Dated June 2017
1. Our Commitment to your privacy
We understand that your privacy is very important to you and that when you agree to us collecting, holding, using, and exchanging your personal information you are putting a lot of trust in us; and your trust is very important to us. That’s why we are committed to strictly protecting your privacy and being open and transparent about what we do with your personal information.
2. This policy
3. Collecting your information
In the course of our business we collect and hold information about our customers, including former and potential customers. This information is usually personal information.
We collect information about you and your interactions with us, for example if you visit our website and order goods or services through our portal. When you use our website we may collect information about your location or activity including IP address, and whether you have accessed third party sites. Some of this website information we collect using Cookies. The information we collect from you may include your identity and contact details, other personal details such as gender, marital status and employment information.
4. Using your information
We collect, use and exchange your information so that we can:
- establish your identity;
- manage our relationship with you;
- contact you;
- identify and tell you about other products or services that we think may be of interest to you;
- conduct, manage and improve our business;
- improve our customers’ experience with us;
- design, price and administer our products and services;
- manage our risks and help identify and investigate illegal activity, such as fraud; and
- comply with our legal obligations and assist government agencies or regulators.
We may also collect, use and exchange your information in other ways where permitted by law.
If you don’t want to receive direct marketing, you can tell us by calling us on 1300 884 933, emailing us at firstname.lastname@example.org , going to our website at www.thecollectiveadvantage.com.au click on the Contact Us tab and complete the email enquiry form, or write to us at Level 17, 175 Pitt Street, Sydney, NSW, 2000.
5. Exchanging your information
We may exchange (i.e. collect from and disclose to) your personal information with the following parties for the following purposes.
We may exchange your information with third parties where this is permitted by law or for any of the purposes mentioned in section 4 by using your information.
Third parties include:
- financial consultants, accountants, lawyers and advisers;
- persons acting on your behalf, for example guardians and persons holding power of attorney;
- any industry body, tribunal, or court;
- businesses assisting us with supplies and orders;
- any of our associates, related entities or contractors;
- any person considering acquiring an interest in our business or assets;
- any organisation providing verification of your identity;
- service providers;
- those to whom we may outsource certain functions, for example, accounting, postage, direct marketing, statement or invoice production, debt recovery and information technology support;
- claims-related providers who help us with claims;
- financial institutions, for example so that we can process payments or a claim for mistaken payment;
- auditors, insurers and re-insurers;
- government and law enforcement agencies or regulators;
- entities established to help identify illegal activities and prevent fraud; and
- any person where we are required by law to do so.
Sending Information Overseas
Occasionally we may send your information overseas, but only directly to our own offices or agents in an overseas location, and to service providers or other third parties who operate or hold data outside Australia. Where we do this, we make sure as far as reasonably possible that appropriate data handling and security arrangements are in place. Please note that Australian law may not apply to some of these entities.
We will take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. We will destroy or permanently de-identify personal information we no longer need or which we are no longer required by law to retain.
We have physical, electronic and procedural safeguards to protect your information which is held by us. Your information, both hard-copy and/or electronic records, are held at secure premises using trusted third parties.
Our office premises are protected against unauthorised access by electronic security passes which are held only by our staff, alarms and cameras. Access to information stored, including electronic records which require login and password authorisation, is restricted to our staff whose job purpose requires access. All our staff undertake information security and privacy training. We have firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing our systems.
7. Customer Rights
Wherever it is lawful and practicable, we will give you the option of not providing information when entering into transactions with us. However, in most cases, if you do not provide the full and complete information requested we will be unable to proceed with your transaction or assist you with your query or request for information.
8. Accessing, correcting and updating your information
You may ask us what personal information we hold about you, and you may make a request to access this information at any time.
You may make a request by calling us on 1300 884 933, emailing us at email@example.com , going to our website at www.thecollectiveadvantage.com.au click on the Contact Us tab and complete the email enquiry form, or write to us at Level 17, 175 Pitt Street, Sydney, NSW, 2000.
We will process your request within a reasonable time and try to make this information available within 30 days of your request. Before we give you the requested information we will need to confirm your identity.
There is no fee for making the request, but there may be an access charge to cover the time we spend locating, compiling and explaining the information you have requested. If there is an access charge, we will give you an estimate first and ask you to confirm that you would like us to proceed; if you would like us to proceed we do require payment up front (you may authorise to direct debit your account). Generally, the access charge is based on an hourly rate plus any other reasonable costs incurred by us such as photocopying and postage.
We do not need to provide access to your information in certain circumstances; for example, the information is commercially sensitive, the request is frivolous or would unreasonably interfere with another person’s privacy or be in breach of the law, or, where to provide access would pose a threat to health or public safety. If we refuse you access we will advise you of our reasons for doing so.
You may ask us at any time to correct the information we hold about you or that we have provided to others by calling us on 1300 884 933, emailing us at firstname.lastname@example.org, going to our website at www.thecollectiveadvantage.com.au click on the Contact Us tab and complete the email enquiry form, or write to us at Level 17, 175 Pitt Street, Sydney, NSW, 2000.
We will process your request within a reasonable time and try to correct the information within 30 days. If it looks like it will take longer, we will let you know the reason for the delay and try to agree to an extended timeframe with you.
If we are able to correct your information because it is indeed inaccurate we will inform you when it is so corrected.
If we disagree with you that the information is inaccurate and should be corrected, we will inform you in writing of our reasons. You may request that we attach a statement to that relevant information noting that you consider it is inaccurate, misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps to comply with such a request.
It is important that we have your correct information and details. You should keep us informed of any changes to your information and details.
You can check or update your information by calling us on 1300 884 933, emailing us at email@example.com, going to our website at www.thecollectiveadvantage.com.au click on the Contact Us tab and complete the email enquiry form, or write to us at Level 17, 175 Pitt Street, Sydney, NSW, 2000.
9. Complaints Resolution
We are committed to providing the highest quality of service and products to our customers. However, we are not perfect and if have you feel that we have not met your expectations we would like to hear from you so we can quickly remedy the problem. If you have a concern about your privacy, you have the right to make a complaint to us and we will do all that we can to promptly remedy the problem or address your concerns.
How to make a complaint
You may lodge a complaint by calling us on 1300 884 933, emailing us at firstname.lastname@example.org, or write to us at Level 17, 175 Pitt Street, Sydney, NSW, 2000.
We will acknowledge your complaint and do our utmost to review your concerns and resolve any issues or remedy any problems as promptly as possible.
How we handle your complaint
If we cannot resolve any issues or remedy any problems within 5 business days we will write to you and provide you with the name and contact details of the complaints handling officer who is investigating and dealing with your complaint. We will keep you updated on the progress of your matter and will provide you with a final written response within 45 days.
We are generally able to resolve complaints within a few days, however if we are unable to provide you with a response within 45 days, we will let you know the reason for the delay and try to agree to an extended timeframe with you.