Privacy Policy

Who Are We?

“We”, “us” and “our” refer to beInformed Group Pty Ltd trading as “beCarWise”, ACN 154 478 725.

Respecting Your Privacy

This privacy policy sets out how we collect and manage personal information about individuals, directors and organisational representatives, and contains our privacy collection statement. We respect your personal information, and this Privacy Policy explains how we handle it. This Policy covers beInformed Group Pty Ltd.

What Personal Information Do We Collect And Hold?

General Information

The types of information that we collect and hold about you could include:

• when you call us, we may collect statistics about your call including; number, date and time;
• we may also record or monitor telephone calls to and from our company for verification, substantiation and quality assurance purposes;
• identification information such as your name, postal or email address, telephone numbers, and date of birth;
• other contact details such as social media handles;
• employment details – employer name and address, profession, occupation, job title and employee number;
• financial details such as your income, assets and liabilities, expenses and medicare number;
• bank account numbers and credit card details;
• credit information such as details relating to credit history, credit capacity, and eligibility for credit (‘credit worthiness’); and
• other information we think is necessary.

Information From A Credit Reporting Body

When we are checking your credit worthiness and at other times, we might collect information about you from credit reporting bodies.

What Sensitive Information Do We Collect?

Sometimes we need to collect sensitive information about you, for instance in relation to some insurance applications. This could include things like medical checks, medical consultation reports or other information about your health. Unless required by law, we will only collect sensitive information with your consent.

When The Law Authorises Or Requires Us To Collect Information

We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions which require us to collect personal information, like the National Consumer Credit Protection Act.

What Do We Collect Via Your Website Activity?

If you use our website or our programs, we may monitor your use of the website and our programs to ensure we can verify you and you can receive information from us, and to identify ways we can improve our services to you. We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However for all confidential matters, we will ensure we interact with you via a secure forum. To improve our services and products, we sometimes collect de-identified information from users of our website or our programs. That information could include IP addresses or geographical information to ensure your use of our website and our programs is secure. We also collect de-identified information if you use our website or our programs. Although the information collected does not identify an individual, it does provide us with useful statistics so that we can analyse and improve our web services and programs. If you disclose information through our websites, you may receive cookies, which are data that a website transfers to a users’ hard drive for record-keeping purposes. Cookies can facilitate a users’ ongoing access to and use of a website. The cookies allow us to track website usage patterns and to compile data that can help us improve our website content. If you do not want us to collect information by use of cookies, there is a simple procedure available in most browsers that allows you to deny cookies. However, please note cookies may be necessary for us to provide some web-based features; like services for which a person must register. For more information on how we use cookies and tracking tags see: www.beCarWise.com.au

How Do We Collect Your Personal Information?

How We Collect And Hold Your Information

We understand that your personal information needs to be looked after and is not something you leave lying around for just anybody to take. So unless it is unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date. There are many ways we seek information from you. We might collect your information when:

• an Employee of the company fills out your application for credit or insurance along with information provided to support such an application. That information may include a credit report about you that you obtain;
• we may collect information from a credit reporting agency including a credit report;
• we may receive information from a third party referrer containing information about you and / or a product or service you may be interested in.

How We Collect Your Information From Other Sources

Sometimes we collect information about you from other sources. We do this only if it’s necessary to do so. Instances of when we may need to include where:

• we can’t get hold of you and we rely on publicly available information to update your contact details;
• we need information from an insurer about an insurance application you make through us; and
• at your request, we exchange information with your legal or financial advisers or other representatives.

What If You Don’t Want To Provide Us With Your Personal Information?

If you do not provide your personal information to us, we may not be able to:

• provide you with the product or service you want;
• manage or administer your product or service;
• verify your identity or protect against fraud; or
• let you know about other products or services that might better meet your financial, e-commerce and lifestyle needs.

How We Collect And Hold Your Credit Information

We will collect your credit information from details included in an application for finance or insurance. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:

• other credit providers;
• your referees;
• your agents and other representatives like your accountants or solicitors;
• bodies that issue identification documents to help us check your identity; and
• our service providers involved in helping us to provide credit or to administer credit, including our debt collectors and our legal advisers.

What Do We Do When We Get Information We Didn’t Ask For?

Because we are a substantial organisation, people often share information with us we have not sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.

When Will We Notify You That We Have Received Your Information?

When we receive personal information, other than from you directly, we will take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint. Sometimes we collect your personal information from third parties. 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.

How Do We Take 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 unauthorised access, modification or disclosure. Some of the ways we do this are:

• confidentiality requirements of our employees;
• document storage security policies;
• security measures for access to our systems;
• only giving access to personal information to a person who is verified to be able to receive that information;
• 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. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.

What Happens When We No Longer Need Your Information?

We will only keep your information for as long as we require it for our purposes. We are also required to keep some of your information for certain periods of time under law, such as the Corporations Act, for example. When we no longer require your information, we will ensure that your information is destroyed or de-identified.

What Are The Main Reasons We Collect, Hold And Use Your Information?

Because we offer a range of products and services, collecting your personal information allows us to provide you with the products and services you have asked for. This means we can use your information to:

• provide you with information about products and services;
• answer your enquiries and respond to any complaints made by you;
• keep your records up to date in our systems;
• perform our business administration including: record keeping, risk management, accounting, planning, systems development, testing, staff training and statistical analysis;
• conduct customer satisfaction surveys; and
• comply with any law, rule, regulation, request or direction from any governmental authority or regulator.

We may share your personal information with our contractors and service providers for any of the purposes outlined above.

Can We Use Your Information For Marketing Our Products And Services?

Given our organisation’s scope, we like to share what we know about our products and services with you. We may use or disclose your personal information to let you know about products and services from across the business that might better serve your financial, e-commerce and lifestyle needs, including running competitions or promotions and other opportunities in which you may be interested. We may conduct these marketing activities via email, telephone, SMS, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites). We will always let you know that you can opt out from receiving our third party or Group program marketing offers. Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs. With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation outside of the company.

Yes, You Can Opt-Out

You can let us know at any time if you no longer wish to receive direct marketing offers from the organisation (see ‘Contact Us’). We will process your request as soon as practicable.

What Are The Other Ways We Use Your Information?

We have just told you some of the main reasons why we collect your information, so here is some more insight into the ways we use your personal information including:

• giving you information about a product or service;
• considering whether you are eligible for a product or service;
• processing your application and providing you with a product or service;
• administering the product or service we provide you, which includes answering your requests and complaints, varying products and services and managing our relevant product portfolios;
• identifying you or verifying your authority to act on behalf of a customer;
• telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, mail, or any other electronic means including via social networking forums), unless you tell us not to;
• assisting in arrangements with other organisations in relation to a product or service we make available to you;
• allowing us to run our business and perform administrative and operational tasks, such as:
  • training staff;
  • developing and marketing products and services;
  • risk management;
  • systems development and testing, including our websites and other online channels;
  • undertaking planning, research and statistical analysis;
  • determining whether a beneficiary will be paid a benefit;
  • preventing or investigating any fraud or crime, or any suspected fraud or crime;
  • as required by law, regulation or codes binding us;
  • maintaining a database of Employees, Referrers and Third Parties, to, amongst other things, track and make payments of commissions and other amounts to them;
  • managing our relationship with you;
  • managing our relationships with our panel of lenders and insurers;
  • investigating and dealing with suspected or actual unlawful activity;
  • assisting in improving industry standards relating to engaging in credit activities;
  • assisting with recovering amounts owing to us; and
• for any purpose for which you have given your consent.

Who Do We Share Your Personal Information With?

To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we may use your information.

Sharing At Your Request

We may share your personal information with:

• your representative or any person acting on your behalf (for example, accountants or solicitors);
• your referees to confirm details about you.

Sharing With Third Parties

We may share your personal information with third parties outside of the company, including:

• our employees;
• our panel of lenders;
• insurers and reinsurers in relation to insurance products and services requested by you;
• motor vehicle dealers in relation to sourcing or remarketing your motor vehicle;
• fuel companies to enable those companies to record fuel, servicing and tyre purchases made by you;
• your employer;
• industry bodies of which we are a member;
• those involved in providing, managing or administering the product or service we provide to you;
• authorised representatives of the companies who sell products or services on our behalf;
• medical professionals, medical facilities or health authorities who verify any health information you may provide;
• valuers, insurers (including lenders’ mortgage insurers and title insurers) , re-insurers, claim assessors and investigators;
• brokers or referrers who refer your application or business to us;
• loyalty programme partners;
• other financial institutions, such as banks;
• organisations involved in debt collecting, including purchasers of debt;
• fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
• organisations involved in surveying or registering a security property or which otherwise have an interest in such property;
• real estate agents;
• government or regulatory bodies (including the Australian Securities and Investments Commission and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
• our accountants, auditors or lawyers and other external advisers;
• guarantors and prospective guarantors of your obligations to us;
• organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
• organisations that participate with us in payments systems including merchants, payment organisations and organisations that produce statements for us;
• our joint venture partners that conduct business with us;
• organisations involved in a corporate re-organisation or transfer of company assets or business;
• organisations that assist with our product planning, research and development;
• mailing houses and telemarketing agencies who assist us to communicate with you;
• other organisations involved in our normal business practices, including our agents and contractors; and
• where you have given your consent.

Sharing Outside Of Australia

The company runs its business in Australia. The company may need to share some of your information (including credit information) with organisations outside Australia. Sometimes, we may need to ask you before this happens. A list of those countries include: Germany, New Zealand, United Kingdom, Philippines, India, Singapore, Japan and the United States. We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

How Do You Access Your Personal Information?

How You Can Generally Access Your Information

We will always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone. We will give you access to your information in the form you want it where it is reasonable and practical (such as a copy of a phone call you may have had with us – we can put it on an electronic medium for you). We may charge you a small fee to cover our costs when giving you access, but we will always check with you first. We are not always required to give you access to your personal information. Some of the situations where we do not have to give you access include when:

• we believe there is a threat to life or public safety;
• there is an unreasonable impact on other individuals;
• the request is frivolous;
• the information would not be ordinarily accessible because of legal proceedings;
• it would prejudice negotiations with you;
• it would be unlawful;
• it would jeopardise taking action against serious misconduct by you;
• it would be likely to harm the activities of an enforcement body (e.g. the police); or
• it would harm the confidentiality of our commercial information.

If we cannot provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.

How Do You Correct Your Personal Information?

How We Correct Your Information

Contact us if you think there is something wrong with the information we hold about you and we will try to correct it if it is:

• 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 will try and help where we can – if we cannot, then we will let you know in writing.

How Do You Make A Complaint?

How Do You Generally Make A Complaint?

If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us. You can contact us by using the details below: The Compliance Officer beInformed Group Pty Ltd PO Box 300 Chatswood NSW 2067 Telephone: 1300 734 500 Facsimile: 02 9475 1425 Email: TalkToUs@beCarWise.com.au We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.

Further Options

If you have contacted us by phone or in person and feel your issue still has not been resolved, the next step is to contact our Customer Resolutions team. Complaints, Disputes & Compliance Officer beInformed Group Pty Ltd PO Box 1207 Crows Nest NSW 1585 Telephone: 1300 734 500 Facsimile: 02 9475 1425 Email: TalkToUs@beCarWise.com.au

Need More Help?

If you still feel your issue has not been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner: Online: www.oaic.gov.au/privacy Phone: 1300 363 992 Email: enquiries@oaic.gov.au Facsimile: +61 2 9284 9666 Mail: GPO Box 5218, Sydney NSW 2001 or GPO Box 2999, Canberra ACT 2601

Contact Us

We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback. You can contact us by using the details below: beInformed Group Pty Ltd PO Box 300 Chatswood NSW 2067 Telephone: 1300 734 500 Facsimile: 02 9475 1425 Email: TalkToUs@beCarWise.com.au

What If You Want To Interact With Us Anonymously Or Use A Pseudonym?

If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way however as we are often governed by strict regulations that require us to know who we’re dealing with. In general, we will not be able to deal with you anonymously or where you are using a pseudonym when:

• it is impracticable; or
• we are required or authorised by law or a court/tribunal order to deal with you personally.

What Do We Do With Government-Related Identifiers?

In certain circumstances we may be required to collect government-related identifiers such as your medicare number. We will not use or disclose this information unless we are authorised by law.

Changes To This Privacy Policy

This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website.