Privacy Policy

1. Who this policy is from

This Privacy Policy is for Bayley Clarke (ABN 93 663 382 974), trading as Bayley the Broker. I operate as a credit representative under Lendi Group Distribution Pty Ltd (ABN 27 105 265 861, Australian Credit Licence 246786).

In this policy, "I", "me", "my", and "we" mean Bayley Clarke / Bayley the Broker. "You" means anyone whose personal or credit information I handle: clients, prospective clients, referral partners, or visitors to this website.

This policy explains how I handle personal information and credit information under the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Privacy (Credit Reporting) Code 2014.

2. What information I collect

Personal information

• Name, date of birth, residential address, phone number and email address
• Government identification (driver licence, passport, Medicare card) for identity verification
• Employment details and income information (payslips, PAYG summaries, tax returns, BAS)
• Bank statements, expense details, existing debts and liabilities
• Details about your family, dependants and living situation, where relevant to a loan application
• Property information (purchase contracts, existing property, valuations)

Credit information

• Credit reports obtained from credit reporting bodies (with your consent)
• Details of existing loans, credit limits, repayment history
• Default or serious credit infringement information (where applicable)

Website and device information

• IP address, browser type, device type, operating system, referring URL
• Pages visited, time spent on pages, clicks on buttons and links
• Cookies and similar tracking technologies (see section 7)

3. How I collect your information

• Directly from you: when you call, email, DM, submit a form, book a call, or attend a meeting
• From the Lendi platform: when you complete a fact-find or upload documents through Lendi's broker tools
• From third parties you've authorised: credit reporting bodies, lenders, your accountant, your conveyancer, your real estate agent, or referral partners
• Automatically, via this website: through cookies, the Meta Pixel, and Google analytics tools when you visit bayleythebroker.com
• From recorded phone calls: I use a voice-recording tool (Plaud) to capture calls so I can accurately document your situation. I will always tell you the call is being recorded. You can decline.

4. Why I collect your information

I collect personal and credit information so I can:

• Assess your borrowing needs and eligibility
• Recommend suitable loan products and lenders
• Prepare and submit loan applications on your behalf
• Communicate with you about your application and loan
• Meet my obligations under the National Consumer Credit Protection Act 2009, AML/CTF law, and ASIC regulations
• Keep you informed about rate reviews, refinance opportunities and other services you may value
• Operate, improve and market my business

5. Who I share your information with

To do my job, I have to share some of your information with third parties. I only share what's necessary, and I only share it with parties who have a legitimate role in your loan, your business relationship with me, or the operation of my business.

Lenders and aggregators

• Lendi Group: my aggregator. All client applications pass through Lendi's systems.
• Lenders on my accredited panel (approximately 26 lenders): when you authorise me to submit an application or obtain a pre-approval on your behalf.
• Credit reporting bodies: when you authorise a credit check.
• Aussie Platform Finance: for asset finance and personal lending referrals, with your consent.
• Alliance Insurance: for insurance referrals, with your consent.

Technology providers

I use the following tools to run my business. Each one processes a specific slice of your information:

Provider	What they do	Where they're hosted
Google (Gmail, Google Drive, Google Sheets, Google Calendar)	Email, document storage, client records, scheduling	United States
Meta Platforms (Facebook, Instagram, Meta Pixel)	Advertising, retargeting, engagement analytics. See section 7	United States
Calendly	Call bookings	United States
Netlify	Website hosting	United States
Plaud	Call recording and transcription	United States
Anthropic (Claude API)	AI-assisted processing of call transcripts and drafting emails	United States
Zapier	Automation and data movement between the tools above	United States

By providing me with your information and continuing to use my services, you consent to it being transferred to and processed in the United States. I take reasonable steps to ensure these providers handle your information consistently with the APPs, but I do not have direct control over how overseas providers handle information once it is disclosed to them.

Other parties

• Your accountant, conveyancer, solicitor, real estate agent or financial planner, only with your authority
• Government and regulatory bodies (ASIC, AUSTRAC, ATO, AFCA, OAIC), when required by law
• Professional advisors engaged by me (e.g. compliance, legal), bound by confidentiality
• A purchaser of my business or book, if I ever sell it, and only under confidentiality obligations

6. Direct marketing

I may use your contact details to send you information about interest rate movements, refinance opportunities, fixed-rate expiry reminders, market updates, and content I think you'll find useful. This is part of the ongoing service relationship I have with you.

You can opt out at any time by emailing info@bayleythebroker.com, replying "unsubscribe" to any marketing email, or telling me directly on a call. Opting out of marketing will not affect the service you get on an active loan application.

I do not sell, rent or trade your personal information to third parties for their marketing.

7. Cookies, the Meta Pixel and online tracking

When you visit bayleythebroker.com, I use cookies and similar technologies to understand how people use the site and to show relevant ads on Facebook and Instagram.

What the Meta Pixel does

• Records page views and interactions (e.g. clicks on phone links, email links, Calendly links) and sends that data to Meta
• Uses Automatic Advanced Matching: if you submit a form that includes an email or phone number, the pixel creates a hashed (SHA-256, one-way encrypted) version of that data and sends it to Meta so Meta can match the activity on my site to your Facebook or Instagram account
• Builds audiences I can advertise to: for example, people who've visited my site or who've clicked a call-to-action

You can limit or disable this tracking by:

• Adjusting your Facebook ad preferences at facebook.com/adpreferences
• Using your browser's "Do Not Track" or private browsing settings
• Clearing cookies or using browser extensions that block pixels (e.g. Privacy Badger, uBlock Origin)

I also use Google services (including Gmail and Google Sheets) and Google Analytics on this website, which uses cookies to help me understand how visitors use the site.

8. How I store and protect your information

• All client records, fact-finds, documents and call notes are stored in Lendi's systems and/or my own encrypted cloud accounts (Google Workspace)
• Access to those accounts is protected by strong passwords and two-factor authentication
• Physical documents (rare, I work digitally) are kept securely and shredded when no longer required
• I review access and retention regularly, and I destroy or de-identify information when there is no longer a lawful reason to keep it (generally, seven years after our relationship ends, consistent with my record-keeping obligations)

If a data breach occurs that is likely to result in serious harm to you, I will notify you and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.

9. Your rights: access and correction

You have the right to:

• Ask what I hold about you. Email me and I'll tell you.
• Get a copy of your information. I'll provide it within 30 days. For most requests, this is free. For unusually large or complex requests, I may charge a reasonable cost-recovery fee and I'll tell you the amount before starting.
• Correct anything that's wrong. Email me with the correction and I'll update my records and let any third parties I've shared the information with know about the correction.
• Withdraw consent to direct marketing, credit checks, or other optional uses of your information.

Send access and correction requests to info@bayleythebroker.com with "Privacy request" in the subject line.

10. Anonymity and pseudonyms

You can browse my website or ask general questions anonymously. But because I'm regulated under credit and AML/CTF laws, I can't prepare or submit a loan application for you without collecting and verifying your real identity.

11. Complaints

If you think I've mishandled your personal or credit information, tell me first. I want the chance to make it right.

• Email: info@bayleythebroker.com with "Privacy complaint" in the subject
• Phone: 0437 189 939

I'll acknowledge your complaint within 5 business days and give you a written response within 30 days.

If you're not satisfied with my response, you can escalate to:

• Lendi Group (as my credit licence holder): lendi.com.au
• Australian Financial Complaints Authority (AFCA): afca.org.au, 1800 931 678, free external dispute resolution
• Office of the Australian Information Commissioner (OAIC): oaic.gov.au, 1300 363 992, for privacy-specific complaints

12. Changes to this policy

I'll update this policy whenever my tools, practices or obligations change. The "Last updated" date at the top of the page always reflects the most recent change. For significant changes, I'll flag it on the homepage or by email to existing clients.

13. Contact

Bayley Clarke
Bayley the Broker
ABN 93 663 382 974
Credit Representative of Lendi Group Distribution Pty Ltd (ABN 27 105 265 861, ACL 246786)
Email: info@bayleythebroker.com
Phone: 0437 189 939
Website: bayleythebroker.com