How We Handle Your Personal Information |
Personal information is information or opinion that
allows others to identify you. It includes your name, age,
gender, contact details, as well as your health and
financial information. We will act to protect your personal
information in accordance with the National Privacy
Principles.
We value your trust and loyalty. The protection of your
personal information is a vital part of this relationship.
We have vast experience in keeping personal
information gathered by electronic means confidential. And
we will use all our resources to ensure the best available
levels for the protection of your
personal information.
We collect personal information to provide you with the
products and services you request as well as information
on other products and services offered by us or
recommended by us. The law may
also require us to collect personal information. We will
tell you who collects the personal information, advise you
of their contact details, your right of access to that
information, and what will happen if you choose not to
provide the information.
Personal information may be used and disclosed within
our Company to administer our products and services,
maintain our Company's relationship with you, and as well
as for prudential and risk management purposes and, unless
you tell us otherwise, to provide you with related
marketing information. We co-operate with police and other enforcement
bodies as required or allowed by law.
We disclose relevant personal information to external
organisations that help us provide services. These
organisations are bound by confidentiality arrangements.
They may include overseas organisations.
You can seek access to the personal information we hold
about you. If the information we hold about you is
inaccurate, incomplete, or outdated, please inform us so
that we can correct it.
Further information and feedback
The pages that follow contain more detailed information
about our privacy and information handling practices.
If you have any questions or would like further
information on our privacy and information handling
practices, please contact us by:
- e-mail our Customer
Relations department
- or writing to the address below:
Privacy Officer
Customer Relations
DigiBOAT Pty Limited
PO Box 408
Newport Beach NSW 2106
AUSTRALIA
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What You Need To Know And Where To Find It |
Background
Collection of personal information
Other members of the Commonwealth Bank
Group
Other disclosures
Personal information quality
Personal information security
Online
Direct marketing
Changes to our privacy and information
handling practices
Access to personal information
Contact us about our privacy and
information handling practices
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Background |
Common law duty of confidentiality
As part of the general law governing the
supplier/customer contract, we are required
to keep any information about customers in the
strictest confidence. Traditionally, information held about a customer could only
be disclosed if:
- they had the customer's express or implied consent;
- the disclosure was compelled by law; for example,
under Taxation Acts;
- the disclosure was required in the best interests of
the Company; for example, to a court if
defending or conducting legal action involving a
customer. This exception does not, as it is sometimes
thought, allow a Company to disclose information for any
purpose it chooses; or
- the disclosure was in the public interest; for
example, if a customer's dealings indicate that he or
she was trading with the enemy during a time of war.
This exception is used rarely and only in the most
serious circumstances.
As a matter of policy, DigiBOAT observes this standard of confidentiality.
Whilst these general requirements remain in place, we now have
broader obligations, under the National Privacy
Principles, which are contained in the Privacy Act 1988
(Australian Commonwealth).
Privacy Act 1988
The (Australian) Commonwealth Government has enacted privacy
legislation to protect information held by all credit
providers about their customers' personal
credit dealings. Since 1991, under Part IIIA of the
Privacy Act, credit providers have only been allowed to disclose
information about personal credit dealings to certain
classes of persons (such as a bank or a credit
union) for certain very limited purposes.
Privacy Amendment (Private Sector) Act 2000
In December 2000, the Commonwealth Government enacted
further privacy legislation, which commenced 21 December
2001, amending the Privacy Act (implementing the National
Privacy Principles) to include provisions that regulate
the way private sector organisations collect, use,
disclose, keep secure and provide access to personal
information.
DigiBOAT acts to protect your
personal information in accordance with the National
Privacy Principles.
This document
The information in this document details how we comply
with the requirements of the Privacy Act in protecting the
personal information we hold about you.
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Collection of Personal
Information |
What is "personal information"?
Personal information is information or an opinion,
whether true or not, and whether recorded in a material
form or not, about an individual whose identity is
apparent, or can reasonably be ascertained, from the
information or opinion.
Why we collect information
Personal information is collected so that we may:
- administer our customer relationships;
- provide customers with the products and services
they request and, unless they tell us otherwise, to
provide information on products offered by other
associated companies.
Personal information may also be used for:
- monitoring and evaluating products and services;
- gathering and aggregating information for
statistical, prudential, actuarial and research
purposes;
- assisting customers with queries; and
What we collect
Personal information collected generally comprises name, address, contact details
(e-mail) and financial information (if ordering products
on-line). We also request your assistance by asking for
some general information regarding the type of boat you
own and its general use, and navigation systems in use. Sometimes we
collect a few personal details unlikely to be known to
other people to help us uniquely identify you.
In addition, as required by Part IIIA of the
Privacy Act 1988, we will obtain your consent to collect,
use and disclose credit information about you.
We do not collect information about your political or
religious beliefs, or ethnic background.
What if you provide incomplete or inaccurate
information?
We may not be able to provide you with the products or
services you are seeking.
Obtaining your consent
In most cases, before or at the time of taking out a
new product we obtain your consent to
the purposes for which the personal information garnered intends to
be used and your consent to our needs to disclose your
personal information (for example: supplying your address
details to an international C-MAP office).
If you do not give us consent, we may not be able to
provide you with the products or services you want. This
is because it is impracticable for us to treat some
customers differently, as most of our processing is
automated and database driven.
Withdrawing consent
Having provided consent, you are able to withdraw it at
any time. To withdraw consent, please notify us by email. Please note that withdrawing your consent may
lead to us not being able to provide
you with the product or service you enjoy given that, as
mentioned above, it is impracticable for us to treat some
customers differently.
Information collected from someone else
In some cases, your personal information may be
provided to us by agents, or by family members or friends.
We will take reasonable steps to let you know that we have
your personal information, unless it is obvious from the
circumstances that you know or would expect us to have the
information, such as an automated email reply. Reasonable steps may include asking the person who
gave us your information to let you know that we have that
information.
Collection from young people
As we gather no age nor gender based
information, we have no control over possible requests from young people.
In any case, we will never provide any product, service or
information inappropriate or illegal for minors.
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Other Recipients
of your Personal Information |
At times, and with your permission,
DigiBOAT will pass on certain details to allow them to
provide you with requested products or services. For
example if your address details are supplied, this will be
passed on to your local C-MAP office for distribution of
the C-MAP Charts on Digital Media.
Without
your consent, other recipients may not use or
disclose your personal information for purposes other than
for which your information was originally collected. All
DigiBOAT's affiliated companies comply with the same standard of privacy
and information handling practices.
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Other Disclosures |
Who we may communicate with
Depending on the product or service you have and the
member of the Group you are dealing with, we may exchange
personal information with:
- brokers and agents who refer your business to us;
- external product providers for whom we act as agent
(so that they may provide you with the product you
seek);
- auditors we appoint to ensure the integrity of our
operations;
- auctioneers (if we have to sell a property we hold
as security to recover moneys owing to us);
- any person acting on your behalf, including your
financial adviser, solicitor and accountant, executor,
administrator, trustee, guardian or attorney;
- your referee (to confirm details about you);
- if required or authorised to do so, regulatory
bodies and government agencies;
- other financial institutions and organisations at
their request if you seek credit from them (for
example: supplying credit card details for on-line
purchases creates a credit transaction between you and
your credit provider);
- suppliers from whom we order goods on your behalf
(so that the goods may be provided to you);
- other organisations who in conjunction with us
provide products and services (so that they may
provide their products and services to you); and
- professional associations or organisations with whom
we conduct an affinity relationship (to verify your
membership of those associations or organisations).
If we have used an example to indicate when we might
exchange personal information, the exchange of personal
information may not be limited to those examples or
examples of a similar kind.
Outsourcing
We disclose personal information when we outsource
certain functions, including bulk mailing, market research, direct marketing,
documentation production, debt recovery and information
technology support. We also seek expert help from time to
time to help us improve our systems, products and
services.
If we use local agents, for example, local businesses,
to help provide you with face-to-face services, these agents
may collect personal information on our behalf.
In all circumstances where personal information may
become known to our contractors, agents and outsourced
service providers, there are confidentiality arrangements
in place. Contractors, agents and outsourced service
providers are not able to use or disclose personal
information for any purposes other than our own.
DigiBOAT takes its obligations to
protect customer information very seriously and we make
every effort to deal only with parties who share and
demonstrate the same attitude.
Sending personal information overseas
We send personal information overseas if we outsource
functions using overseas agents or contractors, or to
complete a particular transaction, such as supplying C-MAP
chart CD-ROMs.
Disclosure required by law
We may be required by law to disclose information, for
example, when we are served with a court order. We may
also be required by a Government Agency to produce
information and records, for example, pursuant to taxation
or social security laws.
Disclosure as a result of your actions
There may be circumstances in which we consider you, by
your actions, to have released us from our duty of
confidentiality or to have consented to the disclosure of
information about you without actually saying so (for
example, if you discuss your situation publicly
to the media, in such a way as to leave us with little
alternative but to respond publicly).
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Personal Information Quality |
Our goal is to ensure that the personal information we
hold is accurate, complete and up-to-date. Please contact
us if any of the details you have provided change. Please
also contact us if you believe that the information we
have about you is not accurate, complete or up-to-date.
We may take steps to update personal information, for
example, an address, by collecting personal information
from publicly available sources, for example, telephone
directories or electoral rolls or internet sites.
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Personal Information Security |
We are committed to keeping secure the personal
information you provide to us. We take all reasonable
precautions to protect the personal information we hold
about you from misuse and loss and from unauthorised
access, modification or disclosure.
We have a range of physical and technology policies in
place to provide a robust security environment. We ensure
the on-going adequacy of these measures by regularly
reviewing them.
Our security measures include, but are not limited to:
- restricting access to our computer systems and
physical records to authorised persons and preventing
users from accessing information they have no need to
access;
- requiring employees to use unique passwords to gain
access to systems. These passwords are changed
regularly and their use is independently monitored;
- concealed data sent from your computer to our
systems during Internet transactions and customer
access codes transmitted across networks;
- employing firewalls, intrusion detection systems and
virus scanning tools to prevent unauthorised persons
and viruses from entering our systems;
Where information we hold is identified as no longer
needed for any purpose we ensure it is effectively and
securely destroyed.
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Online |
Collection of information via web site activity
For statistical purposes we collect information on web
site activity (such as the number of users who visit our
web sites, the date and time of visits, the number of
pages viewed, navigation patterns, what country and what
systems users have used to access the site and, when
entering one of our web sites from another web site, the
address of that web site) through the use of 'cookies'.
This information on its own does not identify an
individual but it does provide our Company with statistics that can be used to analyse and
improve their web sites.
Cookies
A 'cookie' is a packet of information that allows the
server (the computer that houses the web site) to identify
and interact more effectively with your computer.
When you use one of our web sites, we
may send you a
temporary cookie that gives you a unique identification
number. A different identification number is sent each
time you use one of our web sites. Cookies do not identify
individual users, although they do identify a user's
browser type and your Internet Service Provider (ISP).
You can configure your browser to accept all cookies,
reject all cookies, or notify you when a cookie is sent.
Please refer to your browser instructions or help screens
to learn more about these functions. If you reject all
cookies, you may not be able to use some parts of our web sites.
To evaluate the effectiveness of our web site
advertising, we may use third parties to collect
statistical data concerning web site traffic. No personal data is collected on these
occasions.
Links to other websites
Our web sites may contain links to other
web sites. Whilst such links are provided for
your convenience, you should be aware that the information
handling practices of the linked web sites might not be
the same as ours.
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Direct Marketing |
One of the reasons we collect personal information is
so that we may provide you with information on future or
relevant products
and services. Whilst we are permitted by the Privacy Act to
disclose personal information to affiliated companies for
supply of their products or services to you, it is important to note
that our policy is that such companies with
whom you do not have a direct relationship will not use that
information for the purpose of contacting you.
Please contact us immediately if you
believe any affiliated companies are in breach of this
policy.
You may, if you wish, indicate that you do not want to
receive information on products and services offered by or
through any collecting member by:
- 'ticking the box' or not suppling
such optional information where applicable on any of
the various web forms when you take
out a product or service; or
- contacting the collecting agent at any time to
indicate that you wish to 'opt out' of receiving such
communication.
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Changes to our Privacy and
Information Handling Practices |
DigiBOAT may make changes to its
privacy and information handling practices from time to
time for any reason. We will publish those changes on our
web sites and, if there are important changes or a lot of
minor changes, by updating this document. This document is
dated 1 March 2004.
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Access to personal information |
You can request us to provide you with access to the
personal information we hold about you.
How to gain access
Requests for access to limited amounts of personal
information, such as checking to see what address or
contact we have recorded, can be
handled by return email.
Responding to an access request
We will respond to your access request as soon as
possible. We will endeavour to comply with your request
within 14 days of its receipt but, if that deadline cannot
be met owing to exceptional circumstances, your request
will be dealt with within 30 days. It will help us provide
access if you can tell us what you are looking for. Your
identity will be confirmed (including by verifying your
signature) before access is provided. Note most requests
are responded to within 24 hours, but for example
confirming credit card details would require appropriate
paper work and identification etc.
Requests may be denied or limited
If particular circumstances apply, we are permitted by
the Privacy Act to deny your request for access, or limit
the access we provide. We will let you know why your
request is denied or limited. For example, we may give an
explanation of a commercially-sensitive decision, rather
than direct access to evaluative information connected
with it.
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Contact Us About Our Privacy
and Information Handling Practices |
If you have any questions or would like further
information about our privacy and information handling
practices, please contact us by:
- e-mail our Customer
Relations department
- or writing to the address below:
Privacy Officer
Customer Relations
DigiBOAT Pty Limited
PO Box 400
Rose Bay NSW 2029
AUSTRALIA
Making a privacy complaint
We recognise that even in the best run organisations
things can go wrong. Should you have a privacy complaint,
please tell us because it gives us the opportunity to fix
the problem.
To assist us in helping you, we ask you to follow
these simple steps:
- Gather all supporting documents about the matter of
complaint, think about the questions you want answered
and decide on what you want us to do.
- Contact DigiBOAT, using either method
listed above, where your situation will be reviewed and if possible
resolved straight away. A quick "chat" is all that's
required to resolve most issues.
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