- What personal information we collect and from where?
- Consents and notifications
- Using your personal information
- Disclosing your personal information
- Credit Reporting
- Taking care of your Personal Information
- Accessing your Personal and Credit Information
- Correcting your personal information
- Resolving your privacy issues
- Contact us
- Dealing with us anonymously
- Trade credit accounts provided by Outdoor Instant Shelters;
- Extended warranty on any product provided by Outdoor Instant Shelters and;
By providing us with personal information you consent to any of our businesses using the information for the purposes set out or as permitted in this Policy or as otherwise authorized.
What personal information do we collect and from where?
We collect your personal information so that we can perform various functions and activities – especially the provision of the parts products and related services that you request from us. We also collect your personal information if the law requires us to do so. If you do not provide us with the personal information we request, we may not be able to:
- Provide you with the parts products and services that you request from us;
- Manage and administer our relationship with you;
- Let you know about other parts products or services or benefits associated with being a customer that may be of interest to you; and
- Verify your identity and protect against fraud.
Collecting information from you
We collect most personal information directly from you when you make a purchase of one or more of our parts products and related services. For example, you provide us with personal information when you complete an application for a trade credit account, register your interest for a specific product we sell, deal with us over the phone or use our website.
We may collect and hold information from you such as:
- Name, personal and business contact details including addresses, phone numbers, and email addresses and gender,
- Tax file number (“TFN”) and (“ABN”) and GST number;
- Date of birth;
- Financial details relating to you personally and any business you own or are involved in the event you request a credit account;
- Credit history with us and with third parties including nominated trade referees and details of your trading history with them and our preferred suppliers;
- Reports from credit reporting agencies concerning your creditworthiness or credit history;
- Transaction and correspondence history with us;
- Bank account and credit card details;
- Driver’s license.
Collecting publicly available information
We may also collect information about you that is publicly available, including information from:
- Phone directories and trade directories;
- Websites; and
- Public registers such the company register, business names register and the personal property securities register in Australia.
Collecting information from third parties
We may also collect information about you from third parties. For example, we may collect information from:
- Credit reporting bodies if we request a commercial or consumer credit report about your credit history (see the “Credit Reporting” for more information about our credit reporting policy);
- Our preferred suppliers including as you transact with them through your trade credit account;
- Other credit providers or suppliers if you put them forward as a trade reference;
- Our related companies so we can better manager your relationship with us as a whole;
Collecting information through our websites
When you visit our websites, we may use a “cookie” which is a small data file that is placed on your computer of a website user (usually in the browser software folder).
Collecting sensitive information
Sensitive information is information about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health information, genetic or biometric information. We will not collect, use or disclosure sensitive information about you unless:
- We are legally required to do so; or
Collecting information required by law
We may collect information from you because we are required or authorized to do so under law. We will tell you when collection is required or authorized by law. For example, before we can provide you with a trade credit account or any extended warranty product we are required under the anti-money laundering and counter terrorism financing law to collect certain personal information from you such as your driver’s license and/or passport to verify your identity.
Sometimes we may receive unsolicited personal information about you. If so, we will check whether or not that the information is reasonably necessary for us to hold and we could have collected it from you if we had solicited the information. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, and it is lawful and reasonable to do so, we’ll ensure we do the right thing and destroy or de-identify it.
Collecting Information Prospectively
We may also collect personal information from you or from third parties prospectively, having identified you as a person that may wish to use our parts products or related services in the future.
Collecting information from Prospective Employees
When you are dealing with Outdoor Instant Shelters as a prospective employee, we generally collect and uses personal information about you in order to process and evaluate your application for employment, including identification information and your employment history. Unsuccessful application forms may be kept on file up to six months to allow those candidates future opportunities.
Consents and notifications
Your consent is important. We may need your consent to use or disclose your personal information in certain circumstances including where we want to use your personal information for a purpose that is not related to the purpose for which we collected it in the first place.
Notifying you of information received. When we receive personal information from you directly, we’ll take reasonable steps to notify you of:
- Why we collected your information including providing you with our contact details,
- How we collected your information (if not from you);
- Who we may disclose it to;
- How we may use it;
- Whether the collection is required or authorized by law such as our obligation to verify your identity as part of anti-money laundering obligations;
- How you can access it, seek correction of it or make a complaint and how we will deal with any complaint;
- The main consequences if your personal information is not collected.
Sometimes we collect your personal information from third parties and you may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
Using your personal information
We may collect, use and disclose personal information we collect about you for a number of purposes, including:
- To enable us to consider your credit application for a parts account;
- To allow us to provide you with our products and services;
- To allow us to manage our relationship with you, including communicating with you about benefits, events or products and services that you may be receiving or may be entitled to receive;
- To allow us to manage our arrangements with our preferred suppliers or other third parties that may be involved in the provision of products or services to you and also to allow these same preferred suppliers and third parties to manage their arrangements with you;
In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorized by law. For example, we collect TFNs to complete Australian Investment Income Returns and, if applicable, calculate withholding tax on dividends paid. You do not need to provide your TFN to us. If you don’t provide this information we may not be able to provide income information to the Australian Tax Office and may be required to deduct withholding tax from any dividends paid at the highest rate.
Disclosing your personal information
Consistent with the uses of your personal information described above, we may disclose personal information about you to:
- Our related companies, and our employees, officers, assignees, contractors, service providers, mail-houses and external advisers;
- Our preferred suppliers, in particular information relating to: the status of your trade credit account (including if it is placed on stop credit) or any other product or service you may receive from us; o transactions conducted using your trade credit account; or your business contact and transactions details so that they may direct market to you; and o any disputes you may have with the preferred supplier or us relating to the preferred supplier;
- Third party providers of industry publications,
- Organizations which verify identities;
- Credit reporting bodies;
- Your agents, advisers, referees, executor, administer, trustee, the beneficiary of any trust of which you are a trustee, your guardian or attorney;
- Payment system operators;
- Any other party that you consent to.
Marketing and your privacy
As part of our services to you, we may use or share your personal information so that products, services or benefits that we think you may be interested in learning about can be identified and direct marketed to you. We, or our preferred suppliers or other third parties that we have a relationship with, may contact you from time-to-time about new or existing products or services that they or we offer.
We consider that direct marketing to you by us, our preferred suppliers and other third parties with which we have a relationship forms an integral part of delivering services to you and is directly related to the primary purpose for which we originally collected your personal information. Without such a service, the communication between you, us and our preferred suppliers and other third parties which we have a relationship with would be substantially reduced and you would be unlikely to receive the benefits and returns you expect from being one of our members or customers.
We participate in the credit reporting system We may obtain a credit report about you from a credit reporting body if you:
- Apply for a credit account with us;
- Put yourself forward as a covenantor or guarantor for another person applying for credit or receiving credit from us; or
- Currently receive credit from us or are currently a covenantor or guarantor for another person that currently receives credit from us. To request a credit report we will disclose to a credit reporting body information that identifies you (such as your name, address, date of birth and driver’s license number) and also relates to the credit that you are applying for or seeking to covenant or guarantee. Credit reports contain information about your credit worthiness and credit history with other credit providers. This information may include information about your previous and current credit applications, credit facilities, credit repayment history and any payment defaults. We will often combine information contained in credit reports with information that we already hold about you or that has been obtained from other sources (for example, trade references from existing suppliers or any past or current relationship you have had with us).
Using Credit Information
We will use this information to:
- Assess any application you make for credit;
- Assess you suitability as a guarantor;
- To assist in our general management and administration including for example; risk management, strategic development, systems development, credit management, debt collection, staff training and research;
- Comply with any relevant laws, regulations, codes of practice and payment system requirements.
Disclosing Credit Information to credit reporting bodies
As a participant in the credit reporting system we may disclose information about your credit history with us to credit reporting bodies including the following:
- That you receive credit from us;
- The type and amount of credit that you receive;
- The terms and conditions of your credit;
- Your payment history;
- Any default or failure to make payment; and
- Any behavior that is considered by us to be seriously adverse, such as fraud or evasion of repayment obligations.
When we give your information to a credit reporting body, it may then be included in credit reports that the credit reporting body then gives to other credit providers. Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments. That sort of information may affect your ability to get credit from other credit providers.
Credit reporting bodies are required to have a policy explaining how they manage your personal information. You can contact these credit reporting bodies for more information about their policy or information about you that they may hold.
We will not disclose credit information or credit eligibility information to entities that do not have an Australian link.
Contact credit reporting bodies if you think you have been the victim of a fraud
You are entitled to request that a credit reporting body not use or disclose credit reporting information they hold about you in circumstances where you reasonably believe that you have been or are likely to be a victim of fraud, including identity-related fraud. The period while this applies is called a “ban period”. You can make such a request to any of the credit reporting bodies listed above.
Taking care of your Personal Information
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorized access, modification or disclosure. Some of the ways we do this are:
- Physical security of business premises;
- Confidentiality requirements of our employees;
- Record management policies;
- Security measures for access to our systems;
- Only giving access to personal information to a person who reasonably requires access to it in order to perform their duties;
- Control of access to our buildings; and
- Electronic security systems, such as firewalls and data encryption on our websites.
We can store personal information physically or electronically with third party data storage providers. If we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses of it.
We’ll only keep your information for as long as we require it for the purposes that it was collected for. We’re also required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified. We will retain information and use it to ensure that we identify persons who have, in the past, failed to meet their repayment obligations to Capricorn, either directly or through their association with a business.
Accessing your Personal and Credit Information
Upon request we will give you access to your personal information in a reasonable period of time unless there are certain legal reasons for why we can’t. We will give you access to your information in the form you want it if it’s reasonable and practical to do so. We may charge you for our reasonable expenses relating to giving you access, but we’ll always notify of any expenses first. In certain circumstances we are not able to give you access to your personal information. For example this may include when:
- We reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
- The access would have an unreasonable impact upon the privacy of other individuals; or
- The request for access is frivolous or vexatious; or
- The access would be unlawful or would prejudice any legal investigations If we can’t provide your information in the way you’ve requested, we will tell you why in writing and attempt to find an alternative way in which to satisfy your request. If you are not happy with the way we have dealt with your request you can complain.
If you request access to credit information about you that we’ve got from credit reporting bodies (or based on that information), you have the following additional rights. We must:
- Provide you access to the information within 30 days (unless unusual circumstances apply);
- Make the information clear and accessible; and
- Ask you to check with credit reporting bodies what information they hold about you. This is to ensure it is accurate and up-to-date. We are not required to give you access to this information if it would:
- Be unlawful; or
- Harm the activities of an enforcement body (e.g. the police). We may also restrict what we give you if it would harm the confidentiality of our commercial information.
If we refuse to give access to any credit eligibility information, we will tell you why in writing. If you have concerns, you can complain.
Correcting your personal information
We take reasonable steps to make sure that the personal information we collect, uses or discloses is accurate, complete and up-to-date. We also take reasonable steps to ensure that personal information it holds is relevant having regard to the purpose for which it was collected. Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s inaccurate, out of date, incomplete, irrelevant or misleading. If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organization which made the mistake. If we’re able to correct the information, we’ll let you know within a reasonable period of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing. If we’re unable to correct your information, we’ll explain why in writing within a reasonable period of making this decision. If you have concerns about the way we have handled a request to correct information you can complain.
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that has been agreed by you. If we can’t make corrections within a 30 day time frame or the agreed time frame, we will:
- Let you know about the delay, the reasons for it and when we expect to resolve the matter;
- Ask you to agree in writing to give us more time; and
- Let you know you can complain to the Office of the Australian Information Commissioner.
Resolving your privacy issues
If you believe that there has been a breach of privacy or you do not agree with a decision we have made about your access to or correction of personal information, you can make a complaint to us through our Privacy Officer on the details below under the heading “Contact Us” and we will endeavor to resolve it by following our internal complaint resolution process. If your complaint relates to how we handled an access or correction request then you may take your complaint directly to the Office of the Australian Information Commissioner. You are not required to let us try to fix it first, although we would welcome you giving us the opportunity to try and do so. If your complaint is about other things in relation to your personal information, we will let you know how we will deal with it within 7 days. If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to the Office of the Australian Information Commissioner.
If your complaint relates more generally to a product or service provided by Outdoor Instant Shelters then it may be more appropriate to raise that complaint under the separate Complaints and Dispute Handling Process that each of those businesses has.
For further information about privacy issues in Australia and protecting your privacy, you may visit the Office of the Australian Information Commissioner website at http://www.oaic.gov.au/privacy.
If you still feel your privacy issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner.
The Office of the Australian Information Commissioner
Phone: 1300 363 992
Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
We care about your privacy and we always welcome your feedback. Please contact us if you have any questions or comments about the way we handle personal information.
Fax: +61 3 9583 0721 (Australia)
Mail: Outdoor Instant Shelters, Factory 22, 354 Reserve Road, Cheltenhan VIC 3192
Date published (20/01/2015)