Kubio Group Pty Ltd (Kubio Group) respects the privacy of the people we deal with and we uphold high standards of privacy practice and security. This policy explains how we handle personal information and how we interact with you online.
Sometimes it is necessary for us to collect ‘personal information’ such as names, identity details, photos, contact details, transaction information and other personal details where required (such as gender, marital status and financial information).
Your broker may instruct us to collect and retain your credit information on their behalf. We may do this through a credit reporting body (only where you have provided consent for your broker to do so). References to ‘personal information’ throughout this policy includes your credit information. Please refer to the Credit Information annexure for further details relating to our handling of personal and credit information obtained from credit reporting bodies.
We may collect health information provided to us by you or your broker in assessing certain claims, such as hardship. We do not use or share that information for any purpose other than for storage and customer maintenance on behalf of your broker.
Generally, we do not collect sensitive information about you unless required by law or where you consent for us or your broker to do so. Sensitive information includes information relating to:
We may collect information about your affiliation with certain organisations, such as professional associations.
We collect personal information about you which is reasonably necessary to:
Without such information, we may not be able to process your application or provide you with an appropriate level of service.
We collect personal information about you directly from you – this can be in person, in documents you give us, from telephone calls, emails, competitions you enter, your access to our website or from transactions you make.
We also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).
We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.
We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints – this includes interactions you make with your broker.
We use personal information about you for the purpose for which it was provided to us, including to:
We may also:
While we may sometimes share personal information with companies we do business with (e.g. for product development, joint venture or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.
While we typically only share personal information within Kubio Group and with your nominated broker or adviser, we may disclose personal information outside Kubio Group:
We may also disclose your personal information (on a confidential basis) in connection with proposed acquisitions, mergers, divestments, and the management of any parts of our business or assets.
In some circumstances the parties to whom we disclose personal information may operate outside of Australia – this includes locations in the countries listed in the Appendix. Where this occurs, we take steps to protect personal information against misuse or loss.
We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
We use security procedures and technology to protect the information we hold. Access to and use of personal information within Kubio Group seeks to prevent misuse or unlawful disclosure of the information – this includes appropriate information technology infrastructure to segregate and control data as well as internal policies, auditing, training and monitoring of staff. If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
Where the personal information we collect is no longer required, we delete the information or permanently de-identify it in accordance with relevant laws and our records management policy.
You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
When you visit Kubio Group’s websites you will browse anonymously unless you have logged into a client portal or accessed the website from a personalised communication from Kubio Group.
Once you have logged into a Kubio Group portal, accessed our website from an e-mail or other personalised communication sent to you, or provided us with personal information by completing a form online, we may be able to identify you and we may combine that with other information in order to provide you with a better online experience. If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).
A 'cookie' is a packet of information placed on a user's computer by a website for record keeping purposes. While cookies are not considered personal information, they are generally used on Kubio Group sites to:
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check ‘Help’ menu of your browser to learn how to change your cookie preferences).
If you have any questions or complaints regarding privacy or information handling, please write to firstname.lastname@example.org or contact us by phone on 0400 255 349. Please mark communications to the attention of our Privacy Officer. We will respond to let you know who will be handling your matter and when you can expect a further response.
If your concerns are not resolved to your satisfaction, you may be able to escalate your complaint to an external dispute resolution scheme or to a regulatory authority. We can provide details of the appropriate scheme/regulator for you, as these may vary by jurisdiction or product.
You may also contact the Office of the Australian Information Commissioner as follows:
Phone: 1300 363 992 Address: GPO Box 5218, Sydney NSW 2001
Policy updated July 2016
Personal information may be disclosed to third parties in jurisdictions including: Australia; India; Japan; Malaysia; New Zealand; Philippines; Singapore; United Kingdom; United States of America.
Our role in the credit reporting process is limited to requesting a credit report on behalf of your broker. Your lender will have further details about what information they report and avenues for dispute resolution that may be available. While we don’t report your credit information to credit reporting bodies, you should be aware of the following.
The types of credit-related personal information (“credit information”) we collect may include:
This includes information about your arrangements with other credit providers.
We collect this information from you, your broker, your account activity and from third parties including public sources, our related companies, referrers, agents, your adviser(s) and our service providers including credit reporting bodies and information service providers.
Credit reporting bodies may use credit information to maintain information about individuals and provide that information to credit providers for their credit assessments. Your credit provider may also report to a credit reporting body where you fail to meet your payment obligations in relation to consumer credit or you commit a serious credit infringement.
We may exchange credit information with the following credit reporting bodies:
You can contact those credit reporting bodies or visit their websites to see their policies on the management of credit information, including details of how to access the credit information they hold about you. You also have the right to request credit reporting bodies not to: