Respecting your privacy
Central to the success of Spotter Life is our commitment to our clients.
We honour without reservation our obligation to respect and protect the privacy of the personal information of individuals with whom we deal.
THE INFORMATION WE COLLECT AND HOLD
Whenever it is reasonable and practical to do so, we collect information about you directly from you. In some cases, we collect personal information from third parties including public sources, our related companies, referrers, brokers, agents, your adviser(s) and our service providers including credit reporting bodies and information service providers.
As we offer services ranging from Life Insurance to Income Protection, it is important that you understand your rights and our obligations with respect to our core offerings and the requirements we adhere to under each service we offer.
INSURANCE PRODUCT APPLICATION
We collect personal information about you which is reasonably necessary to:
- provide you with quality products or services
- consider applications and approaches you make to us
- maintain your contact details
We generally hold personal information relating to:
- the products and services we provide or have provided to you
- your financial interests and sometimes your financial position, if you are a customer or potential customer of ours
- your name, contact details and identification information (including government-issued tax numbers)
- records of our interactions with you, including by telephone, email and online
- your enquiries or complaints.
We only collect sensitive information about you where required by applicable laws or rules. Sensitive information includes information relating to:
- political or religious beliefs
- sexual preferences
- criminal convictions
- membership of professional or trade associations or unions
- health information.
We collect health information where we offer products with an insurance component to our clients. We do not use or share that information for any purpose other than the underwriting or administration of a client’s policy or account, or as otherwise disclosed to the customer when the information was collected.
We may collect information about your affiliation with certain organisations such as professional associations. We also collect personal information from people who submit applications or register interest with Spotter Finance Pty Ltd.
HOW THIS INFORMATION MAY BE USED
We only use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would be reasonably expected without your permission. For example, we may use and disclose personal information to process applications, administer and manage our products and services including monitoring, auditing, and evaluating those products and services, model and test data, communicate with you and deal with any complaints or enquiries.
We may also use and disclose your personal information (on a confidential basis) in connection with acquisitions, mergers or changes in control of our business or assets.
We may from time to time also use your personal information to provide information about products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this. We do not sell personal information to other organisations to allow them to do this.
We may share personal information inside Spotter Finance Pty Ltd and may disclose personal information outside Spotter Finance Pty Ltd:
- as required by relevant laws or rules, such as those relating to the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006
- to service providers who provide services including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, trustee, securitisation, website and technology services.
In some circumstances the parties with whom we share personal information may operate outside of Australia. Where this occurs, we take steps to protect personal information against misuse or loss.
HOW DO YOU ACCESS YOUR PERSONAL INFORMATION?
How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone.
We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
- we believe there is a threat to life or public safety;
- there is an unreasonable impact on other individuals;
- the request is frivolous;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- it would be unlawful;
- it would jeopardise taking action against serious misconduct by you;
- it would be likely to harm the activities of an enforcement body (e.g. the police); or
- it would harm the confidentiality of our commercial information.
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
KEEPING INFORMATION ACCURATE AND UP TO DATE
We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
KEEPING INFORMATION SECURE
We use security procedures and technology to protect the information we hold. Access to and use of personal information within Spotter Finance Pty Ltd seeks to prevent misuse or unlawful disclosure of the information. If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
HOW YOU CAN ACCESS OR CORRECT YOUR INFORMATION
You can contact us as set out below to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
WHAT ADDITIONAL THINGS DO WE HAVE TO DO TO MANAGE YOUR COMPLAINTS ABOUT INFORMATION?
If your complaint relates to how we handled your access and correction requests
You may take your complaint directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.
For all other complaints relating to information
If you make a complaint about things (other than an access request or correction request) in relation to your information, we will let you know how we will deal with it within seven days.
Ask for more time if we can’t fix things in 30 days
If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
DEALING WITH SPOTTER FINANCE ONLINE
If you are an anonymous visitor, the information we collect is not capable of personally identifying you.
Once you have accessed our websites from an e-mail or other personalised communication sent to you or provided us with personal information by completing a form online, we may be able to identify you. If we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our websites, irrespective of how you access our sites (e.g. by clicking a link in an advertisement or from a third party website). In addition we may combine that information about your use of our websites with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information. If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).
A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies are generally used on Spotter Finance’s websites to:
- manage advertising – we use advertising companies to deliver our online advertising. When you see one of our ads on a third party website, cookies are sometimes used to collect anonymous information about what pages you visit and the type of software you are using
- monitor traffic – we use tracking companies to gather anonymous information about how people are using our websites, this information includes time of visit, pages visited, and some system information about the type of computer you are using. We use this information to enhance the content and services offered on the site
- collect identifiable information about your use of our websites – if we have identified you as a result of you accessing our website from an e-mail or other personalised communication sent to you or providing us with personal information by completing a form online.
CONTACT US / HOW DO YOU MAKE A COMPLAINT?
We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
Alternatively, if you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can contact us by using the details below:
- Phone: 03 8568 6000
- Email: email@example.com
- Fax: (03) 8672 3561 or 03 8677 6591
- Mail: PO BOX 11, Heidelberg 3084 VIC
We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.
If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner: