Privacy Policy

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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:

• contact information such as your name and address, telephone and fax numbers and email address;
• date of birth;
• financial information, including bank account details and credit card details;
• business details, including Australian Business Number;
• tax file number; and
• other information which we may be required by law to collect to perform our services or voluntarily provided by you.

The credit related personal information which we may collect includes:

• identification information- name, date of birth, current or previous address, driver’s licence number;
• type and amount of credit sought;
• trade references – name of entity, ABN, contact name, telephone number, fax number, email, years trading with you;
• publicly available information about an individual’s creditworthiness;
• consumer credit liability information- name of credit provider, type of consumer credit, details of the consumer credit provided;
• default information;
• repayment history information;
• payment information in relation to an overdue payment;
• court proceedings information;
• personal insolvency information; and
• opinion that a serious credit infringement has been committed by an individual.

You acknowledge that the personal information we collect from you is your own information or information which you have been authorised to provide us.

Sensitive information

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.

Unsolicited information

Where unsolicited information is received by the de Bruin Group (such as through our Facebook page or other social media platforms we operate or may establish) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs.  If it would not be permitted for the de Bruin Group to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable.  Otherwise, the de Bruin Group may retain the information in accordance with the terms of this Privacy Policy.

Information we collect automatically

When you visit our Website(s) we may collect certain information by automated means such as through the use of cookies, other automated devices and website tracking tools such as Google Analytics.  We use Google Analytics to collect information about how our Website(s) are used.  Google Analytics generates statistical and other information about websites by means of cookies stored on users’ computers. Google may collect, transfer, store, and process this information on its servers located in the United States.  We will not use Google Analytics to track or collect any personal information from visitors to our Website(s).  You can read about how Google Analytics collects and processes data at ‘How Google uses data when you use our partners’ sites or apps’ http://www.google.com/policies/privacy/partners/.  If you do not want information relating to your visit to our Website(s) reported by Google Analytics, you can install the Google Analytics opt-out browser add-on.  For more information see ‘Google Analytics Opt-out Browser Add-on’ https://tools.google.com/dlpage/gaoptout.

The type of information we may collect by automated means includes:

• your visiting domain name or IP address;
• the device, browser, operating system type and screen resolution you use;
• information on actions taken at our Website(s) such as navigation patterns (ie. pages viewed and downloaded) and the date, time, duration and number of times you visited our Website(s);
• the previous site you visited;
• the geographical location (such as country and city) from where you accessed our Website(s); and
• search terms or other webpages that led you to our Website(s).

You can change the privacy settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer.  However, by blocking or deleting cookies used for our Website(s), you may not be able to take full advantage of services offered via our Website(s).  This is because cookies are used to help you navigate the Website(s) and to perform certain functions when using our Website(s) such as delivering content specific information to you.

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.

Method of collection

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:

• If you request products or services from us in-store or via any online shopping facility we operate or may establish, we may collect information such as your name and contact details (ie billing and/or postal address, phone/fax number(s) or email address), date of birth and/or credit card details.
  • If you sign up to use a particular service provided by us such as our newsletter(s) and e-newslettters, mail outs (about product updates and developments, special events or promotions), or enter into a competition operated by us, we may collect information such as your date of birth and your interests and any other information required to provide that service to you (in addition to your name and contact details).
  • If you participate in any surveys we, or a third party service provider acting on our behalf, may conduct from time to time on our Website, we may collect personal information relating to your survey responses.
  • If you make an inquiry, provide feedback or make a complaint to us, we may collect your name and contact details.
  • If you are applying for employment with us, we may collect any information that is relevant to such employment including:
    • your name and contact details (ie residential address, phone number(s) and/or email address)
    • any other information relevant to the recruitment process (including any information contained in the application form and your resume).

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 information

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:

• providing the products and/or services you have requested from the de Bruin Group including for example:
  • to process sales transactions (whether in store or online);
  • to deliver the products or services to you;
  • to register you for a service requested by you, such as our newsletter(s) and e-newslettters, mail outs, competitions and administering such services;
  • to manage warranty claims;
  • to respond to any inquiries, feedback or complaints made by you; and
• direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions (unless as directed otherwise);
• assisting us to improve our products and services and making them more relevant to you;
• assisting us to improve our Website(s) or Facebook page or any other social media platforms we operate or may establish;
• processing and assessing employment applications for current and future positions;
• managing our internal business operations and processes; and
• other purposes related to any of the above.

Direct marketing

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:

• monitor the use of our Website(s);
  • help us make improvements to the Website(s); and
  • offer relevant information and services to as many users as possible.

Disclosure

There will be occasions where it will be necessary for the de Bruin Group to disclose your personal information to third parties who assist us to provide, manage and administer our services and products.  Information provided to third parties will be dealt with in accordance with that entity’s privacy policy.

The de Bruin Group may disclose your personal information to:

• contractors and third party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of the product or service.  This includes organisations such as marketing agencies (such as MailChimp), data processing companies, printing and mailing houses, delivery companies, or finance agencies or debt collection agencies;
• other members of the de Bruin Group for marketing purposes (subject to obtaining your prior consent);  
• government authorities or other third parties as required by law; or
• any other third party in respect of which you have consented to such disclosure.

Transfer of information outside Australia

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.

No sale of personal information

Under no circumstances will the de Bruin Group sell or receive payment for licensing or disclosing your personal information.

Storage and Security

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.

Dealing with us anonymously

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.

Data quality, access and correction

Access

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.

Correction

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). 

Complaints about privacy and our complaint handling procedure

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
Email: enquiries@oaic.gov.au

Contact Privacy Officer

Please contact our Privacy Officer on the contact details below if you would like to:

• inquire about or request access and/or update your personal information; or
• report an alleged breach of your privacy rights or make a complaint:
• talk to our Privacy Officer about our Privacy Policy

Please contact:

Post:                      Privacy Officer, de Bruin Group, PO Box 52 – Mount Gambier  SA  5290
Telephone:           (08) 8721 3000
Facsimile:            (08) 8725 8003
E-mail:                   privacy@debruingroup.com.au

Miscellaneous

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.

This Privacy Policy is periodically reviewed.  The de Bruin Group reserves the right to modify or amend this Privacy Policy at any time.  The effective date will be displayed at the beginning of the policy.  The de Bruin Group will notify changes to our Privacy Policy by prominently identifying the alteration for a period of not less than two weeks on our Website.

Further Information on Privacy

For more information about your privacy rights in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au