners use this information for internal reporting, improving customer experience, and marketing purposes. For further details, contact us at privacy@capflow.com.au.
How We Hold Personal Information
We take reasonable steps to protect your personal information from loss, misuse, interference, and unauthorized access, modification, or disclosure using physical and electronic security measures, such as access restrictions. We train our employees to maintain confidentiality. We retain your personal information for as long as necessary for its collected purpose or as required by law.
Overseas Disclosures
We may disclose your personal information to business partners, service providers, subsidiaries, or affiliates located overseas (e.g., in the United States) to assist in delivering our products and services, such as customer service, credit checks, or data storage. We will comply with applicable laws when doing so.
Credit Reporting – Notifiable Matters
While we do not provide consumer credit, we may use consumer credit information to assess commercial credit applications or guarantor suitability. We may disclose or collect personal information from credit reporting bodies, such as Equifax Australia Information Services and Solutions Pty Limited (https://www.equifax.com.au/) or Illion Australia Pty Limited (https://www.illion.com.au/), which include this information in reports for other credit providers.
You can ask these credit reporting bodies not to:
- Use or disclose your credit information if you believe you are a victim of fraud.
- Use your credit information for pre-screening direct marketing by a credit provider.
We do not use credit-related personal information for direct marketing.
Access and Correction
We strive to ensure the personal information we collect, use, or disclose is accurate, complete, and up-to-date. You may request access to your personal information (including credit information) or request corrections if the information is inaccurate, incomplete, or outdated. We will endeavor to process corrections within 20 working days or notify you of any delays.
We do not charge a fee for access requests but may charge reasonable costs for processing. It is your responsibility to inform us if your personal information needs correction or updating.
To request access or corrections, contact our Privacy Officer at privacy@capflow.com.au or by postal mail at:
CAPFLOW Pty. Ltd.
Suite 130, 155 Clarence Street
Sydney, NSW, Australia, 2000
We will respond within 30 business days. We retain your information as long as your account is active or as necessary for its collected purpose (or longer if required by law).
Marketing and Option to Opt Out
We may contact you to offer products or services of interest. You may opt out of marketing communications by:
- Following unsubscribe instructions in our emails.
- Emailing privacy@capflow.com.au with your full name, business email, and account number.
- Mailing us at the address above.
You may also opt out of sharing personal information provided for public display (e.g., blog comments or testimonials) by contacting us at privacy@capflow.com.au.
Concerns or Breaches We take the security of your information seriously. If we become aware of a data breach involving loss, unauthorized access, misuse, interference, or disclosure, we will take steps to contain and rectify the breach, prevent reoccurrence, and comply with notification obligations.
If you have a complaint about our handling of your personal information, contact our Privacy Officer at privacy@capflow.com.au. We will investigate and aim to resolve your concerns.
If we do not adequately address your concerns, you may complain to the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/privacy/privacy-complaints. Complaints must be made in writing.
Updates to This Privacy Policy
We may update this Privacy Policy to reflect changes in our information practices. Material changes will be notified by email or a notice on our website before taking effect. Your continued use of our services constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically.
Additional Information Relating to Use of Our Website
Tracking Technologies
We and our partners (e.g., marketing partners, analytics, or service providers) use cookies, beacons, tags, and scripts to analyze trends, administer the website, track user movements, and gather demographic information. We use cookies for user authentication and analytics. You can control cookies at the browser level, but rejecting cookies may limit website functionality. Learn more at allaboutcookies.org.
Log Files
We automatically collect and store information in log files, including IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and clickstream data. We may combine this with other collected information to improve services, marketing, analytics, and website functionality.
Behavioral Advertising/Re-Targeting
We partner with third parties to display advertising on our website and manage advertising on other sites. These partners may use cookies to gather information about your browsing activities to provide interest-based ads. You may opt out of interest-based ads by following instructions provided by our partners, but you will still receive generic advertisements.
Security of Information
We protect your information using bank-level security, including 128-bit encryption and Secure Sockets Layer (SSL) protocol. Sensitive information (e.g., credit card numbers) is encrypted during transmission. If you provide banking information online, it is read-only, and we cannot change or modify it. Employee access to banking usernames and passwords is restricted and securely stored with financial service providers.
Third-party service providers performing data storage or processing are instructed to comply with our privacy standards and use your information only for the intended purpose.
Links to Third-Party Sites
Our website may include links to third-party sites with different privacy practices. We are not responsible for their practices, and you should review their privacy policies.
Blog/Forum
Our website may offer publicly accessible blogs or forums. Information you provide in these areas may be read, collected, or used by others. To request removal of your personal information, contact us at privacy@capflow.com.au. We will inform you if removal is not possible.
Testimonials
With your consent, we may post testimonials with your name. To update or delete your testimonial, contact us at privacy@capflow.com.au.
Social Media Widgets
Our website may include social media features (e.g., Facebook “Like” button) that collect your IP address, visited pages, or set cookies. These features are governed by the privacy policies of the providing company.
