The de Bruin Group includes:
1 March 2015
At the de Bruin Group (“the de Bruin Group”, “our” “we” or “us”) your privacy is important to us. We are committed to protecting your privacy when managing your personal and credit information (collectively “personal information”). We have policies and procedures to ensure that all personal information is handled carefully and securely in accordance with our obligations under the Privacy Act 1988 (Cth) (“Privacy Act”), including the Australian Privacy Principles (“APPs”)
The types of information that the de Bruin Group collects from you will depend on the circumstances of collection and on the service that we are providing to you.
The type of personal information collected will be directly related to the specified purpose it has been collected. How much of your personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in the de Bruin Group being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.
Our Website(s) are directed to persons over the age of 18. We do not knowingly collect personal information from anyone under the age of 18, unless they have applied for employment with us.
The personal information we may collect about you includes:
The credit related personal information which we may collect includes:
You acknowledge that the personal information we collect from you is your own information or information which you have been authorised to provide us.
The de Bruin Group does not generally collect sensitive information about you as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information. However, subject to obtaining your prior consent, the de Bruin Group may collect sensitive information from you in the course of considering an application for employment.
Information we collect automatically
The type of information we may collect by automated means includes:
The information we collect automatically is also used for statistical and administrative purposes. Analysing the way in which visitors utilise our Website(s) enables us to improve our services. The information is not used in any way to uniquely identify an individual and we do not collect information about the identity of the visitors unless they voluntarily provide that information. Users or their browsing activities will not be identified except in the event that any law requires us to disclose or permit a law enforcement agency to inspect the service provider's logs.
Personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way.
The de Bruin Group collects your personal information when you deal with us directly, including via our Website(s) or our Facebook page, via forms or correspondence (ie by mail or email), over the phone or in person.
Examples of how we collect your personal information include:
The de Bruin Group may also collect personal information through our related bodies corporate and our third party service providers (such as data relating to survey responses) where it is unreasonable or impracticable for us to directly collect information from you so that we may provide a better or more relevant product to you.
In addition to the above methods, we may also collect credit related information from other credit providers, such as trade references, subject to any restrictions at law. The de Bruin Group does not collect any credit related personal information from credit reporting bodies.
Use of personal information
The de Bruin Group will use the personal information you have provided to us for the purpose for which you provided it or a related secondary purpose which you would reasonably expect. The de Bruin Group will not use it for any other purpose without your consent, unless permitted or required by law.
Generally, we will use your personal information for the following purposes:
The de Bruin Group will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities, so that they can provide you directly with marketing material about their products and services.
Any direct marketing materials that you receive from us via email (including newsletters and special promotions) may utilise open tracking so that we can monitor delivery and receipt of the material.
The de Bruin Group will provide you with the opportunity to opt out of receiving marketing materials at the time of collection of your personal information and at any time afterwards. You may opt out of receiving marketing materials from us by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below. If you have registered with us online via any online shopping facility or e-newsletter service, you will also be able opt out of receiving future marketing materials at any time by logging into the account settings area of our Website once it has been established.
Use of anonymous information
The de Bruin Group gathers anonymous information to:
The de Bruin Group may disclose your personal information to:
Generally, the de Bruin Group will not disclose your personal information to recipients outside of Australia. However, personal information by be disclosed to overseas based marketing agencies, such as MailChimp based in the United Stated of America, for the purpose of providing marketing activities on our behalf. If you consent to receiving direct marketing materials from us you will be taken to have consented to the disclosure of your personal information to an overseas recipient for that purpose. By providing such consent you acknowledge that if the recipient handles your personal information in breach of the APPs, we will not be accountable for the recipient’s mishandling of your personal information an dyou will not be able to seek redress under the Privacy Act.
Other than as stated above, we do not disclose personal information that you may give us to any organisation or person outside of the de Bruin Group unless you have authorised us to do so.
Under no circumstances will the de Bruin Group sell or receive payment for licensing or disclosing your personal information.
The security of your information is important to us. Your personal information will be stored as physical files in a secured area, on our electronic database system and on computers with appropriate back-up and security systems. Archived files are stored in secure on and off site storage. The de Bruin Group operates secure data networks that are designed to protect your privacy and security. When we have collected personal information about you it cannot be seen or modified by anyone else. The de Bruin Group has implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorised access.
Only authorised de Bruin Group personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.
We review and update our security measures in light of current technologies. You should, however, be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.
Where lawful and practicable to do so, you can deal with us anonymously or using a pseudonym. You can deal with us anonymously or using a pseudonym when making a general enquiry about the goods and services that we can offer to you including via telephone, our website or in person.
At the time you purchase our goods or engage our services, it is no longer practicable for you to deal with us anonymously or using a pseudonym.
You may at any time, request access to personal information that the de Bruin Group holds about you by making a request to our Privacy Officer at the address or email address below.
We will take appropriate steps to verify your identity (or verify that you act as a legal guardian or authorised agent of the individual concerned) before granting a request to access personal information.
We will endeavour to process any requests for access to personal information within a reasonable period of time and if access is granted, will be provided within 30 days from your request. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. We will provide you with access to your information in a manner as requested by you, provided that it is reasonable to do so. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding.
The de Bruin Group may charge a nominal fee for supplying personal information.
We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service being provided.
Otherwise, if you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below. Our Privacy Officer will consider your request and as soon as practicable manage the correction of your personal information and will update you in writing.
Your request for correction will be dealt with within 30 days, or such longer period as agreed by you. We will accept your request for correction of your credit related personal information where we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
Upon accepting a request for correction of your information, we will take all steps that are reasonable in the circumstances, having regard to the purpose for which your information is held, to correct your information.
If your request for correction of credit related personal information is accepted, we will provide written notice of this correction to any entity to which we have disclosed this information previously, to the extent that it is practicable.
If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).
If you have any complaints relating to the management of your personal information or if you believe there has been a breach of the Privacy Act by the de Bruin Group, please forward your complaint in writing to our Privacy Officer at the address or email address below.
Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time, but not more than 30 days from receipt of the complaint.
If our Privacy Officer decides that there has been a breach of the Privacy Act, s/he will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform the de Bruin Group’s Managing Director in order to resolve the matter.
If you are still not satisfied after lodging a complaint with us and given us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:
Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749
TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.)
TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)
Post: GPO Box 2999 Canberra ACT 2601
Fax: +61 2 9284 9666
Please contact our Privacy Officer on the contact details below if you would like to:
Post: Privacy Officer, de Bruin Group, PO Box 52 – Mount Gambier SA 5290
Telephone: (08) 8721 3000
Facsimile: (08) 8725 8003
Credit information has the same meaning as in the Privacy Act.
Personal information has the same meaning as in the Privacy Act.
Sensitive information has the same meaning as in the Privacy Act.
Website(s) refers to all websites which are owned, operated or under the control of the de Bruin Group including www.debruingroup.com.au.
For more information about your privacy rights in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au