Assurant Services Australia Ltd - Privacy Notice

This Privacy Notice describes how Assurant Services Australia Pty Ltd ABN 18 613 632 367 (a company incorporated in Australia) referred to as “Assurant”, “We”, “Us”, “Our” throughout this Policy, collects, holds, uses and discloses personal information in compliance with and pursuant to the Privacy Act 1988 (Cth) (the “Act”), the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (the “Act”) and the Australian Privacy Principles. Assurant is part of Assurant, Inc (NYSE AIZ), a global provider of risk management solutions.

Assurant respects your concerns about privacy. Assurant is providing the Enterprise and Government Device Trade-In Website (the “Service”) to serve Our Telstra enterprise and Government customers. In order to provide this Service, Assurant collects and processes your personal information as set forth in this Privacy Notice (“Notice”) and pursuant to applicable privacy legislation.

We manage your personal information in an open and transparent manner and employ safeguards designed to protect your information, including to:

  1. Comply with the Australian Privacy Principles (APPs);
  2. Ensure that we manage your personal information transparently;
  3. Collect only the personal information reasonably necessary to provide the Service to you;
  4. Tell you how we use your personal information;
  5. Let you know if we disclose your personal information to anyone else (including anyone overseas) and if so, under what circumstances this may happen;
  6. Employ safeguards designed to protect your personal information;
  7. Respond to any request received from you regarding marketing communications;
  8. Make sure your personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by us;
  9. Ensure that, where appropriate, you may access and correct your personal information that is held by us in the context of the Service.

This Notice describes how We collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use the Service, and how We comply with the Act and the APPs.

You must read this Notice before providing Us with any personal information or using the Service. By providing Us with your personal information and using the Service, you are confirming your agreement to this Notice.

This Privacy Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided associated with each.

If you have any concern about providing information to Us or your information being used in any manner permitted by this Privacy Notice, you should not visit Our Web Portal or otherwise use the Service.

1. What information We collect

We collect your personal information in the following ways:

1.1 When you use our Service

When you use the Service; so that We can administer the Service, We ask users to provide Us with their: (i) first name and surname and (ii) contact details, including email address, and phone number.

1.2 When you communicate with Us

When you contact Us through the Service. We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).

You may report any problems or security concerns with the Service by contacting customer support by e-mail at Enterprise.Tradein@assurant.com.

The customer support centres are located within Australia and are operated by Us.

2. We process your personal information for the following purposes

We collect and process your personal information to provide the Service to you and to contact you in relation to the provision of the Service, including.

  1. Providing the Service to you;
  2. Verifying your identity;
  3. Managing your account;
  4. Preventing fraud and other criminal activities;
  5. To assist us in operating our business and to improve our services and performance, including staff training, risk management, recordkeeping, developing and enhancing the Service;
  6. Recognizing you on the Service, improving your experience, increasing security of our networks and systems, and measuring use and effectiveness of our Service;
  7. Communicating with you and customizing our support responses;
  8. Conducting market research and customer surveys;
  9. Investigating complaints received from you and others about the Service, or our products and services and tracking potential issues and trends to better serve you;
  10. Making decisions about, and implementing, reorganizations or sales of all or part of our business;
  11. Where you give us consent;
  12. To protect your safety or the safety of others, investigate fraud, or respond to a government request;
  13. To comply with our legal obligations.

2.1 Withdrawing consent

Wherever We rely on your consent, you can always withdraw your consent at any time with effect for the future by contacting customer support by e-mail: enterprise.services@assurant.com.

2.2 Automated decision making

We do not use automatic decision making or profiling.

3. How We share your personal information

3.1 Sharing personal information with other recipients

We may disclose your personal information to public authorities if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.

We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to lawyers and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.

4. Your Choices and Rights

4.1 Your choices and rights

You have the following rights with regard to the data processed by Us:

  1. the right of access to your personal data stored by us in accordance with APP 12; and
  2. the right to rectify incorrect or complete correct personal data stored by us in accordance with APP 13.

4.2 Additional information

You can exercise any of your rights by contacting Us through the customer support centre at 1300 013 300 or by e-mail at Enterprise.Tradein@assurant.com

You can also send Us your request by writing to Us at the address provided in the “Contact Us” section of this Notice. In order to safeguard your personal information from unauthorised access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

In certain situations and subject to applicable laws, including data protection laws, We may not be able or obliged to comply with all or part of your request. For example, We may not comply with an access request if doing so would reveal personal data about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping.

If you have unresolved concerns, you have the right to complain to an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) to have your concerns heard and assessed.

5. Data Retention

We retain personal information you provide while your service contract is active or as needed to provide the Service, and up to 15 years in accordance with applicable law. We may retain your personal information if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Privacy Notice. We may retain personal information, for a limited period of time, if requested by law enforcement.

6. Important Information

6.1 Minimum age

We do not knowingly collect personal information from anyone under the age of 18 or such equivalent minimum age for consenting to data processing in the relevant jurisdiction. You must be at least 18 years of age (or ensure a person of 18 years of age or older is present for the duration of a service), or the equivalent minimum age in the relevant jurisdiction, to use the Service.

6.2 Changes to this Privacy Notice

We may update this Privacy Notice from time to time. If We make any material changes to this Privacy Notice, We will notify you via the relevant website, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. As We may make changes to this Privacy Notice, We suggest that you review it each time you access and use the Service. Please review changes carefully. If any changes are made to this Privacy Notice, We will revise the Effective Date that is indicated on the Privacy Notice.

6.3 Security Procedures

We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.

6.4 Contact Us

If you have questions or comments about this Privacy Notice, please contact Us online or by postal mail.

We welcome your questions or comments regarding this Notice. Please send enquiries to Data Protection Officer, Assurant Services Australia Pty Ltd, Level 4, Deutsche Bank Place, 126 Phillip Street Sydney 2000 NSW, or send Us an email at dataprotectionofficer.apac@assurant.com.

You also have the right to file a complaint directly with the Office of the Australian Information Commissioner under applicable local data protection law. You may make a complaint with the OAIC.

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