SUM+ Privacy Policy

AKMT Financial Services Pty Ltd trading as SUM+ ABN 87 169 182 432 | Australian Credit Licence 509559 Effective date: 1 November 2026

 

1. About this policy

AKMT Financial Services Pty Ltd trading as SUM+ (“SUM+”, “we”, “us”) is a mortgage broking business and holds Australian Credit Licence 509559. We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), Part IIIA (credit reporting) and the Privacy (Credit Reporting) Code. This policy explains how we collect, use, disclose and protect your personal information, including when we use technology and artificial intelligence (AI).

 

2. Information we collect

We collect the information we need to give you credit assistance. This may include:

• Identity and contact details: name, date of birth, address history, phone, email, citizenship or residency, and identity documents.
• Financial information: employment and income, payslips, tax returns, business financials, bank and loan statements, assets, liabilities, living expenses and dependants.
• Credit information: credit reports, credit scores, repayment history, defaults and credit enquiries (see section 5).
• Property information: contracts of sale, valuations, rates notices and title searches.
• Communications: emails, messages and notes of our conversations with you.

 

We do not collect or use health information.

Tax file numbers. We do not ask for your tax file number (TFN). If a document you give us shows a TFN, we do not record it, and we redact it where we can before storing or sharing the document.

Information about other people. You may give us information about other people connected to your application, such as co-borrowers, guarantors, dependants, your spouse or partner, your employer, accountant, solicitor or other advisers. Before you do, please tell them you are giving us their information and where they can find this policy. We handle their information in the same way as yours

 

We usually collect information directly from you, in person, by phone, by email, or through our fact find and document request process. With your consent, we may also collect it from credit reporting bodies, lenders, your employer, accountant, real estate agent, solicitor, other brokers or referrers, and public registers.

If you do not give us the information we ask for, we may not be able to help you. You can make general enquiries without identifying yourself.

We also collect your contact details when you complete a form on our website or a lead form in one of our Facebook or Instagram ads (see our Cookie and Online Advertising Notice).

Electronic identity verification. We, and the lenders we submit your application to, may verify your identity electronically. This can involve checking your identity documents against government records through the Document Verification Service, or matching your name, address and date of birth with information held by a credit reporting body. This check is not a credit enquiry. If you would prefer not to be verified electronically, tell us and we will arrange another method.

Information we did not ask for. If we receive personal information we did not ask for and do not need, we destroy or de-identify it as soon as practicable, where it is lawful to do so.

 

4. Why we use it

We use your information to:

• understand your needs and objectives and recommend suitable loan options;
• complete our responsible lending obligations, including the preliminary assessment that a loan is not unsuitable for you;
• verify your identity, income, expenses and liabilities;
• prepare and lodge loan applications and manage them through to settlement;
• review your loans after settlement;
• meet our legal, licensing, audit and record-keeping obligations;
• handle complaints; and
• send you information about products and services, unless you opt out (see section 12).

 

5. Credit reports and credit information

With your consent, we may obtain your credit report from a credit reporting body to help assess which loans may suit you. The credit reporting bodies we may use are:

• Equifax — www.equifax.com.au
• illion — www.illion.com.au
• Experian — www.experian.com.au

Each of these bodies has its own credit reporting policy on its website. You can ask a credit reporting body not to use your credit information for direct marketing pre-screening. If you believe you are a victim of fraud, you can ask them to place a ban period on your credit file.

We use credit information only to help you obtain credit and to meet our legal obligations. It may be reviewed by our credit team, including team members overseas (section 9). We do not disclose it to anyone except as allowed under Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code.

 

6. How we use artificial intelligence

AI is used on your file in two ways: through our own AI platform, which we control, and within our aggregator’s platform, which we do not control. We explain each separately.

 

6.1 Our AI platform

We use an enterprise version of AI software to help our credit team work on your file. Our use is limited to three things:

• Financial assessment: analysing your income, expenses, liabilities and credit history, and running an initial (indicative) servicing calculation.
• Data accuracy: comparing the information you have declared with your supporting documents, and flagging differences for us to check with you.
• Financial data: reading and organising the financial documents you give us.

 

We do not use our AI platform for any other purpose.

Our commitments:

• We only use the enterprise version of the software. Information we enter is not able to be used for AI learning or model training outside our control.
• Only the financial and identity information needed for the assessment is used. Health information is never used.
• A qualified SUM+ team member reviews all AI output. AI does not make any decision about you on its own.
• We do not enter your information into free or publicly available AI tools.
• As the licensee, we regularly audit our use of AI and our team’s handling of client information. We record and track any issues through to resolution.

 

6.2 Our aggregator’s platform

We lodge loan applications through our aggregator’s platform. The aggregator uses AI within that platform to help refine broker notes and the rationale for the lender we recommend. This information stays inside the aggregator’s platform.

The aggregator manages and maintains that platform under its own privacy policy and security controls, which we do not control. Our aggregator is bound by the Privacy Act, and a copy of its privacy policy is available on request. A SUM+ broker reviews and approves all broker notes and lender rationale before they are used by any lender.

 

6.3 Video meetings

We may meet with you using Zoom and other video conferencing tools. Some of these tools offer recording, transcription and automated meeting summaries. We will tell you at the start of a meeting if it is being recorded or transcribed. Meeting content is processed by the provider under its own privacy terms. Any recording or notes we keep are stored securely and kept in line with section 11.

 

7. Automated decision-making

Some of our software uses your personal information to do things that are substantially and directly related to decisions that can significantly affect you. This section explains what that involves.

Decisions made solely by a computer program: None. A person makes every decision.

Decisions where a computer program substantially helps a person decide:

• whether a loan is likely to be not unsuitable for you (our preliminary assessment);
• which loan options and lenders we present to you;
• how much you may be able to borrow (indicative servicing); and
• what further information or documents we need from you.

 

Kinds of personal information used: identity details, age, income and employment, living expenses and dependants, assets and liabilities, credit report information, and property details.

The lender makes the final decision on whether to approve your loan. Lenders have their own privacy policies, which explain their own use of automated decision-making.

If you have questions about how a recommendation was reached, or want a person to review it, contact us (section 16).

 

8. Who we share it with

We only disclose your information as needed to help you or as required by law. This may include:

• lenders and credit providers;
• lenders mortgage insurers;
• credit reporting bodies;
• valuers;
• aggregators and loan lodgement platforms;
• other mortgage intermediaries and referrers you have agreed to;
• our staff and contractors, including our credit and support team overseas (section 9);
• technology providers, including CRM, document storage, e-signature and AI providers;
• your solicitor, conveyancer, accountant or financial adviser, with your consent;
• our auditors, compliance advisers, insurers and lawyers;
• the Australian Financial Complaints Authority (AFCA), if you make a complaint; and
• government agencies and regulators, such as ASIC, the OAIC and AUSTRAC, where required by law.

 

If we sell or transfer all or part of our business, including our client book, or a broker’s clients move to another licensee, your information may be transferred to the new owner or licensee. They must handle it in line with Australian privacy law.

 

9. Overseas disclosure

Some of our team and service providers are based outside Australia. Your information, including credit reports, may be accessed or stored in:

• the Philippines and Bangladesh, where members of our credit and support team work; and
• the United States and other countries where our technology providers, including our AI provider, host data.

 

Our overseas team members work under written agreements that require them to follow Australian privacy law and our security procedures. They access your file only through our secure systems. We take reasonable steps to make sure overseas recipients handle your information in line with the APPs, and we remain accountable for how they handle it.

 

10. Licensee oversight

As the holder of Australian Credit Licence 509559, we are responsible for how our team, contractors and technology providers handle your information. We regularly audit access to client files, the use of AI and the work of our offshore team. Any issue found is recorded, tracked and fixed, and our processes are updated where needed.

 

11. Storage, security and retention

We store your information in secure, access-controlled cloud systems. We use measures such as multi-factor authentication, encryption, role-based access and staff training.

We keep client records for 7 years, to meet our licensing and legal obligations. After that, we securely destroy or de-identify them.

 

12. Marketing

We may send you information about loan reviews, property finance and our services. You can opt out at any time by using the unsubscribe link or contacting us. Opting out will not affect any service we are currently providing.

We advertise on Facebook and Instagram and use cookies and similar technology on our website. Our Cookie and Online Advertising Notice explains how this works and how to opt out.

 

13. Access and correction

You can ask for access to the personal information we hold about you, or ask us to correct it. There is no fee to make a request. If a request takes significant effort to complete, we may charge a reasonable cost, and we will tell you before we start.

We will respond within 30 days. If we refuse a request, we will tell you why in writing and how to complain.

 

14. Data breaches

If we suspect a data breach, we will assess it promptly and within 30 days. If a breach is likely to cause you serious harm, we will notify you and the OAIC under the Notifiable Data Breaches scheme, and tell you what steps to take.

 

15. Complaints

If you are unhappy with how we have handled your information, please contact our Privacy Officer first (section 16). We will acknowledge your complaint within 1 business day where possible and aim to resolve it within 30 days.

If you are not satisfied with our response, you can contact:

Australian Financial Complaints Authority (AFCA) Phone: 1800 931 678 | Email: info@afca.org.au | Website: www.afca.org.au Mail: GPO Box 3, Melbourne VIC 3001

Office of the Australian Information Commissioner (OAIC) Phone: 1300 363 992 | Website: www.oaic.gov.au Mail: GPO Box 5288, Sydney NSW 2001

You can learn more about the Privacy Act and your rights at www.privacy.gov.au

 

16. Contact us

Privacy Officer: Adrian Bryers

Phone: 1300 761 197

Email: admin@sumplus.com.au

Mail: PO Box 187, Baulkham Hills NSW 1755

 

17. Changes to this policy

We review this policy regularly, including when we change how we use technology or AI. The latest version is always available at sumplus.com.au/privacy-policy.