Privacy policy

Last updated 11 December 2018

Introduction

This is the Privacy Policy of “HUBconnect”. In this Privacy Policy “HUBconnect”, “we”, “our” and “us” have the same meaning.

Protecting your personal information is important to us. We respect your privacy and we are committed to protecting your privacy. We are bound by, and committed to supporting, the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy explains the way we collect, maintain and handle your personal information.

If you give us personal information about another person, you represent that you are authorised to do so and agree to inform that person who we are, that we will use and disclose that information for the relevant purposes set out below, and that they can access the information we hold about them.

Your personal information will be treated strictly in accordance with the Australian Privacy Principles contained within the Privacy Act, as amended from time to time.

This policy outlines for our customers and prospective customers:

  • the kinds of personal information that we collect and hold;
  • how HUBconnect will collect and hold such personal information;
  • the purposes for which we collect, hold, use and disclose personal information;
  • how our customers or prospective customers may access their personal information, held by HUBconnect;
  • how our customers or prospective customers raise a complaint about a breach of the Australian Privacy Principles, and how we will deal with such a complaint; and
  • whether we will or is likely to disclose personal information to overseas recipients, and to which countries the information may be sent.

Information HUBconnect collects

Personal information is information that can identify you. We must obtain personal information about you so we can provide the most appropriate products and services to you, provide information and marketing material to you and satisfy certain legislative and regulatory requirements.

We will only collect personal information that is necessary to provide our products and services to you, including information needed to comply with legal and regulatory requirements.

We may collect the following types of personal information:

  • name;
  • email address, mailing or street address and other contact details;
  • date of birth;
  • information to verify your identity such as your driver’s licence number; and
  • information about other products or services of ours or any related body corporate that you may hold or use.

We are required to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth). We are authorised to collect tax file numbers under tax laws and the Privacy Act.

Telephone recording

HUBconnect or third parties providing connected services, may record telephone conversations. If HUBconnect does record conversations, this will be disclosed prior to connecting to a HUBconnect staff member and you will be given an opportunity to refuse such recording.

Cookies

A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. We may use cookies and other technologies to grant you access to certain parts of the website and to monitor traffic patterns, manage advertising and other activities.

Cookies may also be used for other purposes on the HUBconnect website.  In each case, none of the information collected can be used to identify you personally but rather identifies your computer. You can configure your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it each time.

If you disable the use of cookies on your web browser or remove or reject specific cookies from the website or linked sites, then you may not be able to gain access to all of the content and facilities within HUBconnect’s website.

We use cookies on this website for the following purposes:

  • Analytical purposes: Analytical cookies allow us to recognise, measure and track visitors to the website. This helps us to improve and develop the way the website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.
  • Usage preferences: Some of the cookies on the website are activated when visitors to our sites make a choice about their usage of the site. Our website then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of the site to the individual user.
  • Terms and conditions: We use cookies on the website to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our website. This helps to improve the user’s experience of the site – for example, it avoids a user from repeatedly being asked to consent to the same terms.
  • Session management: The software that runs the website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.
  • Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

Not providing your personal information

If you do not give us your personal information some or all of the following may happen:

  • we may not be able to provide you with, or subsequently administer, some or all our products or services; or
  • we may not be able to provide you with information about our products and services.

How HUBconnect will collect and hold such personal information

Personal information will generally be collected directly from you through the use of any of our standard forms, through the HUBconnect portal, via email, or through a telephone conversation with you. For example, we may collect personal information from you using any of these methods when:

  • you subscribe to any of our information or other services;
  • you sign up for or log into the HUBconnect portal; or
  • you give information or other material to any part of HUBconnect.

There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.

The purposes for which we collect, hold, use and disclose personal information

Other than as required by law, we will generally only collect, hold, use and disclose your personal information for the purposes of:

  • assessing your application and providing our services to you;
  • communicating with you in relation to your use of our services;
  • monitoring, auditing, evaluating and otherwise administering our services;
  • providing you with access to protected areas of our websites;
  • providing continuous service to you and to conducting business processing functions including by providing personal information to our related bodies corporate, contractors, service providers or other third parties;
  • assisting with the administrative, marketing (including direct marketing), planning, product or service development, quality control or for research by us and our contractors and service providers; and
  • facilitating our internal business operations, including the fulfilment of any legal requirements.

We will only use or disclose personal information we collect about you for the purpose for which it was collected, or related purposes which would reasonably be expected, or as otherwise permitted by the Australian Privacy Principles.

We will not sell your personal information to other organisations. Nor will we provide organisations outside our group with your personal information for purposes unrelated to the provision of services to you.

Personal information may be disclosed to external parties including the following:

  • agents, contractors, or external service providers appointed by us (such as auditors or other professional advisers);
  • your nominated financial adviser and/or accountant, unless you instruct us otherwise in writing;
  • your personal representative, attorney or agent (but only with your written consent);
  • a government or regulatory body where required or authorised by law (such as ASIC or a law enforcement agency);
  • financial institutions and other similar organisations that we deal with in the course of our corporate activities, or those that are nominated by you;
  • external service providers and professional advisers that provide services to us including electronic identification services;
  • credit reporting agencies, any credit provider name in the report and any credit provider whose details have been provided to us by you;
  • third party service providers to whom you or your financial adviser(s) ask us to provide your personal information or to whom we are required to provide your personal information to perform a request from you or your financial adviser(s) (for example, for the purpose of opening an account for you with that third party service provider); and/or
  • in order to comply with a court order or in conjunction with court proceedings.

Disclosure of personal information overseas

We do not disclose your personal information to persons located outside of Australia.

External websites

Our website may contain references or links to other external websites. Those references or links may in turn refer or link to other references or links. We, our directors, officers, employees or agents are not responsible to you or any person for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.

Direct marketing

We may also send you direct marketing communications and information about our products and services that we expect may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email. By using our services, you consent to us sending you those direct marketing communications by any of those methods. At any time you may opt-out of receiving marketing communications from us by contacting us (see contact details below) or by using the opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from the relevant mailing list.

Please note that, if we are currently providing you with services or products, we will still need to send you essential information about your account, the relevant services or products and other information required by law.

Keeping your personal information secure

We invest considerable resources to keep your personal information secure from misuse, loss, interference, unauthorised access, modification or disclosure. Access to and the use of personal information is regulated to prevent misuse or unlawful disclosure of the information. We use security procedures such as encryption, firewalls, intrusion detection and anti-virus technology to prevent unauthorised access. We also use valid log-in identification and password based security to achieve electronic information security.

We retain information for so long as may be necessary to respond to issues that may arise at a later date, and longer in appropriate cases where required by law. When personal information is no longer required by us, it is destroyed or de-identified.

As our website is linked to the internet, and the internet is inherently insecure, we cannot give any assurance to any person regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Accessing personal information held by HUBconnect

Under the Privacy Act, you have the right to obtain a copy of any personal information which we hold about you and to advise us of any inaccuracies.

To make a request, you will need to write to us verifying your identity and specifying what information you require. We will try to respond to your request within 7 days. If the information sought after is extensive we may charge a fee to cover cost.

In normal circumstances we will give you full access to your information. However, there may be times where some legal reason requires us to deny access, such as where granting access would interfere with the privacy of others or it would result in a breach of confidentiality. If access is denied, we will give you written reasons for any refusal.

We aim to ensure that the personal information held about you is accurate, complete and up to date. You should contact us as soon as possible if any of your details change. You can also contact us at any time and ask us to correct personal information you if you feel the information we have about you is inaccurate or incomplete. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it. We will also give you a written notice that sets out our reasons for refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

How to raise a complaint about a breach of the Australian Privacy Principles, and how HUBconnect will deal with such a complaint

If you believe that your privacy has been breached, or if you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

If, after this process, you are not satisfied with our response, you can submit a complaint to the Office of the Australian Information Commissioner.  To lodge a complaint, visit the ‘Complaints’ section of the Australian Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Australian Information Commissioner’s office.

The Privacy Officer

HUBconnect

GPO Box 529

SYDNEY NSW 2001

Email: complaints@hub24.com.au

Phone: 1300 370 095

Changes to this Privacy Policy

From time to time, we may change this Privacy Policy. All updates to the privacy policy will be made available to customers and prospective customers on our website.

Contact Details

If you have any questions regarding our Privacy Policy or handling of information, please contact us.

Should you wish to obtain further information about privacy you can do so by visiting the Office of the Australian Information Commissioner (OAIC) website www.oaic.gov.au.