X-TOOLS Privacy Policy

Our privacy policy was last updated on July 1, 2026.

1. Introduction

This document sets out the privacy policy of Ethicare Financial Services Pty Ltd (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’).

We are committed to protecting your privacy and handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

We take our privacy obligations seriously and we've created this privacy policy to explain how we store, maintain, use and disclose personal information. By providing personal information to us, you consent to our storage, maintenance, use and disclosure of personal information in accordance with this privacy policy.

We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy. Your use of the X-TOOLS platform is also governed by our Terms of Use available on our website at ethicarefs.com.

2. Type of Personal Information We Collect

The personal information we collect may include the following:

  • name;
  • mailing or street address;
  • email address;
  • telephone number and other contact details;
  • age;
  • date of birth;
  • credit card or other payment information;
  • information about your business or personal circumstances;
  • client fact find information, income and expense information, asset and liability information, property ownership information, funding position information, lending scenario information, application notes, compliance documentation, financial objectives, and other personal, business or financial information voluntarily entered into the X-TOOLS platform.
  • information in connection with client surveys, questionnaires and promotions;
  • your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
  • information about third parties; and
  • any other information provided by you to us via our website or our online presence or otherwise required by us or provided by you.

3. How we collect personal information.

We may collect personal information either directly from you, or from third parties, including where you:

  • contact us through our website;
  • receive goods or services from us;
  • submit any of our online sign-up forms;
  • communicate with us via email, telephone, SMS, social applications (such as LinkedIn) or otherwise;
  • interact with our website, services, content and advertising; and
  • invest in our business or enquire as to a potential purchase in our business.

We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, “cookies or other similar tracking technologies” that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.

We may use Google Analytics to collect and process data, including when you use third party websites or apps. To find out more see How Google uses data when you use our partners' sites or apps.

4. How We Use Your Personal Information

We collect and use personal information for the following purposes:

  • to provide goods, services or information to you;
  • for record keeping and administrative purposes;
  • to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing goods or services to you;
  • to improve and optimise our service offering and customer experience;
  • to provide, operate, improve and personalise the X‑TOOLS platform, including generating funding position reports, lending scenario analysis, application notes, comparison reports, compliance documentation and other workflow outputs requested by you.
  • to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
  • to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
  • to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
  • to consider an application of employment from you.

We may use de‑identified and aggregated information for analytics, system improvement, product development and machine learning purposes.

Any information used for analytics, product improvement or machine learning purposes will be de-identified and aggregated wherever reasonably practicable and will not be used to identify individual users.

We retain personal information only for as long as reasonably necessary for business, legal and regulatory purposes.

Where required by law, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) of eligible data breaches.

We may disclose your personal information to cloud providers, contractors and other third parties located inside or outside Australia. Our service providers may be located in Australia, New Zealand, Singapore, the United States or other jurisdictions where our technology providers operate. If we do so, we will take reasonable steps to ensure that any overseas recipient deals with such personal information in a manner consistent with how we deal with it.

5. Security.

We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.

6. Links.

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites, and we suggest you review the privacy policies of those websites before using them.

7. Requesting access or correcting your personal information.

If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.

If you think that any personal information, we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.

8. Complaints.

If you wish to complain about how we handle your personal information held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable timeframe.

9. Contact us.

For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Website: www.ethicarefs.com

Email: hello@ethicarefs.com