Privacy Policy
Esteb and Co Pty Ltd (ACN 681 636 056) trading as Esteb & Co is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy explains what personal information we collect, why we collect it, how we use and disclose it, and the rights you have over it.
1. Who we are
- Trading name: Esteb & Co
- Legal entity: Esteb and Co Pty Ltd (ACN 681 636 056)
- Credit Representative: Esteb and Co Pty Ltd, ASIC Credit Representative #574070
- Authorised broker: Richard Esteb, ASIC Credit Representative #574071
- Australian Credit Licensee: Australian Finance Group Ltd (AFG), ACL #389087
- Privacy contact: Richard Esteb · r@estebandco.com · +61 424 406 977
2. What we collect
Information you give us through a calculator
- Income figures (base salary, bonus, rental, other), employment type, dependants, household structure
- Existing liabilities (credit card limits, personal loans, car loans, HECS, BNPL)
- Property details (purpose, postcode, expected rent for investments)
- Loan term and household living expenses
Information you give us when requesting a report
- Name, email address, mobile number (optional)
- Whether you've indicated you're ready to speak with a broker
Information collected automatically
- Technical data: IP address, browser/user-agent string, device type
- Page interaction: which questions you answered, time on each step, abandonment points
- Marketing attribution: UTM parameters, Google Click ID (gclid), Facebook Click ID (fbclid), referring URL
Information collected later in the process (only if you proceed with a loan)
- Identity documents (driver licence, passport) for AFG/lender ID verification
- Income and asset evidence (payslips, BAS, bank statements, tax returns)
- Credit history (with your consent, via the lender's credit enquiry)
- Property and contract documents
3. Why we collect it
We collect personal information for the following purposes:
- To run the calculator and show your panel result — figures are processed by our borrowing-capacity engine against each lender's published policy.
- To respond to your request for a personalised report, follow up by email or phone, and arrange a meeting if you've asked to speak with a broker.
- To prepare and lodge a credit application with a lender on your behalf, if you decide to proceed.
- To meet our regulatory obligations — file notes, the Credit Quote and Credit Proposal disclosure, AML/CTF identification, ASIC and AFG audit requirements, and 7-year record retention under the National Consumer Credit Protection Act.
- To improve the calculators — we look at aggregated funnel analytics (which questions cause drop-off, how long the wizard takes) so we can make the tool better.
4. Who we share it with
We disclose your personal information to the following categories of third parties, only for the purposes above:
| Recipient | What is shared | Why |
|---|---|---|
| Australian Finance Group Ltd (AFG) — our aggregator and Australian Credit Licensee | Full file: contact details, financial position, ID, application data | AFG is the licensee under which Richard Esteb is authorised to provide credit assistance. Lodgement, compliance and audit run through AFG's systems. |
| The lender you choose to apply with | Application data, ID, income/asset evidence, credit-enquiry consent | To assess and process your loan application. We only send your file to a lender after you've signed the Credit Proposal authorising it. |
| Mailgun (Sinch Australia / Mailgun Technologies, US) | Email address, name, message content | Sends transactional and broker emails on our behalf. Mailgun does not use your data for its own purposes. |
| Google (Google LLC, US) — Analytics 4 and Ads | De-identified usage events; hashed email if you submit (advanced matching) | Measures site performance and ad attribution. We do not upload financial figures to Google. |
| Meta Platforms, Inc. (US) — Facebook Pixel and Conversions API | Hashed email, hashed phone, hashed name, country, event metadata | Measures ad attribution. Identifying fields are SHA-256 hashed before transmission. |
| Hostinger (Lithuania / Singapore) | Server-side data and DNS | Hosts our infrastructure. Data on the server is encrypted at rest where supported. |
| Service providers we engage to settle your loan | Application-relevant data only | For example: valuers, conveyancers, settlement agents — only when a transaction reaches that stage. |
| Government and regulators | As required by law | ASIC, AUSTRAC, the Australian Taxation Office, courts, and law-enforcement agencies — only when legally compelled. |
We do not sell your personal information to anyone.
5. Overseas disclosure
Some of the providers above (Mailgun, Google, Meta) store and process data outside Australia, primarily in the United States and the European Union. Where personal information is disclosed overseas we take reasonable steps, consistent with APP 8, to ensure the recipient handles it consistently with the Australian Privacy Principles. By submitting information through a calculator or contact form you consent to that overseas disclosure.
6. Cookies and analytics
Our site uses cookies and similar technologies for three things:
- Functionality — remembering your progress through a calculator wizard so you don't lose answers if you reload.
- Analytics — Google Analytics 4 (anonymised IP, no demographic targeting).
- Advertising attribution — Google Ads conversion tag, Facebook Pixel. Both fire only after you've submitted your details, and identifying fields are hashed.
You can disable cookies in your browser. Disabling functional cookies may break the calculator wizards. Disabling analytics or advertising cookies has no effect on the calculator output you see.
7. Direct marketing
If you submit your details through a calculator we may send you:
- An immediate report email summarising the panel result you saw on screen.
- Follow-up emails relevant to your scenario (for example: rate movements, lender policy changes, content tied to your loan type).
Every marketing email contains a one-click unsubscribe link and we honour unsubscribe requests immediately. You can also reply STOP to any email or text us at +61 424 406 977 and we'll remove you from follow-up. Transactional and regulatory communications (for example: a Credit Proposal you've signed) are sent regardless of marketing preference.
8. Storage and security
Personal information is stored on a server we operate in Australia, plus the third-party platforms listed in §4. Reasonable steps we take to protect it:
- HTTPS for all browser-to-server traffic
- SSH key authentication for server administration; root login disabled by password
- Encryption-at-rest where supported by the underlying storage
- Database access restricted to least-privileged application users
- Daily database backups retained for 14 days
- API keys and credentials kept outside the public web root
No system is bulletproof. If we ever experience a notifiable data breach affecting your information we will notify you and the Office of the Australian Information Commissioner (OAIC) consistently with our obligations under Part IIIC of the Privacy Act.
9. How long we keep it
- Calculator submissions without contact details: up to 12 months for funnel analysis, then deleted.
- Lead records (with email): kept for 24 months from last interaction unless you've engaged us as your broker.
- Active client files: retained for the life of the loan and then for 7 years after the file closes, as required under the National Consumer Credit Protection Act and AFG's record-keeping policy.
10. Your rights — access, correction, complaints
You can ask us, at any time, to:
- Tell you what personal information we hold about you (APP 12)
- Correct any of it that's wrong, incomplete or out of date (APP 13)
- Delete your record (where we're not legally required to retain it)
- Stop sending marketing emails
Email r@estebandco.com with the subject line "Privacy request" and we'll acknowledge within 7 days and respond substantively within 30 days.
If you're not satisfied with our response, you can complain to:
- Office of the Australian Information Commissioner (OAIC) — oaic.gov.au/privacy/privacy-complaints · 1300 363 992
- Australian Financial Complaints Authority (AFCA) — afca.org.au · 1800 931 678. Esteb & Co is covered under AFG's AFCA membership (#10532).
11. Changes to this policy
We may update this policy from time to time — for example, to reflect changes in the providers we use or in the law. The "last updated" date at the top of the page reflects the most recent revision. Material changes will also be notified to active clients by email.
12. Contact
For privacy questions, access requests, or to correct your details:
- Email: r@estebandco.com
- Phone: +61 424 406 977
- Post: Richard Esteb, Esteb and Co Pty Ltd, Gold Coast QLD