IO Ventures respects your privacy and is committed to protecting your personal information. Here we outline the obligations which we have in managing the personal information we hold about our clients, potential clients, contractors and others.
This Policy outlines our obligations in managing personal information about our clients, potential clients, contractors and others. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).
1. Personal information we collect and hold
'Personal information' is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
The privacy of your personal information is a priority to us at IO Ventures Pty Ltd (ABN 66 6228 313 05) (, IO Ventures, we or us). We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we are committed to complying with the Privacy Act’s requirements in respect of the collection and management of your personal information. In general terms, this means any information that can be used to identify you, including your name, address, telephone number and email address.
When you interact with us, you will ordinarily have to identify yourself, which will involve providing us with your personal information. This is because it is impractical in most circumstances for you to remain anonymous and we may not be able to do business with you or answer your enquiry if we are not able to identify you or collect your personal information.
2. CUSTOMERS & PROSPECTIVE CUSTOMERS
2.1 What information do we collect from customers and prospective customers?
As a customer or prospective customer, we may collect your name, current and previous addresses, date of birth, telephone number, email address, bank account details and credit card details and credit history.
We may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with.
2.2 How do we collect personal information?
Unless it is unreasonable or impracticable to do so, we will endeavour to collect your personal information directly from you, including through our website, by telephone, through written correspondence (such as letters and emails), and in person.
We may also collect personal information about you from third parties, including from additional account holders on your account, your authorised representative, from our agents or third parties with whom we have business relationships, from credit reporting bodies and other credit providers and from publicly available sources of information, such as address validation software and telephone directories. For prospective customers, we also receive and collect person information about you from third parties (some of whom may be our agents) who have identified you as a person who may wish to receive offers relating to our products and services.
2.3 Using your personal information
As a customer or prospective customer, once we’ve collected your personal information we intend to use it:
· to provide our products and services to you, or to provide you with a quote or offer for our products and services;
· if you are or become a customer of ours, to communicate with you about your account with us, including issuing bills and seeking payment of those bills;
· if you request or agree, to set up a direct debit facility to cover payment of any bills issued by us;
· if you lodge a complaint with us, to process and respond to your complaint;
· if you make an enquiry via our telephone helpline or via our website, to answer your enquiries and provide any information or documents requested by you;
· for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
· to update our records and keep your contact details up to date;
· to conduct a credit assessment of you and use information we are permitted by law to use to establish or report on your creditworthiness; and
· for marketing purposes where we have your express or implied consent to contact you using one or more types of personal information that we hold about you or we are otherwise permitted by law to do so.
If you do not wish to receive our product and service offers, you can manage your communication preferences, which includes an option to opt out of one or more (or all) communication channels.
Alternatively, you can call us on 0390345299 or write to us at
IO Ventures Pty Ltd,
1 Queens Road
2.4 When do we disclose personal information to third parties?
We may disclose your personal information to third parties in the conduct of our business.
Some of these third parties act on our behalf, and if this is the case we ask that these third parties hold, use and disclose your personal information in accordance with the Privacy Act.
These third parties may include additional account holders or your authorised representative, financial institutions (for payment processing), credit reporting bodies and other credit providers, government and regulatory authorities (where required or authorised by law) and other service providers.
Examples of service providers include information technology suppliers, debt collection agencies, marketing and advertising agencies and contractors, mailing and logistics providers and our professional advisors (such as accountants, auditors and lawyers). We may disclose your personal information to these service providers for the purpose of their work and, equally, and these service providers may provide us with personal information they have collected from you in the course of providing the relevant products or services.
We may also disclose your personal information to third parties to whom we assign your debt.
3. CREDIT REPORTING POLICY
3.1 Purpose and application
Where we provide products or services to you on credit (that is, you will pay for those products or services after we start providing them to you), we are a credit provider for the purposes of the Privacy Act.
3.2 Collection of credit related information
We may collect, hold, use and disclose certain credit related information about you. We may obtain this information from you or from third parties, including from credit reporting bodies and other credit providers, in order to assist us in determining whether we will provide or continue to provide any products or services to you on credit and to manage our relationship with you. Credit related information includes:
· your name and contact details;
· your credit history (including any repayments or late repayments you have made);
· details of any credit you have sought or obtained from other credit providers;
· any credit rating or credit assessment score that we calculate or that a credit reporting body might provide to us; and
· details of any credit related court proceedings or insolvency applications that relate to you.
3.3 Our use and disclosure of your credit related information
We may use the credit related information collected and held by us to derive or calculate a credit assessment score in relation to you, which we may use to help us decide whether or not to provide credit to you and to manage our relationship with you.
We will securely store all credit related information that we collect or hold about you.
Credit related information that we hold about you may be used and disclosed by us as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code. This includes:
· using your credit related information to assess an application for credit made by you to us;
· using your credit related information to collect payments that you owe to us;
· disclosing your credit related information within IO Ventures where we are considering whether to provide credit to you;
· disclosing your credit related information to credit reporting bodies which collect different types of credit related information about individuals and use that information to provide a credit related service to their customers;
· disclosing your credit related information to other third parties, such as debt collectors, credit management agencies and our agents and other third parties which provide credit related services to us (such as processing applications for credit made to us);
· disclosing your credit related information to a third party that you or we request act as a guarantor in relation to any credit provided to you;
· disclosing your credit related information to third parties to whom we assign your debt;
· using and disclosing credit related information that we hold about you in relation to any access or correction requests that you make to us, a credit reporting provider or another credit provider;
· using and disclosing credit related information that we hold about you in relation to any complaint that you make, whether to us, a regulator or any provider of a recognised external dispute resolution scheme;
· using and disclosing credit related information that we hold about you as required by law or the order of a court or tribunal; and
· where you otherwise expressly consent to the use or disclosure.
3.4 Other matters regarding credit related information
If your application for credit is refused by us based on information provided to us by a credit reporting body, we will inform you of this and provide you with the name and contact details of that body (together with any other information required to be provided to you).
If you request that we correct any credit related information that we hold about you, we will respond to that request within 30 days (or such longer period as you may agree) and correct any credit related information that we hold about you that we are satisfied is inaccurate, out-of-date, incomplete, irrelevant or misleading. We may consult with other credit providers and credit reporting bodies in relation to your request. If we do correct your credit related information as a consequence of you making a correction request, we will notify you and each other credit provider and credit reporting body to which we have previously disclosed that information, including where we disclosed your credit related information after you made a complaint but before it was resolved. At the time of making such a disclosure before your complaint is resolved, we will tell the recipient that you have made such a complaint.
If we correct credit related information that we hold about you without you first making a correction request, we will take reasonable steps to notify that correction to you and each other credit provider and credit reporting body to which we have previously disclosed that credit related information (unless it is impracticable for us to do so).
If you make a complaint in relation to correction of your credit related information, we will notify each other credit provider and credit reporting body to which we have previously disclosed that information that you have made a correction complaint in relation to that information and the outcome of that complaint, unless it is impracticable or illegal for us to do so.
4. OUR EMPLOYEES & CONTRACTORS
If you are applying for a position with us (either as an employee or a contractor), we will ask you to provide specific personal information, such as your name, email address, telephone number, proof of right to work documents, qualifications and career history. We may also ask you for other information such as your interests and the position(s) you are interested in.
Any personal information that you provide to us in connection with your application may be used to consider you for current and future employment or engagement as an employee or a contractor. We may disclose any personal information that you provide to our external advisors to assist us in the selection and recruitment and employment processes.
If your application is unsuccessful, the Privacy Act will apply to any personal information that we collect, use, hold and disclose about you. We may retain this information for a reasonable period, and may use it to contact you in relation to other employment or contracting opportunities that you may be interested in.
4.2 Our Employees
If you are or become our employee, we will collect employee records and personal details, referee reports and other information about you. The handling of your personal information as an employee is exempt from the Privacy Act if it is directly related to your current or former employment relationship with us. We will not disclose your personal information for any other purpose, other than as required by law or to manage your employment relationship with us.
4.3 Our Contractors
If you are engaged by us as a contractor, the Privacy Act will apply to any personal information that we collect, use, hold and disclose about you. We will collect, use, hold and disclose personal information about you in order to manage and administer your engagement as a contractor. This may include disclosing your personal information to employees and other contractors of ours so they may contact you in relation to your engagement as a contractor, including to provide instructions or information to you and collecting, using and disclosing your personal information in relation to reviewing and paying any invoices related to your engagement as a contractor, and ensuring appropriate training is provided.
5. OTHER CONTRACTORS & VISITORS
If you are an employee or contractor of a third party with whom we engage as part of our business, then we may collect personal information about you as part of your role in working for that third party.
If you are a visitor to any of our offices or sites (such as for a business or other meeting), we may collect some personal information about you as part of this visit, including for safety and security purposes.
We will collect, use, hold and disclose personal information about you in connection with these purposes, including to the extent required to provide you with access to any sites, offices, buildings or other premises that we own or lease or which are under our control.
6. SECURITY, QUALITY AND LOCATION OF YOUR INFORMATION
We rely on the personal information and credit related information that we receive and hold to conduct our business. We take reasonable steps to ensure that the personal and credit related information that we collect, use and disclose about you is accurate, complete and up-to-date and, in relation to the purpose of our use or disclosure, relevant. You can help us by letting us know about any changes to your personal information, such as your address, email address or telephone number.
We store information in different ways, including in hardcopy and electronic form. We have implemented controls around technology and our organisational processes to assist us in protecting your information from misuse, interference and loss and from unauthorised access, modification or disclosure. This includes having in place confidentiality requirements for employees and contractors, as well as implementing document storage security policies, systems and site access restrictions.
Where we disclose your personal information to a third party which is located overseas or which will hold your personal information overseas, we will take reasonable steps to ensure that the overseas recipient of your personal information handles your personal information in accordance with the standards required under the Privacy Act.
We do not sell, rent or trade our customers’, shareholders’ or other stakeholders’ personal information to or with third parties.
However, no data transmission over the internet can be guaranteed to be 100 per cent secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of that information if it is sent over the internet. Once we receive your information, we make endeavour to ensure its security on our systems. If you are concerned about sending your information over the internet, you can contact us by telephone, email or post. We may however send information within IO Ventures or to third parties who we work with, including over the internet.
7. OUR WEBSITES
7.1 Privacy when browsing IO Ventures websites
7.2 Information collected through our websites
Some of the information that may be collected by us during your visit to our websites is not personal information, because it does not reveal your identity. For example, we may record the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used.
If collected, this information will be used and disclosed by us in accordance with section 7.3 of this Policy or in an aggregated form for purposes including statistical and web site development. However, we reserve our right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
We may log IP addresses (which is the electronic address of a computer connected to the Internet) to analyse trends, administer our websites, track users’ movements and gather broad demographic information.
Our websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
8. ACCESS AND CORRECTION
Please contact us using the contact details below if you would like to access or correct the personal information or credit related information that we hold about you.
Where we hold any of that information about you, we will try to provide you with suitable means of accessing it (such as by making it available to you in our offices or by mailing or emailing it to you) if you request access to that information. We will generally provide access to you within a reasonable time, subject to some exceptions permitted by law. We may in some circumstances charge a reasonable fee to cover our costs of providing access to you. However, we will not charge you for making a request for access or for making any corrections to your personal information or credit related information.
We may refuse to grant you access to your personal information or credit related information under some circumstances prescribed by the Privacy Act (for example, if providing access would be unlawful or would have an unreasonable impact upon the privacy of other individuals).
If you believe that any personal information or credit related information which we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, then you may request that we amend your information using the contact details below. We will consider whether the information requires amendment and notify you of the outcome of our assessment.
Where we do not agree that there are grounds for amendment of your personal information then we will (if you request) add a note to the personal information stating that you disagree with it.
If we correct any personal information that we hold about you, you may request that we notify a third party that we have corrected any personal information that we hold about you. We will take reasonable steps to comply with such a notification request if made by you.
9. OUR COMPLAINTS HANDLING PROCESS
If you believe that your privacy has been breached or you have a complaint in relation to our handling of your personal information or credit related information, please contact us using the details below and provide details of the incident. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Privacy Act, if applicable).
If you are not satisfied with our response or our proposed resolution of your complaint, then you may lodge a formal complaint with the Office of the Australian Information Commissioner (for more information, please see www.oaic.gov.au). If your complaint relates to credit related information, you may also make a complaint to a third party dispute resolution provider instead of the Office of the Australian Information Commissioner. We will tell you who this third party dispute resolution provider is when we write to you regarding our proposed resolution of your credit related complaint.
10. CONTACTING US