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Privacy Policy

Privacy Policy Statement

Effective 1 June 2014

 

Our commitment to your privacy

How we handle your personal information, is of utmost importance to Capital 19. This includes information or opinions about you that we collect and record which reasonably could be used to identify you. We adhere to the Privacy Act and the Australian Privacy Principles upon which this policy is based.

This document sets out our policies for managing personal information across the Capital 19 businesses operating in Australia. We have a Privacy Officer, whose contact details are below.

Information we collect from you When dealing with our customers and clients we generally collect your name, address, telephone number and other contact details. Depending on the type of account or facility you apply for or have, we may also collect and update personal information necessary to set up and maintain the account or investment, such as date of birth, employment details, bank account details, tax file number, basic financial information, and other information about your credit worthiness and credit history. We also record information about the status of your account and the transactions you make or wish to make on your account.

Sensitive Information We generally do not collect sensitive information (such as relating to ethnic origin, religious or philosophical beliefs, membership of a political or trade association, sexual preferences or health), and would not do so without your consent.

How do we use your information? Generally, we collect, update and use personal information about you to carry on our business, including:

  • to process your application for account-based services or facilities (including to check your identity and obtain credit reports and assess your credit worthiness) and to establish and manage your account or facility, and carry out transactions you wish to make
  • to provide requested services to you, and bill you for our services and collect overdue payments
  • for our research and development of new products and services
  • for training, quality control and verification purposes (including monitoring and recording your telephone conversations with us from time to time)
  • to communicate our, a related company's or a third party's marketing offers to you - when making the offer we will let you know how you may stop receiving any further marketing offers. Where another organisation outside of Capital 19 and its related companies is involved in the offer, we do not give information about you to that organisation
  • to meet our legal obligations. We may also collect, use and exchange your information in other ways where permitted by law

Direct Marketing If you don't want to receive direct marketing, you can tell us by contacting any employee of Capital 19 or following the opt out procedures enclosed in all our direct marketing

How we collect information Generally, we collect personal information directly from you, such as when you apply for or request a product or service, when you participate in our call centre marketing campaigns, competitions or surveys, in response to our advertising or direct mail or when you have other dealings with us. We may collect that information over the telephone or internet, in person (when you visit us at a Capital 19 office or through an agent) and when you write to us. We may also collect personal information through third parties such as:

  • credit reporting agencies
  • a business that provides commercial credit worthiness information
  • referees (if you give us the name of someone who can give a reference about you)
  • publicly available sources of information.

How we store information We store information in a combination of secure computer storage facilities and paper based files and other records. We have taken a number of steps to protect the personal information we hold from misuse, loss and unauthorised access, modification or disclosure. We use generally accepted technology and security so that we are satisfied that your information is transmitted safely to us through the internet or other electronic means. We will take reasonable steps to securely destroy or permanently de-identify personal information when we no longer need it.

Who do we exchange your information with? Generally, we may disclose information about you in the following circumstances:

  • where we have contracted an external organisation to provide us with support services. This may include but is not limited to processing applications or orders, marketing support, deliveries, market research and debt collection. These service providers may be within or outside Australia
  • to comply with our legal obligations (we notify you any time we are required to produce information in this way unless we are prohibited by court order or law or there is suspicion of fraud and/or criminal activity)
  • where we suspect that unlawful activity has been or may be engaged in and the information is a necessary part of our investigation or reporting of the matter. We also may disclose information about you in the following circumstances:
  • where you have a corporate or government card membership, we may exchange information with your employer or government agency
  • to our related companies (including other Capital 19 companies outside Australia) to provide you with products and services you request and to inform you about other Capital 19 products and services
  • to credit reporting agencies in connection with us providing credit to you or recovering from you amounts that you owe under any contract you have with us.

We impose strict requirements of security and confidentiality on all third parties as to how they handle personal information. We provide our outside contractors only with information they need to perform their services - they are not permitted to use the information for any purpose except to provide the service to us. The Privacy Act also strictly controls the information we exchange with credit reporting agencies.

We will disclose personal information about you only with your consent in the following circumstances:

  • where organisations cooperate with us in offering products and services such as cobrand partners (we will notify you of that disclosure and obtain your consent on the application form)
  • to meet your request for certain services
  • to anyone else you authorise us to disclose information to, from time to time.

Under 16s and special needs If you are under 16 or have special needs, we may share information with your parent or legal guardian or any person appointed to manage your affairs.

Sending Information Overseas Capital 19 employs the services of overseas companies in providing our services to you. It is highly likely we will need to send your information to these overseas service providers. Where we do this, we make sure that appropriate data handling and security arrangements are in place. Please note that Australian law might not apply to some of these entities.

We may also send information overseas to complete a particular transaction, or where this is required by laws and regulations of Australia or any other country.

When we send your information overseas, it is likely to be one of the following countries

  • United States of America
  • United Kingdom
  • Canada
  • Germany
  • Hong Kong

Keeping us up-to-date We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If your personal details change, such as your telephone number or billing address, please contact us so that we can continue to provide you with our products and services.

How you can access your personal information You can ask for access to your basic information (for example: what transactions you've made by going online or calling us. For more detailed information please make a request using the details below. Following a request, we will provide you with a copy of personal information which we hold about you in accordance with our obligations under the Privacy Act. We may charge a fee for retrieving this information (we will inform you of the fee before providing the information). Please note that there are some circumstances set out in the Privacy Act where we may refuse your request.

Making a privacy complaint If you have a concern about your privacy, you have a right to make a complaint and we'll do everything we can to put matters right.

To lodge a complaint, please get in touch with us using our customer service team or using our contact details below. We'll review your situation and try to resolve it straight away. Usually it takes only a few days to resolve a complaint, however, if we're unable to provide a final response within 45 days, we'll contact you to explain why and discuss a time frame to resolve the complaint.

If you're not satisfied with our handling of your matter, you can refer your complaint to an external dispute resolution. We suggest you only do this once you've first followed our internal complaint process as above. The Office of the Australian Information Commissioner will hear your complaints about the way we handle your personal information. You can contact them on 1300 363 992 or online at www.oaic.gov.au.

About this Privacy Policy Statement We may update our policies and this Privacy Policy Statement from time to time. The latest version is published on our web site at www.capital19.com and is available in print at the Capital 19 office, by contacting us using the details below.

Contacting us> If you have any questions about our policies, or if you wish to update or access the information we hold about you, wish to make a related complaint or to receive a copy of our most current Privacy Policy Statement, please telephone us on 02 9002 0360 or write to us at: The Privacy Officer Capital 19 PO Box H69, Australia Square NSW 1215