Thank you for trusting us with your information. We value that trust, and that’s why protecting your information, and being clear about how we collect, use, exchange and protect your information, is of huge importance and a vital part of our relationship with you.
1. Your privacy is important to us
This Policy outlines how Grow Advisory Group (growadvisorygroup.com.au) and its related companies, (“we / us / the Group”) collect, disclose, use, store or otherwise handle personal information. It is important to us that we manage your personal information securely and consistently with relevant legislation, including the Privacy Act 1988 (Commonwealth) (“Privacy Act”).
If necessary, how you can make a complaint relating to our handling of that information. This policy is not limited to current customers or guarantors of customers (where applicable) – it relates to all other individuals who deal with us.
2. Information we collect from you
We collect information about you and your interactions with us, for example, when you request or use our products or services, make a card purchase or transfer money, phone us or visit any of our websites. When you use our website or mobile applications, we may collect information about your location or activity including IP address, telephone number and whether you’ve accessed third-party sites. Some of this website information we collect using cookies.
The information we collect from you may include your identity and contact details, other personal details such as gender and marital status and financial information. Where applicable, we also collect health information, for example, for insurance purposes.
2.1 Personal Information
We collect information about you and your interactions with us, for example, when you request or use our products or services, make a card purchase or transfer money, phone us or visit any of our websites. When you use our website or mobile applications, we may collect information about your location or activity including IP address, telephone number and whether you’ve accessed third-party sites. Some of this website information we collect using cookies. The information we collect from you may include your identity and contact details, other personal details such as gender and marital status and financial information.
2.2 Information we collect from others
We collect information about you from others such as service providers, agents, advisers, brokers, employers or family members.
2.3 Sensitive information
The Privacy Act also protects your sensitive information, such as health information that’s collected on insurance or hardship applications. If we need to obtain this type of information, we will ask for your consent, except where otherwise permitted by law.
3. How do we use your information?
In many circumstances, we will collect the above information primarily from you (or from someone who is representing or assisting you). However, there are certain instances in which we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. We use this information to:
- Establish your identity and assess applications for products and services
- Price and design our products and services
- Administer our products and services
- Manage our relationship with you
- Conduct and improve our businesses and improve the customer experience
- Manage our risks and help identify and investigate illegal activity, such as fraud
- Comply with our legal obligations and assist government and law enforcement agencies or regulators
- Identify and tell you about other products or services that we think may be of interest to you.
We may also collect, use and exchange your information in other ways where permitted by law.
3.1 Direct marketing
If you don’t want to receive direct marketing, you can tell us by using any of the methods set out in section 9.
3.2 Gathering and combining data to get insights
Improvements in technology enable organisations to collect and use information to get a more integrated view of customers and provide better products and services. We may combine customer information it has with information available from a wide variety of external sources (for example census or Australian Bureau of Statistics data). We are able to analyse the data in order to gain useful insights which can be used for any of the purposes mentioned earlier in this policy. In addition, Group members may provide data insights or related reports to others, for example to help them understand their customers better. These are based on aggregated information and do not contain any information that identifies you.
4. Who do we exchange your information with?
We exchange your information with other members of the Group, so that the Group may adopt an integrated approach to its customers. Group members may use this information for any of the purposes mentioned in this section.
4.1 Third parties
We may exchange your information with third parties where this is permitted by law or for any of the purposes mentioned in section 4.
Third parties include:
- Your co-applicant(s) (if any)
- Related entities based in Australia
- Entities that provide services to us such as mailing houses or call centre operators
- Service providers, for example law firms, market research / data providers, and loyalty program redemption partners
- Those to whom we outsource certain functions, for example, direct marketing, statement production, debt recovery and information technology support
- Brokers, agents and advisers and persons acting on your behalf, for example guardians or persons holding power of attorney
- Auditors, insurers and re-insurers
- Employers or former employers
- Government and law enforcement agencies or regulators
5. Keeping your information secure
We keep your hard-copy or electronic records on our premises and systems or offsite using trusted third parties. Our security safeguards include:
5.1 Staff education
We train and remind our staff of their obligations with regard to your information.
5.2 System security
When you transact with us on the internet via our website or mobile apps we encrypt data sent from your computer to our systems. We have firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing our systems. When we send your electronic data outside the Group we use dedicated secure networks or encryption. We limit access by requiring use of passwords and/or smartcards.
5.3 Building security
We have protection in our buildings against unauthorised access such as alarms, cameras and guards (as required).
5.4 Destroying data when no longer required
Where practical, we keep information only for as long as required (for example, to meet legal requirements or our internal needs).
6. Accessing, updating and correcting your information
6.1 Can I get access to my information?
You can ask for access to your basic information (for example what transactions you’ve made) by calling us.
6.2 How long does it take to gain access to my information?
We try to make your information available within 30 days of your request. Before we give you the information, we’ll need to confirm your identity.
6.3 Can you deny or limit my request for access?
In certain circumstances, we’re allowed to deny your request or limit the access we provide. For example, we might not provide you access to commercially sensitive information. Whatever the outcome, we’ll write to you explaining our decision. Updating your basic information It’s important that we have your correct details, such as your current address and telephone number. You can check or update your information by going online, emailing or phoning us.
7. Making a privacy complaint
7.1 We’re here to help
We accept that sometimes we can get things wrong. 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.
7.2 How do I make a complaint?
To lodge a complaint, please get in touch with us using your point of contact or one of the customer service teams set out in section 8. We’ll review your situation and try to resolve it straight away. If you’ve raised the matter through your point of contact or our customer service teams and it hasn’t been resolved to your satisfaction, please contact our Customer Relations team using the details in section 8.
7.3 How do we handle a complaint?
We acknowledge every complaint we receive and provide our name, a reference number and contact details of the investigating officer. We keep you updated on the progress we’re making towards fixing the problem. 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 timeframe to resolve the complaint.
7.4 External review
If you’re not satisfied with our handling of your matter, you can refer your complaint to external dispute resolution. We suggest you do this only once you’ve first followed our internal complaint processes set out above. The Financial Ombudsman Service (FOS) offers a free and independent dispute resolution service for the Australian Financial Services industry. Please contact FOS at 1300 780 808, online at www.fos.org.au or write to Financial Ombudsman Service Limited, GPO Box 3, Melbourne VIC. If your complaint is about the way we handle your personal information, you may also contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, online at www.oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.
8. How to contact us or find out more
For privacy related queries, access or correction requests, or complaints, or to request a printed version of this policy, email email@example.com. We aim to resolve your query or complaint at your first point of contact with us. You can use your usual point of contact or call our customer service team.
8.1 To update your direct marketing preferences or request not to receive direct marketing
You can call us using the number above or emailing us. For more information about the Australian Privacy Principles visit: Office of the Australian Information Commissioner (privacy generally).