Protecting personal information has always been important to us, but the recently enacted Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) amending the Privacy Act 1988 (Cth) (‘the Act’) means that we have further obligations in relation to protecting your personal information. The Act, in accordance with Australian Privacy Principles (APP’s) which were introduced in March 2014 to replace the National Privacy Principles and Information Privacy Principles, determines how we must handle personal information.
This is a summary of GreenCo Health (Ciala)’s policy on the management, collection, security, integrity, disclosure of and access to personal information about members.
Personal information you provide to GreenCo Health (Ciala) (“GCH”)
1.1 You agree for GCH to obtain from a credit reporting body (“CRB”) a credit report containing personal credit information (for example name, address, dob, occupation, previous credit applications, credit history etc.) about you in relation to credit provided by GCH.
1.2 You consent to GCH being given a consumer credit report to collect overdue payment on commercial credit.
1.3 You agree that personal credit information provided may be used and retained by GCH for the following purposes (and for other purposes as shall be agreed between you and GCH or required by law from time to time):
(a) the provision of Goods and/or services; and/or
(b) the marketing of Goods and/or services by GCH, its agents or distributors; and/or
(c) analysing, verifying and/or checking your credit, payment and/or status in relation to the provision of Goods and/or services; and/or
(d) processing of any payment instructions, direct debit facilities and/or credit facilities requested by you; and/or
(e) enabling the daily operation of your account and/or the collection of amounts outstanding in your account in relation to the Goods and/or services.
1.4 You acknowledge GCH’s right to access publicly available information about you which can:
(a) relate to your activities in Australia or the external Territories and your credit worthiness; and
(b) that is not court proceedings information about you or information about you that is entered or recorded on the National Personal Insolvency Index.
1.5 Insofar as it is possible, GCH will preserve your anonymity and/or pseudonymity where practical and in accordance with the law.
Disclosure of your personal information
1.6 You agree that GCH may exchange information about you with those credit providers either named as trade referees by you or named in a consumer credit report issued by a CRB and with related body corporates for the following purposes:
(a) to assess an application by you; and/or
(b) to notify other credit providers of a default by you; and/or
(c) to exchange information with other credit providers as to the status of this credit account, where you are in default with other credit providers; and/or
(d) to assess your creditworthiness with the CRB providing information pertaining to your repayment history for a period of up to the previous two years.
You understand that the information exchanged can include anything about your creditworthiness, credit standing, credit history or credit capacity that credit providers are allowed to exchange under the Act and the APP’s.
1.7 GCH may give information about you to a CRB for the following purposes:
(a) to obtain a consumer credit report about you; and/or
(b) allow the CRB to create or maintain a credit information file containing information about you including credit history information.
1.8 The information given to the CRB may include:
(a) personal particulars (your full name, alias, or previous name, sex, current address (or last known), previous addresses, date of birth, name of employer, driver’s licence number);
(b) name of the credit provider and that GCH is a current credit provider to you;
(c) whether the credit provider is a licensee;
(d) type of consumer credit;
(e) details concerning your application for credit or commercial credit, date of commencement and/or termination of the credit account and the amount requested;
(f) advice of any consumer credit defaults to include overdue accounts, loan repayments, and/or any outstanding monies owing which are overdue by more than sixty (60) days and for which written notice for request of payment has been made, resulting in debt collection action being started in accordance with GCH’s terms and conditions;
(g) that your repayment history in relation to overdue accounts, loan repayments and/or any outstanding monies are no longer overdue in respect of any default that has been listed;
(h) information that, in the opinion of GCH, you have committed a serious credit infringement (that is, fraudulently or shown an intention not to comply with your credit obligations);
(i) advice that the amount of your overdue payment is equal to or more than one hundred and fifty dollars ($150);
(j) that credit provided to you by GCH has been paid or otherwise discharged and all details surrounding that discharge to include the dates of payments and your compliance with any payment plan as between you and GCH.
1.9 Unless otherwise agreed, GCH agrees not to disclose any personal information about you for the purpose of direct marketing. You have the right to request (by telephone and/or by e-mail) that GCH does not disclose any personal information about you for the purpose of direct marketing;
1.10 GCH agrees where information is to be disclosed about you to a third party (an overseas recipient) that GCH will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles (other than AAP 1) in relation to the information, in accordance with APPs 8.1 & 8.2).
How to manage your personal information
1.11 GCH respects your right to make choices about the use and disclosure of your personal information. You shall have the right to request from GCH a copy of the information about you retained by GCH and the right to request (by telephone and/or by e-mail and/or by use of the “my account” section of the GCH website) from GCH to correct any incorrect information.
Website access and use
1.12 Where you have used GCH’s website for account access, expert product advice or to provide a testimonial, cookies may be used by GCH to collect information including IP addresses about people from GCH’s website. There are many aspects of GCH’s website which can be viewed without providing personal information, however, for access to the customer support features (and future customer features) you are required to submit personally identifiable information. Cookies allow GCH to determine who has seen particular pages on its website and how frequently. This can help GCH to identify your preferences and allow GCH to recommend content it believes you would be most interested in.
1.13 For each visitor to reach the site, GCH expressly collects the following non-personally identifiable information, including but not limited to:
(a) Brower type;
(b) Version and language;
(c) Operating system;
(d) Pages viewed while browsing the website;
(e) Page access times; and
(f) Referring website address.
This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at the website.
1.14 From time to time, GCH may use customer information for new, unanticipated uses not previously disclosed in this privacy notice. If GCH’s information practices change at some time in the future, GCH will use data collected from the time of the policy change for these new purposes only.
Security of your personal information
1.15 GCH has appointed a specialist Administrator to provide services to this organisation. These service providers are authorised by way of a contract to use personal information only to administer contracted services, and are required to treat that information in the strictest confidence in accordance with a confidentiality agreement.
Destruction of information
1.16 GCH will destroy personal information upon your request (by telephone and/or by e-mail) or when the personal information is no longer required. The exception to this is if the personal information is required in order to fulfil the purpose of this organisation or is required to be maintained and/or stored in accordance with the law.
External access to information
1.17 Any authorised representative including accountants, solicitors and financial planners must have been authorised to receive your personal information, security checked and verified and it be recorded on our database except if it’s required in accordance with the law such as a Federal Act.
1.18 The following measures are in place in order to deal with any enquiries that would result in the divulgence of personal information:
Administration staff will establish identification by correct answer to personal questions: eg. DOB, address, employer, commencement with employer.
Response is provided to the address on the written enquiry but only if it is the same as in GCH’s records.
Any authorised representative including accountants, solicitors and spouses must have been authorised by you, security checked and verified and it be recorded on GCH’s database except if it’s required in accordance with the law such as a Federal Act.
User identification and password requirements for clients that are set and maintained by GCH. You can correct your personal information by accessing our website.
Protection of customer payment information
1.19 To complete payment transactions, you are taken to a third party payment processors (Paypal) secure web server. At no time during this transaction do we have access to or storage of your credit card details. After the payment is processed, we are sent a “token” confirming payment has been received and we process your order for shipping.
1.20 You can make a complaint to our internal dispute resolution team (‘IDR’) regarding an interference with and/or misuse of your personal information by contacting GCH via telephone or e-mail. GCH will respond to that complaint within 7days of receipt and will take all reasonable steps to make a decision as to the complaint within 30 days of receipt of the complaint. GCH will disclose information in relation to the complaint to any relevant credit provider and or CRB that holds the personal information the subject of the complaint. In the event that you are not satisfied with the resolution provided they can make a complaint to the Information Commissioner on the OAIC website at www.oaic.gov.au.
1.21 You hereby agree and consent to the contents of the collection, use and disclosure of your personal information. In the event that you do not wish to agree or consent to any of the above use, collection and disclosure of your personal information by GCH, GCH warrants that any request by you to withdraw your consent or agreement shall be deemed as confirmation by you to cease any and/or all collection use and disclosure of your personal information. Request (by telephone and/or by e-mail) can be made by you to GCH.
1.23 You can contact GCH by sending GCH an email to: firstname.lastname@example.org , or by phoning GCH: +61 423 629 933 during normal business hours EST.
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