Brightside Cover is committed to protecting your privacy in accordance with the Privacy Act 1998 (Cth) and the Australian Privacy Principles or, if you are in New Zealand, the New Zealand Privacy Act 1993 and the Information Privacy Principles.

In Australia, for the purpose of this Privacy Policy ‘Our’, ‘Us’ and ‘We’ refers to ICF Protection Plus Pty Ltd ABN 27 139 212 972 trading as Brightside Cover, of Suite 1, Building B, 34-46 Brookhollow Ave Baulkham Hills, NSW 2153, Australia. In New Zealand, ‘Our’, ‘Us’ and ‘We’ refers to Product Care Administration Services (NZ) Ltd NZB 9429031182737 trading as Brightside Cover, of 1/527B Rosebank Road, Avondale, Auckland, New Zealand 1026.

This Privacy Policy describes our current policies and practices in relation to the collection, use, disclosure and handling of personal information. It also deals with how you can complain about a breach of the privacy laws and how you can access the personal information we hold and how to have that information corrected.

It applies to any personal information you provide to Us and any personal information we collect, use, disclose or handle about individuals from other sources.

Why we collect personal information

In Australia personal information is information or opinion about an individual whose identity is apparent or can easily be ascertained from the information or opinion. In New Zealand personal information is information or opinion about an identifiable individual.

We collect personal information to offer, provide, arrange, manage and administer the many financial services and products we and our group of companies are involved in. These include insurance broking and claims management, risk management consulting, other forms of insurance services (including underwriting of insurance products and reinsurance), employee benefits, superannuation and investment advisory services.

If you would like more information on the services and products available please contact us.

We also collect personal information to be able to develop and identify products and services that may interest you, to conduct market or customer satisfaction research, to develop, establish and administer alliances and other arrangements with other organisations in relation to the promotion, administration and use of our respective products and services. We give you the option of electing not to receive these communications in the future. You can unsubscribe by notifying us and we will no longer send this information to you.

The usual type of personal information collected includes your name, postal or e-mail address, date of birth, financial details etc. We may also need to collect sensitive information about you in relation to life, general and workers compensation insurance, information about your membership of professional or trade associations, health information, sexual preferences and criminal record.

If you do not provide the information requested, we or those involved with the provision of the service or product, may not be able to provide the appropriate type or level of service or product.

How we collect personal information

We generally collect personal information directly from the relevant individual but in some cases we may collect it indirectly from a third party.

For example, an insured’s representative may tell us about other persons wanting the benefit of our service or the relevant product such as a nominated driver, a director or officer or professional or other staff member. Alternatively, we may collect through our own representatives, advisers or another third party, such as loss adjusters, lawyers, insurers health care workers, publicly available sources or witnesses to a claim etc.

Who we disclose personal information to

We do not sell, trade, or rent your personal information to others.

We have a duty to maintain the confidentiality of our clients’ affairs, including personal information. Our duty of confidentiality applies except where disclosure of personal information is with our client’s consent or compelled by law.

We may disclose personal information to third parties who we believe are necessary to assist us in providing, managing and administering the services we provide and products we are involved in.

For example:

• our related companies and alliance partners who may wish to tell you about their services, products or promotional opportunities which may be of advantage to you, unless you tell us not to
• your representatives such as your lawyers, accountants, financial advisers etc for banking and finance products – card producers, card schemes, credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers
• for financial planning and investment products and trustee or custodial services -superannuation and managed funds organisations and their advisers and organisations in which you invest
• for insurance broking and life and general insurance products – insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, medical service providers, fraud detection agencies, our advisers such as loss adjusters, lawyers and accountants, and others involved in the claims handling process
• Your personal information may also be used in connection with such purposes

Transfer of information overseas

We may transfer your personal information overseas where it is necessary for the purposes described above. For example, some insurers like Lloyd’s of London, are based overseas and we need to provide your personal information to them or an overseas broker to arrange your cover.

If you are located in Australia, we will tell you at time of advising on your insurance if they are overseas and in which country the insurer and intermediary is located. If they are not regulated by laws which protect your information in a way that is similar to the Privacy Act 1988 (Cth), we will seek your consent before disclosing your information to them.

New Zealand, Australian and overseas insurers acquire reinsurance from reinsurance companies that are located throughout the world, so in some cases your information may be disclosed to them for assessment of risks and in order to provide reinsurance to your insurer. We do not make this disclosure, as this will be made by the insurer (if necessary) for the placement for their reinsurance program

What we expect of you

We can only fully advise you and assist in arranging your insurance or claim, if we have all relevant information. The insurance laws require you to provide your insurers with the information they need in order to be able to decide whether to insure you and on what terms.

In Australia, you have a duty to disclose the information which is relevant to the insurer’s decision to insure you (In New Zealand, the duty is to disclose the information which a prudent insurer would wish to take into account in deciding whether to insure you and on what terms).

When you provide us with personal information about other individuals, we rely on you to have made or make them aware that you will or may provide their information to us, the types of third parties we may provide it to, the relevant purposes we and the third parties we disclose it to will use it for, and how they can access it (as described in this document). If it is sensitive information we rely on you to have obtained consent to the above. If you have not done either of these things, you must tell us before you provide the relevant information.

If you collect, use, disclose or handle personal information on our behalf, or receive it from us, you and your representatives must meet the relevant requirements of the Australian Privacy Principles set out in the Privacy Act 1988 or the requirements of the New Zealand Information Privacy Principles set out in the Privacy Act 1993 (as applicable) and only use and disclose it for the purposes we agreed to.

Security of your personal information

Your personal information may be stored in hard copy documents, as electronic data, or in our software or systems. We endeavour to protect any personal information that we hold from misuse and loss, and to protect it from unauthorised access, modification and disclosure.

Some of the ways we achieve this are:

• confidentiality requirements on our employees
• policies on document storage security
• security measures for access to our systems
• only providing access once proper identification has been given
• controlling access to our premises
• website protection measures

We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

Keeping information up to date and accessing it

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect, disclose or use it. You can also gain access to correct or update your personal information.

We do not charge for receiving a request for access to personal information or for complying with a correction request. Where the information requested is not a straightforward issue and will involve a considerable amount of time, then a charge will need to be confirmed for responding to the request for the information.

In some limited cases, we may need to refuse access to your information, or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.

Contact Us to request an update to your personal information.

Opting out of receiving marketing information etc

If we send you any information about services or products, or you do not want us to disclose your personal information to any other organisation (including related bodies corporate) you can opt out by contacting Us.

Dealing with us anonymously

Where lawful and practicable to do so you can deal with us anonymously e.g. general inquiries about the services we can offer you.

Your consent

By asking us to assist with your insurance needs, you consent to the collection and use of the information you have provided to us for the purposes described above.

How to contact us

If you wish to gain access to your personal information, make a complaint about a breach of your privacy or you have any query on how your personal information is collected or used, or any other matter relating to our Privacy Policy you can:

• speak directly with our staff who will make every effort to try to resolve your issue as quickly as possible
• you can contact us online so the matter can be considered by our Privacy Officer
• we will respond to you as soon as reasonably possible

For more information on Australian privacy see the Australian Information Commissioner’s website www.privacy.gov.au

For more information on New Zealand privacy see the Office of the Privacy Commissioner’s website www.privacy.org.nz

Website information and content

The information provided on this website does not cover all aspects of the law on the relevant subject matter. Professional advice should be sought before any action is taken based upon the matters described and discussed on this site.

To the extent permitted by law, we make no representations about the suitability of the content of this site for any purpose. All content is provided without any warranty of any kind. We disclaim all warranties and conditions with regard to the content, including but not limited to all implied warranties and conditions of fitness for a particular purpose, title and non-infringement.

We will not be liable for any damages or injury caused by, including but not limited to, any failure of performance, error, omission, interruption, defect, delay in operation of transmission, computer virus, or line failure. To the extent permitted by law we will not be liable for any damages or injury, including but not limited to, special or consequential damages that result from the use of, or the inability to use, the materials in this site.

We believe the content of this site to be accurate, complete and current; however there are no warranties as to the accuracy, completeness or currency of the content. It is your responsibility to verify any information before relying on it. The content of this site may include technical inaccuracies or typographical errors.

We reserve the right to modify the content of this site from time to time.

Anonymous data

We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services.

Cookies

In order to collect this anonymous data we may use “cookies”. Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. Once you leave the site, the cookie is destroyed and no personal or other information about you is stored.

Forms

Our Website allows visitors to submit information via Self-Service forms (Claim Forms, Employment and Contact request). The information submitted via the Forms is not encrypted – an option is available for claim forms to be downloaded in PDF format for faxing. Should you be concerned about confidentiality of the claim information, this would be the recommended method.

Information collected via on-line forms is sent to our offices via EMAIL (not encrypted) and is also stored on a database which is accessible by relevant staff only (password protected).

We also use your information to send you requested product information and promotional material and to enable us to manage your ongoing requirements, e.g. renewals, and our relationship with you, e.g. invoicing, client surveys etc.

We may occasionally notify you via direct marketing about new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post on insurance matters. If you would rather not receive this information or do not wish to receive it electronically, email or write to us.

We may use your information internally to help us improve our services and help resolve any problems.

Tell us what you think

We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact Us.