1. About us
2. Your privacy is important to us
We protect your information & aim to be clear & open about what we do with it.
You do not have to provide us with your personal information. However, if you don’t do so it may affect our ability to assist you or provide you with a product or service. If you want to deal with us while not identifying yourself (i.e. anonymously or by using a pseudonym) we will allow you to do so where it is practical (for example, where you make a general enquiry of us). Please tell us if you wish to do this & we will indicate whether, given the nature of the transaction, it is practical.
3. What information do we collect, how & from where?
We collect personal information about you when you use our products or services, or deal with us. We may also collect personal information about you from other people & organisations.
|How your information may be collected & from where||Information we may collect|
Information that you (or others) share with Upkeep+, our group members, agent & distributors, service providers & external providers, such as information collected:
|Information automatically collected from your devices, such as:|
Where we collect sensitive information, we will generally not use it for any other purpose other than the purpose we collected it for. We will only use sensitive information for another purpose:
- where you would reasonably expect the information to be used in that way;
- if the purpose is directly related to the purpose we collected it for; or
- if you give us consent to do so.
4. How do we use your information?
We’re careful about how we collect, hold, use & disclose your personal information. We use it to deliver our products & services. We also use your personal information for other purposes, such as to better understand your needs, and to let you know about other products & services you may be interested in.
|Purpose for use of your information||How your information may be used by us|
|Serving you as a customer:|
|Enhance our products & services:|
|Facilitating our business operations:|
|Fraud, crime & misuse prevention:|
|Responding to regulatory requirements:|
|For marketing purposes:|
5. Who do we share your information with?
We may share your personal information with other members of the IAG Group (meaning Insurance Australia Group Limited & its related bodies corporate). We may also share your information with others for the reasons outlined in section 4.
We may disclose your personal information to the entities listed in the table below. They will only be authorised to use that information for the specific purposes outlined in section 4.
|Our group members, agents & distributors.|
Other than the vendors providing the services you have requested as described above & as otherwise described in this section, we do not share your personal information with unaffiliated third parties without aggregating, anonymising and/or de-identifying it first unless we obtain your prior consent.
Sending information overseas
Some of the entities listed above operate in countries outside of Australia, such as the United States, Singapore, New Zealand, South Africa, Philippines, Brazil & India. We may disclose your personal information to these parties located outside Australia. If we do this, we do all we can to ensure that there are arrangements in place to protect your personal information.
Upon sign-up, your identity & payment details are provided to the following external parties:
- Identity details are provided to the external identity & access management provider that we use, Amazon Cognito. Information about Cognito data usage, privacy & security can be found here: https://aws.amazon.com/privacy/
- Payment details are provided to the external payment processor that we use, Stripe Payments Australia Pty. Ltd. Information about Stripe data usage, privacy & security can be found here: https://stripe.com/au/ssa#section_d
- Contact management & email marketing are provided by Hubspot Inc. Information about Hubspot’s data usage, privacy & security can be found here: https://legal.hubspot.com/privacy-policy
6. Keeping your information safe
Our staff are trained in how to keep your personal information safe & secure. We use secure systems & buildings to hold your personal information. We aim to only keep your information as long as we need it.
We hold personal information electronically & may also hold information physically. We implement & maintain processes & security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
These processes & systems include:
The use of identity & access management technologies to control access to systems on which information is processed & stored;
Requiring all employees to comply with internal information security policies & keep information secure;
Requiring all employees to complete training about information security; and
Monitoring & regularly reviewing our practise against our own policies & against industry best practice.
We also require third parties to protect your information in accordance with our strict information security policies that align with generally accepted information security standards.
We store personal information for as long as necessary for us, our group members, service providers & related entities described above in section 5, to provide products & services to you & others, to comply with legal obligations, or to administer any product or service.
7. Accessing, updating & correcting your information
You can contact us & ask to view your personal information. For more detailed information, you may need to fill out a request form. If your information isn’t correct or needs updating, let us know straight away.
Can you see the information we have?
You can request access or correction of the personal information that we hold about you by contacting us (see section 10). So that we can provide access quickly & efficiently, we may ask you to complete a ‘Personal Information Access Request Form’ which can be located here.
Is there a fee?
There is no charge for requesting access to your personal information, but we may charge you a reasonable amount to cover matters such as retrieving, copying & sending out information in connection with an access request. There is no charge for correcting your personal information.
How long will it take?
We will respond to your requests to access or correct personal information in a reasonable time & will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date & complete.
Can we refuse to give you access?
There are some circumstances in which we are not required to give you access to your personal information. We’ll let you know if we are unable to give you access, if it is practical to do so.
Updating your information
It’s important that we have your correct details, such as your current home, email addresses & phone number. You can check or update your information by contacting us (see section 10).
8. Making a privacy complaint
If you have a concern or complaint about your privacy, let us know & we’ll try to fix it. If you’re not satisfied with how we handle your complaint, there are other things you can do.
How can you make a complaint?
If you have a complaint about our handling of your personal information, please contact us via email at firstname.lastname@example.org with details of your complaint.
How do we manage complaints?
- promptly acknowledge your complaint;
- determine if the complaint relates to a service provided by a service provider or other external party, in which case we will pass the complaint on to them & notify you;
- carefully investigate any complaint relating to services delivered by us (e.g. billing, subscriptions) & determine the steps that we will undertake to resolve your complaint;
- contact you if we require any further information & provide you with our determination once it is made; and
- if you are unhappy with our determination, provide you details on how to take your complaint further.
What else can you do?
If you remain unhappy with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) (in Australia) or the Privacy Commissioner (www.privacy.org.nz) (in New Zealand) for guidance on alternative courses of action which may be available.
9. Revision to this Policy
We’re here to help
If you need further information, want to update your personal information, have a privacy concern, or want to update your preferences – help is just a few clicks away.
- write to us at Upkeep+, Level 3, Tower 2, 201 Sussex Street, Sydney NSW 2000; or
- email us at email@example.com.