Privacy
Policy.

Protect Underwriting Pty Ltd (ABN 21 095 612 276; AFSL 241055) (“Protect”, “we”, “us” or “our”) is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy describes our current practices in relation to the collection, handling, use, and disclosure of your personal and sensitive information.

Personal information includes a broad range of information, or an opinion, that could identify an individual. Sensitive information is a subset of personal information that includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional trade or association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information or biometric information.

We collect personal information that is required by law and necessary to provide and manage the products or services we offer.

Depending on the product or service we are providing to you, we may collect information that includes your name and contact details, age, gender, information about your profession, assets and liabilities, financial situation, payment and account details, insurance and claims history and technical information about your IP address, visits to our website and the device you use. We may ask you to provide photographs or grant us access to your mobile device or certain app data, but will only ever do this with your express consent.

In certain circumstances, we may collect sensitive information about your membership with a professional association, health, medical history or criminal record. We only collect sensitive information with your express consent or where required by law.

We may collect information in a variety of ways such as directly through our website, online portals, or via telephone and email correspondence and via Application Programming Interface (API) to external parties.

We may collect your information from:

• intermediaries such as your insurance broker, authorised representatives, or co-insureds.
• third parties, including insurers, other underwriting agencies, credit reporting bodies, the Insurance Reference Services (IRS) database.
• partner providers with whom you have separate relationships and, with your express permission, where they share data with us relevant to our provision of services to you. Partners who pass data to us may also be data controllers of that data. They will process personal data in accordance with our Privacy Policy as part of our agreement with them.
• public sources such as information from publicly available registers or government departments.

3.1Security of your personal information

We take all reasonable steps to protect personal information under our control from misuse, interference and loss and from unauthorised access, modification or disclosure.

We hold your personal information in secure security systems, electronic databases, digital records, telephone recordings and in hardcopy or paper files. We retain information for as long as required by law (generally 7 years) before securely destroying or de-identifying it.

The reasonable steps we take to protect your personal information from misuse, unauthorised access, modification, disclosure and loss include:

• Maintaining and continually improving IT security protocols.
• Requiring any third-party providers to have adequate measures to protect your personal information.
• Ensuring our premises are secure.
• Destroying or de-identifying information as required.
• Providing training to employees and representatives regarding their privacy obligations.
• Providing authorised persons with user identifiers, passwords or other access codes.

We collect and use your information for the primary purpose of carrying out the core functions of our business. This includes:

• Providing quotes, assessing risks, and binding insurance cover.
• Administering policies, processing payments and handling complaints
• Facilitating claims processing
• Conducting internal audits and research to improve our products
• Assisting Insurers and Brokers with the development and provision of insurance products and services
• Managing, training and developing our employees and representatives.
• Regulatory and legal authorisations and requirements

We may hold, use and disclose your information for:

• The purpose of identifying you.
• The primary purpose for which the information was collected (please see “Why we collect your personal information” above)
• A purpose for which you have consented.
• Telling you about other products or services we think might be of interest to you
• Any other purpose authorised or required by an Australian law, court or tribunal.

5.1Who do we disclose your personal information to?

To provide our services, we may disclose your information to:

• Our related companies
• Our underwriters
• Third party service providers with whom we have contracted to provide services such as investigative, information technology, legal, audit and monitoring, payment processing, analytical, marketing, and debt collection services.
• Any relevant distributors, or intermediaries connected with your policy such as your advisor or broker.
• Your financier or credit institution.
• Credit reporting agencies.
• Hospitals and health professionals.
• The Australian Financial Complaints Authority or any other relevant dispute resolution body.
• Policy or product holders or others who are authorised or noted on the policy as having a legal interest.
• Other insurers, financial services providers, premium funders, loss assessors and related claims management services.
• Government regulators and enforcement bodies.
• Your representatives such as legal advisers or family members authorised to act on your behalf.

5.2Anonymity

Where possible, you may deal with us anonymously or via a pseudonym (e.g., for a general enquiry). However, we cannot provide formal quotes or issue policies without your identifying information.

5.3Overseas Recipients

We may disclose information to service providers or underwriters located overseas (including countries such as the UK, USA, and NZ). We take reasonable steps to ensure these recipients handle your data in accordance with Australian privacy standards.

For example, if we seek insurance terms from an overseas insurer (e.g. Lloyd’s of London), your personal information may be disclosed to the insurer. If this is likely to happen, we inform you of where the insurer is located, if it is possible to do so.

Australian and overseas insurers acquire reinsurance from reinsurance companies that are located throughout the world so in some cases your information may be disclosed to them for assessment of risks and in order to provide reinsurance to your insurer. We do not make this disclosure. This is made by the insurer (if necessary) for the placement for their reinsurance program.

We aim to protect your personal information by taking reasonable steps to ensure that each overseas provider has similar protections in relation to privacy or that we enter contractual arrangements with the recipient that safeguards and ensures compliance with Australian privacy law and this privacy policy. However, in some cases we may not be able to take reasonable steps to ensure they do not breach the Privacy Act and they may not be subject to the same level of protection or obligations that are offered by the Privacy Act.

6.1Accessing your personal information

You may request access to the information we hold about you by contacting us at info@protectunderwriting.com.au. You may be required to provide further information to us to identify yourself. We do not charge a fee for making a request, though we may charge for the reasonable cost of retrieving and providing the information.

We may refuse your request in a number of circumstances, such as:

• Giving access to the information would pose a serious threat to the life, health or safety of a person.
• Giving access would have an unreasonable impact on the privacy of a person.
• The information relates to existing or anticipated legal proceedings and would not be available under the discovery process.
• Where denying access is required or authorised by an Australian law or court order.

6.2Correcting your personal information

We rely on the information we hold about you to efficiently conduct our business of providing products and services. For this reason, it is very important that the information we collect from you is accurate, complete and up to date. If your information changes, please inform us by contacting us at info@protectunderwriting.com.au so that we may update our records.

If you believe we have breached this Policy or the APPs or Privacy Act, please contact us at complaints@protectunderwriting.com.au. We will and endeavour to respond with a final decision within 30 calendar days of you first making the complaint if all necessary information has been provided. If you feel your complaint has not been resolved, you may contact:

The Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• By phone: 1300 363 992
• By email: enquiries@oaic.gov.au
• In writing: GPO Box 5218, Sydney NSW 2001

By applying for our products or using our services, you consent to the collection and use of your information as set out in this policy. We may update this policy from time to time; any changes will be published on our website.