Privacy Policy

Settled Leads is a lead generation service. We connect people who enquire about a loan, an insurance policy, superannuation or business or asset finance with one licensed broker or adviser. Personal information is the core of what we handle, so this policy sets out exactly what we collect, why, who receives it and how you control it.

1. Who we are

Settled Leads is a business name of Hayden Clive Mitchell trading as Interlink AI, ABN 60 460 171 068, based in Victoria, Australia. In this policy, "we", "us" and "our" mean Settled Leads.

We also operate Your Quote Sorted (yourquotesorted.com), the consumer-facing website through which enquiries are submitted. That site has its own privacy policy covering consumer enquiries.

2. What this policy covers

This policy applies to settledleads.com, the Settled Leads broker portal, and our dealings with brokers, advisers and other business contacts. It also explains what happens to consumer enquiry data once it reaches us.

We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Where we send commercial electronic messages we also comply with the Spam Act 2003 (Cth), and telephone contact is subject to the Do Not Call Register Act 2006 (Cth).

We are not a lender, credit provider, insurer, aggregator, licensee or credit assistance provider. We do not give credit, financial, insurance or legal advice, and we do not assess anyone's creditworthiness.

3. What we collect

3.1 Brokers, advisers and business contacts

• Name, business name, email address, mobile number, state or region
• Lead volume requirements, the verticals you broker, and correspondence with us
• Portal account details, including login email and authentication records
• Records of leads delivered to you, purchases, invoices and payment status
• Licence, authorisation or accreditation numbers, such as an Australian Credit Licence, credit representative number or Australian Financial Services Licence, where you provide them

We do not collect or store your full card details. Card payments are processed by Stripe, which handles that information directly under its own terms.

3.2 Consumers who submit an enquiry

Where a person submits an enquiry through Your Quote Sorted or one of our advertising lead forms, we collect:

• Name, email address, mobile number, suburb and state
• The type of enquiry, the approximate amount, the purpose and the timeframe
• Consent record, including the exact consent wording shown, the date and time, the page used, and technical details such as IP address and browser

We do not knowingly collect enquiries from anyone under 18, and we do not collect sensitive information as defined in the Privacy Act, such as health, racial or ethnic origin, or political or religious information. Please do not send us that information.

3.3 Website and technical information

• IP address, browser type, device type, referring page and pages viewed
• Cookies and similar technologies, as described in our Cookie Policy
• Server logs and error reports used to keep the service running

4. How we collect it

We collect personal information directly from you wherever reasonably practical, through:

• Forms on settledleads.com and easyhomeloanquotes.com
• Lead forms on advertising platforms such as Meta (Facebook and Instagram), where you submit an enquiry without leaving the platform
• Email, phone and messaging correspondence with us
• Your use of the broker portal
• Automatically, through cookies and analytics, subject to the choices you make on our cookie banner

If you provide personal information about someone else, you must have their authority to do so.

5. Why we use it

We do not use personal information for automated decision-making that produces a legal or similarly significant effect on an individual. Allocating a lead to a broker is a routing step and does not assess or make any decision about the consumer.

6. Who we disclose it to

6.1 The assigned broker

A consumer enquiry is disclosed to one licensed broker or adviser. We do not sell the same enquiry to multiple brokers and we do not resell it later. Once disclosed, that broker becomes responsible for the personal information it holds and handles it under its own privacy policy. The broker must contact the consumer only about the enquiry they submitted, and must comply with its own obligations under the Privacy Act, the Spam Act and the Do Not Call Register Act.

6.2 Service providers

We use third party providers to run the service. They may access personal information only to perform their function for us.

6.3 Other disclosures

• Our professional advisers, such as accountants and lawyers, under confidentiality
• Where required or authorised by law, including to courts, regulators or law enforcement
• To a buyer or successor if we sell or restructure the business, subject to equivalent privacy protection

We do not sell, rent or trade personal information to data brokers, list sellers or marketing aggregators.

7. Overseas disclosure

Some of our providers store or process data outside Australia, principally in the United States and the European Union. This includes the hosting, database, email, analytics and advertising providers listed above.

Before disclosing personal information overseas we take steps that are reasonable in the circumstances to ensure the recipient handles it consistently with the Australian Privacy Principles, including relying on the provider's contractual data protection commitments. By using our services you acknowledge that information may be handled overseas on this basis.

8. Direct marketing and opting out

We may send brokers and business contacts marketing about our lead supply services where you have consented or would reasonably expect it. Every marketing message includes a working unsubscribe, and we honour opt outs promptly.

Consumers who submit an enquiry are contacted about that enquiry by the assigned broker and by us in connection with it. We do not add consumer enquiries to unrelated marketing lists, and we do not pass them to any party other than the assigned broker.

To opt out, use the unsubscribe link in any message or email hayden@interlinkai.io. You may also ask us not to disclose your information for direct marketing purposes, and ask us to tell you the source of information we hold about you.

9. Cookies and tracking

We use cookies and similar technologies. Non-essential cookies, including advertising and analytics, stay switched off until you accept them on our cookie banner, and you can change your choice at any time. See the Cookie Policy for detail.

10. Security and retention

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These include encryption in transit, access controls and role-based permissions, secrets held server-side only, row level security on our database, and monitoring and error tracking.

No system is completely secure, and we cannot guarantee the absolute security of information transmitted to us.

We keep personal information only as long as we need it for the purposes above or to meet legal and record keeping obligations, generally up to seven years for transaction and consent records. When it is no longer needed we destroy or de-identify it.

11. Data breaches

We maintain a data breach response plan. If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

12. Access and correction

You can ask us for a copy of the personal information we hold about you, and ask us to correct anything inaccurate, out of date or incomplete. Email hayden@interlinkai.io.

We will need to verify your identity. We normally respond within 30 days and do not charge for a request, although we may charge a reasonable cost for supplying information in an unusual format. If we refuse access or correction we will tell you why in writing and how to complain.

You can also ask us to delete information we hold about you. We will do so unless we are required to keep it by law or need it to resolve a dispute. Once an enquiry has been passed to a broker, you will also need to contact that broker directly about the information they hold.

13. Complaints

If you think we have breached the Australian Privacy Principles, email hayden@interlinkai.io with the details. We will acknowledge within 5 business days and respond within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner:

• Web: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

14. Changes to this policy

We may update this policy as our services or the law change. The current version is always available at settledleads.com/privacy, with the version number and date at the top. Material changes affecting how we handle your information will be notified to active brokers by email.