Privacy policy

Who we are and what this covers

Broker Twin (ABN 73 402 846 460) is an Australian business based in Sydney. We provide an AI employee for mortgage brokers: software that makes calls, gathers documents, monitors rates and follows up with clients for a brokerage. In this policy, "we", "us" and "our" mean Broker Twin.

This policy explains how we handle personal information about:

• people who visit brokertwin.com.au
• people who contact us or book a call with us
• brokerages, and the people who work in them, who trial or use Broker Twin
• clients of those brokerages, whose information the AI employee handles for the brokerage
• people who ask about working with us.

We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. We apply that standard to all the personal information we hold.

Our two roles

Our own customers and contacts. When you visit our website, contact us, book a call, or trial or use Broker Twin as a brokerage, we decide what we collect and why. This whole policy applies.

Clients of a brokerage. When a brokerage uses Broker Twin with its clients, the brokerage chooses which clients the AI employee contacts and what it does. We handle those clients' information on the brokerage's instructions and under our agreement with it. The brokerage's own privacy policy also applies.

If you are a client and your question is about your loan, your broker is the right person to ask. If your question is about how Broker Twin handled your information, you can ask your broker or ask us.

What we collect

What the AI employee never asks for. It never asks for passwords, PINs, tax file numbers or card numbers. If a document shows a tax file number, please cover it before you send it.

Sensitive information. We do not ask for sensitive information, such as health information. If it appears in a document or a call, we handle it only as part of that record and do not use it for anything else.

Payment details. Card and bank payment details are handled by our payment provider. We do not store full card numbers.

Children. Broker Twin is a service for businesses and their adult clients. We do not knowingly collect information from anyone under 18.

How we collect it

• From you, when you fill in a form, book a call, email us, talk to or message the AI employee, or upload a document.
• From a brokerage, when it adds a client or a team member to Broker Twin.
• From your bank, only with your express consent, through an accredited data recipient under the Consumer Data Right.
• Automatically, through the standard logs our website host keeps when pages load.
• From public registers, such as ASIC's registers, to confirm that a brokerage holds an Australian credit licence or is an authorised credit representative.

If you give us information about another person, please make sure they know and agree.

You can stay anonymous when you browse the website or ask a general question. We need your details to reply to you, book a call or provide the service.

Why we use it

We use personal information to:

• answer enquiries and run discovery calls and demos
• set up and run trials and subscriptions, send invoices and give support
• carry out the tasks a brokerage has switched on for its AI employee, such as calls, intake and fact-finding, gathering and checking documents, rate monitoring and follow-up
• keep the service secure, find and fix faults, and understand how it is used so we can improve it
• keep records, meet our legal obligations and handle complaints
• send brokers news about Broker Twin, where the law allows (see Marketing).

We do not use a brokerage's clients' information for our own marketing. Follow-up contact with clients is made for their brokerage.

If you do not give us the information we ask for, we may not be able to reply to you or provide the service.

AI and automated decisions

The AI employee is software. On every call it says it is an AI assistant and names the brokerage it is calling for.

It never gives advice and never decides a loan. The AI employee does not give credit, financial or legal advice. It does not decide whether anyone gets a loan, a rate or a product. Brokers give the advice. Brokers and lenders make those decisions.

Steps the software takes without a person:

• choosing when to send a reminder or make a follow-up call, within the hours and rules the brokerage sets
• checking whether a document is the one requested, is readable and is complete, and asking again if it is not
• comparing the rate on a loan with rates lenders publish.

Steps where the software helps a person decide:

• summarising calls and the details a client has given, for the broker to review
• flagging loans whose rate may be worth reviewing, and suggesting which clients a broker speaks to first.

Information the software uses for these steps: contact details, the content of calls and messages, documents, loan details and, with consent, bank data.

If you think an automated step got something wrong about you, tell us or your broker and a person will review it.

Who we share it with

• The brokerage. A client's information goes only to that client's own brokerage.
• Providers that help us operate: website hosting and forms, form security, booking, email, cloud hosting, phone and messaging carriers, voice AI and transcription, payments and accounting. They receive only what they need to do their job for us.
• An accredited data recipient, which collects bank data when a client consents.
• Our professional advisers and insurers, where they need it to advise or cover us.
• Regulators, courts and law enforcement, where the law requires or allows it.
• A successor to the business, if Broker Twin is sold or restructured, for example moved into a company. The successor must handle the information as this policy describes.

We never sell personal information.

Where it is stored and sent

We are based in Australia. Our main database is hosted in Australia, and bank data is stored only in Australia.

Some of our providers store or process information overseas, mainly in the United States:

• Netlify hosts this website and receives contact form messages and job applications, including any resume you upload (United States).
• Calendly provides the booking calendar (United States).
• Cloudflare runs the security check on our forms (United States, and other countries where Cloudflare operates).
• Google supplies the fonts on this website, so your browser connects to Google's servers when a page loads.
• Phone, messaging and voice AI providers may process call audio, transcripts and messages in the United States when the service is in use.

Before we send personal information overseas, we take reasonable steps to make sure the recipient protects it to a standard like ours. We will update this section if the countries change.

Bank data and the Consumer Data Right

Some features use bank account and transaction data shared under the Consumer Data Right.

• It is collected only with the client's express consent, given on the consent screens of an accredited data recipient. No one can consent for you.
• The AI employee never asks for your internet banking password.
• Consent is for a set purpose and a set time. You can withdraw it at any time, at no cost.
• Bank data is stored in Australia. It is never used for marketing and never sold.
• When consent ends, we delete the bank data and anything worked out from it.

Bank data features are not yet available. Before they are switched on for any brokerage, we will publish a Consumer Data Right policy on this website. It will name the accredited data recipient and explain how to see, manage and withdraw your consent, and how to complain.

Calls, recordings and messages

When the AI employee contacts a brokerage's client, it:

• says it is an AI assistant and names the brokerage it is calling for
• tells you at the start if the call is recorded
• calls only within the hours the telemarketing rules allow
• names the brokerage in every text message.

To stop contact, tell the AI employee during a call, reply STOP to a text message, or tell your broker. We stop and let the brokerage know.

Recordings and transcripts are used to pass accurate details to your broker, to check quality and to fix faults.

Marketing

We send brokers news about Broker Twin only where they have agreed, or where we are otherwise allowed to under the Spam Act 2003. Every message says it is from Broker Twin and tells you how to unsubscribe. We act on an unsubscribe within five business days.

Cookies and similar technology

• We do not use advertising or analytics cookies on this website.
• The website stores one item in your browser for the length of your visit, so the opening animation plays once. It does not identify you.
• When you open the booking calendar, Calendly loads inside the page and may set its own cookies. Calendly's privacy policy applies to it.
• Our forms use Cloudflare Turnstile, a security check that tells people from automated programs. It reads technical details about your browser and device to do this. Cloudflare's privacy policy applies to it.
• Links to Instagram, LinkedIn and Facebook take you to those sites, which have their own policies.

If we add analytics later, we will update this section first.

How we protect it

We take reasonable steps to protect personal information from misuse, loss and unauthorised access. These include:

• encrypting information when it moves between systems
• limiting access to the people who need it to do their work
• keeping bank data separate from our other systems and stored in Australia
• choosing providers with care.

No system is completely secure. If you think your information is at risk, tell us straight away.

How long we keep it

We keep personal information only for as long as we need it for the purposes in this policy, or as the law requires. Then we delete it or remove what identifies you.

• Enquiries are kept while we are in contact with you and for a reasonable time afterwards.
• A brokerage's client information is kept while the brokerage uses Broker Twin. When the brokerage leaves, we return or delete it as our agreement with the brokerage sets out.
• Bank data is deleted when the client's consent ends.
• Records the law requires, such as consent records and tax records, are kept for the period the law sets.

If something goes wrong

If personal information we hold is lost, or accessed or disclosed without authorisation, we act quickly to contain it and work out what happened. If the breach is likely to cause serious harm, we tell the people affected and the Office of the Australian Information Commissioner. If it involves a brokerage's clients, we also tell the brokerage.

Seeing and correcting your information

You can ask us for a copy of the personal information we hold about you, or ask us to correct it. Email support@brokertwin.com.au.

• We may need to confirm who you are first.
• We respond within 30 days.
• There is no charge to make a request. If a request is unusually large we may charge a reasonable cost, and we will tell you first.
• If we cannot give you access or make a correction, we tell you why in writing.

If you are a client of a brokerage, you can also ask your broker.

Complaints

If you think we have mishandled your personal information, email support@brokertwin.com.au and mark it for the Privacy Officer.

1. We acknowledge your complaint within 7 days.
2. We look into it and give you a written answer within 30 days.
3. If you are not satisfied, 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 review this policy at least once a year and whenever what we do changes. The date at the top shows when it was last updated. If a change is significant, we will say so on this website, and we will tell brokerages that use Broker Twin directly.

Contact us

Privacy Officer, Broker Twin (ABN 73 402 846 460)
Email: support@brokertwin.com.au
You can also use the contact form.

We will give you a copy of this policy in another form, such as by email, if you ask.