This Privacy Policy applies to the operations of Trade Credit Collections Pty. Limited ABN 82 635 605 (“we” or “us”) and explains how we manage your personal information. We are committed to safeguarding your privacy and the confidentiality of your personal information, protecting personal information from misuse or unauthorised disclosure and complying with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles set out in the Act.
Personal information we collect
Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not, and
- whether the information or opinion is recorded in a material form or not.
Types of personal information we generally collect may include:
- Names, addresses, dates of birth, email address, phone number and other contact details
- Employment and/or business history
- Financial records including, where applicable, balance sheets, Profit & Loss Statements, assets, income and financial history
- Information that you submit when you are using our online services or via email, including debt recovery information and payment information, and
- Solvency status and/or personal bankruptcy.
In most cases, we will collect personal information directly from you or from the people or organisations to whom we disclose information as listed below. Where we collect sensitive information, such as health information, we will obtain your consent, unless we’re required or permitted by law to collect it without consent.
Dealing with us anonymously
If requested, there are limited circumstances where you may be able to deal with us anonymously or by using a pseudonym. An example is where you are seeking only general information about one of our products or services. In most cases it will not be reasonably possible for you to deal with us in this way.
What we do with personal information
We collect, hold, use and disclose personal information in ways people would reasonably expect and where it’s reasonably necessary for our business, including:
- To assist our clients in the recovery of debts
- To process claims payments on behalf of our clients
- To determine the financial circumstances of debtors
- To make contact with debtors in relation to debt recovery action
- To our authorised agents to assist in debt recovery, and
- For other related matters and those required or authorised by law.
Disclosing personal information
We, or our authorised agent(s), may disclose your personal information to:
- any person authorised by you
- our related bodies corporate including QBE’s services company located in the Philippines (which provides accounting and administration services to us in Australia)
- a mail house, records management company or technology services provider (for printing and/or delivery of mail and email, including secure storage and management of our records)
- credit reporting agencies for the purpose of searching for credit-related information on debtors
- auditors, solicitors and other professional consultants
- our third parties such as suppliers, financial verification and security service providers, process servers and contractors
- trade, commercial and/or mercantile agents
- insolvency practitioners such as administrators, receivers and liquidators
- insurers, insurance brokers and insurance assessors
- as required by law or by a regulator, government department or agency.
Personal information (about you) may also be collected from the above people or organisations.
Disclosure to business partners, intermediaries and group policy holder
When you buy a policy arranged by one of our business partners or intermediaries, or if you’re a third party beneficiary under a group policy, you consent to us providing all of your personal information to that business partner, intermediary or group policy holder, which may include sensitive information and claim information. That business partner, intermediary or group policy holder may also provide us with personal information.
You should read the privacy policy of that business partner, intermediary or group policy holder to find out how they collect, hold, use and disclose your personal information.
Disclosure to overseas recipients
In some instances, our service providers and related companies to which we disclose personal information may be located overseas. The countries in which these service providers and related companies are located may vary from time to time, but include the Philippines, India, Ireland, the UK, the US, China and countries within the European Union.
Where personal information has been disclosed to an overseas recipient, there is a possibility that in certain cases the recipient may be required to disclose it under a foreign law. Where this occurs, such disclosure is not a breach of the Act.
How personal information is held
Your personal information is held in secure environments including computer systems and databases, paper records and telephone recordings. We may utilise related companies, agents and third party suppliers for data storage services, which may be located outside of Australia.
When you supply information via the internet, all information you submit is held securely and is not retained on our web servers. Credit card details submitted via our websites or over the phone are processed through our service providers. Other information held on our systems cannot be accessed through the internet connection due to encryption at transit and at rest. Our online payment facilities are secure and the data, once collected, cannot be accessed through the internet due to encryption at transit and at rest.
Website and app tracking
When you visit our websites or use one of our apps we, or third parties acting on our behalf, use cookies to collect information. Cookies are small text files placed on your computer. We use both 'persistent' and 'session’ cookies. We also utilise other technologies similar to cookies, including those which are embedded into or which accompany emails sent by us or on our behalf. The information we collect includes:
- Details of visits to our websites or use of our apps and the browser used
- Details of sites visited before visiting our website
- Pages visited, time spent on them and documents viewed and download
- Visits made to our websites before
- Location
- Preferences, and
- Server address/IP address.
What we use this information for
We use information collected to:
- Assist in the use our online services and understand needs
- Collect and analyse statistical information
- Enhance and tailor website functionality and the customer experience
- Investigate security incidents
- Learn about emails sent, including if they were opened and what’s been done with them
- Manage our servers and websites
- Market our products and services and continue to improve them, and
- Evaluate the effectiveness of our advertising.
Managing cookies
By accessing our websites or using our apps you agree to cookies being stored in your browser or device. Browsers may be able to be configured to accept or reject cookies, or to notify when a cookie is being sent. The ‘help’ function on your browser will provide details on how to change configurations.
The functionality of our websites and apps may be affected if cookies are blocked or rejected.
Sharing information
We share information from cookies and other technologies with third party providers, including Google Analytics. The information collected can be combined with other information, allowing us or those third parties to identify users at an individual level, their behaviours, activity and needs.
Some of our websites present content and functionality provided by third parties which we don’t control. We’ll take reasonable steps to tell you before you use them, but you should consult the privacy policies of the third party providers as well.
For more information about cookies
For further information about cookies, including how to see what cookies have been set, how to manage and delete them or how to manage browser settings visit www.allaboutcookies.org
Accessing and seeking correction of your personal information
Our aim is to always have accurate, complete, up-to-date and relevant personal information. When you receive any documents from us you should check that the information is correct.
You may contact us to request access to your personal information that we hold at any time, and request us to correct any errors in that information. Generally, no restrictions or charges will apply. Customer care are also available if you have questions about our privacy policy or would like a free copy.
TCC Customer Care
Phone: +61 2 9375 4484 (Mon-Fri, 9am-5pm AEST)
Email: [email protected]
Post: GPO Box 5169 SYDNEY, NSW 2001
If you think we have not handled your personal information correctly, you can make a complaint with our TCC Customer Care team, the Office of the Australian Information Commissioner (OAIC) or, in certain circumstances, the Australian Financial Complaints Authority (AFCA). We recommend you contact us first so we can try and resolve your complaint effectively and efficiently as generally, the OAIC and AFCA will refer you back to us if you have not already complained to us.
Our TCC Customer Care team will contact you to acknowledge your complaint and provide you with a unique reference number. You will have the opportunity to explain why you are unhappy with how we have handled your personal information and provide information to support your complaint. Our TCC Customer Care team will review your concerns, taking into account all relevant information including relevant privacy requirements and work with you to try and resolve your complaint.
If you are not satisfied with the outcome of your complaint, you can take your complaint further including to:
Office of the Australian Information Commissioner (OAIC)
Complaints to the OAIC must be made in writing.
Website: www.oaic.gov.au
Email: [email protected]
Phone: 1300 363 992
or
Australian Financial Complaints Authority (AFCA)
AFCA can consider certain privacy complaints. You should contact AFCA to check if they can help you.
Website: www.afca.org.au
Email: [email protected]
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority, GPO Box 3, MELBOURNE VIC 3001
Date prepared:
Date effective:
A pdf version of our Privacy Policy can be requested from [email protected]