Privacy Policy

Comvision Victoria Pty Ltd ABN 26 110 641 373 and its related entities (Comvision, us, we, our) takes your privacy seriously and is committed to responsible privacy practices.

We seek to comply with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the Privacy (Credit Reporting) Code 2014 (CR Code). This Privacy Policy describes how we collect, use, disclose, store, and handle your personal information, credit information and eligibility information.

References in this Privacy Policy to “you” are references to you as an individual and/or as a company,

organisation or trust as applicable.

What is personal information?

In this Privacy Policy, ‘personal information’ has the meaning set out in the Privacy Act.  In general terms, personal information is information (whether fact, opinion, or evaluative material) about an individual who is identifiable from, or can be reasonably identified from, the information.

Some types of personal information are designated as ‘sensitive information’, which are subject to additional

protection under the Privacy Act.  For example, these can include information about your health.

What types of personal information do we collect?

The types of personal information we collect about you will depend on the purpose for which the information is collected. This can include:

  • in the case of customers purchasing our products and services – your name, service address, email address, telephone number(s), payment information (including credit card information or alternative payment method account information), and order details;
  • if you have requested to receive news and exclusive offers, promotions, or events – your name, mailing or street address, email address, and telephone number(s);
  • if you have contacted our customer service team to make a complaint, provide feedback, submit an enquiry, request a call-back or request support – your name, mailing or street address, email address, and telephone number(s);
  • in the case of trade credit applicants – information required to assess your credit worthiness, including your credit or business history and any trade referees;
  • in the case of prospective employees or contractors – information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers; and
  • in the case of our suppliers and distributors – your name, mailing or street address, email address, and telephone number(s).

Generally, we do not collect sensitive information about you. However, in certain circumstances, such as when we conduct pre-employment checks of prospective employees or contractors, we may need to collect limited sensitive information about you. For example, information relating to any health conditions, disabilities or criminal record.

We also collect technical information and general analytics, such as IP address, web browser type and browsing preferences, Internet service provider, referring/exit pages, and date/time stamps, time zone, and geolocation data (if applicable) arising from your use of our websites.

How do we collect personal information?

We collect your personal information directly from you, including when you:

  • access or use our websites;
  • sign up as a customer to purchase our products or services;
  • sign up to receive our newsletter;
  • provide information directly to us or otherwise communicate with us by email, by telephone, in person, via a website or otherwise; and
  • apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties.  In limited circumstances, we may collect personal information about you from third parties, such as through referrals from mutual contacts or from our service providers (such as third parties that conduct pre-employment police checks on our behalf).

If you provide Personal Information about other individuals to us, you must ensure that you have informed those individuals that you are providing their Personal Information to us and that you have obtained their consent and advised them of our Privacy Policy.

We also use the following technologies to collect technical information and general analytics:

  • cookies, which are data files that are placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies,

visit https://www.allaboutcookies.org;

  • log files, which track actions occurring on our websites; and
  • web beacons, tags, and pixels, which are electronic files used to record information about how you browse our websites.

By using our websites, you are consenting to the use of these technologies in accordance with this Privacy

Policy.

Can you choose not to disclose your personal information?

If you contact us to make a general enquiry about our business operations, you do not have to identify yourself or provide any personal information. Alternatively, you can also notify us that you wish to deal with us using a pseudonym.

However, if we are not able to collect personal information about you, we may not be able to provide you with the information or assistance you require.  For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number.

If you want, you can disable your web browser from accepting cookies and other technologies used to collect technical information and general analytics.  If you do so, you can still access our websites, but it may impact your user experience.

How do we use your personal information?

In general, we use your personal information for purposes connected with our business operations. Some of the specific purposes for which we use your personal information are as follows:

  • to provide our products and services to customers or to receive goods or services from third parties;
  • to enable the proper operation and functionality of our products and services;
  • to verify your identity (for example, if you request access to the personal information we hold about you);
  • to consider you for a job (whether as an employee or contractor) or other relationship with us;
  • to communicate with you and to address any issues or complaints that we or you may have regarding our relationship;
  • for direct marketing purposes (see the “Direct marketing” section below); and
  • to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

In conducting our business operations, we may share some of your personal information with third parties such as outsourced service providers or contractors.

We may also use or disclose your personal information for other purposes to which you have consented, or as otherwise permitted or required by law.

Technical information and general analytics is used for the purpose of assessing visitor traffic, trends and delivering personalised content to you while you are on our websites, and to improve our websites and our products and services.

To whom do we disclose personal information?

We may disclose your personal information to third parties in connection with the purposes described above

(see the “How do we use your personal information?” section).

This may include disclosing your personal information to the following types of third parties:

  • our related companies;
  • credit providers and credit reporting bodies, in relation to an application for credit you have made to us;
  • any potential third party acquirer of our business or assets, and advisors to that third party;
  • our professional advisers (such as lawyers, accountants or auditors) and insurers;
  • our employees, contractors and third party service providers who assist us in performing our functions and activities e.g. criminal record and police check providers, payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers;
  • organisations authorised by us to conduct promotional, research or marketing activities;
  • third parties to whom you have authorised us to disclose your information (e.g. referees); and
  • any other person as required or permitted by law.

For clarity, we use third party service providers to provide us with web analytics services, such as Google

Analytics. You can read more about how Google Analytics uses your personal information here.

If we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.

What credit information we collect

“Credit information” refers to certain information relating to an individual’s credit-related dealings with us, and “credit eligibility information” refers to certain information related to an individual’s credit-related dealings with other credit providers (as provided by credit reporting bodies), as defined in the Privacy Act. We may collect your credit information:

  • during our due diligence process prior to on-boarding you as a new customer and signing an agreement with you;
  • where you have signed an agreement with us or seek to purchase new goods or services from us;
  • where you are making an application for credit facilities with us or request specific credit terms that vary from our standard credit facility; or
  • if you default on any payment to us.

Credit information we may collect or hold may include the above personal information, as well as your employer, position held, income, consumer credit liability information, repayment history information, information request statements from credit providers, mortgage insurers or trade insurers, default information, payment information, new credit arrangement information, court proceedings information, personal insolvency information and other publicly available information related to your credit-worthiness.

How we collect credit information

We may collect credit information from you, where lawfully permitted to do so, in various ways, including from:

  • credit application forms and other customer forms submitted to us;
  • information provided by you, including when you sign an agreement with us or are onboarded as a customer;
  • credit reporting bodies; and
  • other credit providers.

Use and disclosure of credit information

We collect, use and disclose credit information for the primary purpose of conducting our business, which includes:

  • assessing applications for credit arrangements including checking your credit-worthiness;
  • establishing and maintaining customer accounts and managing such relationships;
  • dealing with the management, recovery, securitisation and assignment of debts;
  • assisting you to avoid defaulting on your credit obligations;
  • providing information to debt collection agencies for the purpose of recovering debts;
  • notifying other credit providers of a default by you;
  • assessing credit defaults reported by credit reporting bodies or debt collection agencies; and
  • for internal management purposes.

To enable us to assess an application by you for a credit arrangement we may:

  • obtain from a credit reporting body a credit report containing credit information and personal information about you; and
  • obtain a report from a credit reporting body and other information in relation to the commercial credit activities of all individuals listed in the application for credit.

We may, where you have given consent, give to, and obtain from, any credit provider named in your application for a credit arrangement and any credit provider that may be named in a credit report issued by a credit reporting body, information about your credit arrangements.

We may also disclose your credit information and personal information to credit reporting bodies in relation to credit-related dealings, for example where you have failed to meet payment obligations or commit a serious credit infringement. We may disclose your credit information to the following credit reporting bodies:

Equifax Australia

Equifax – Customer Resolutions

PO Box 964

Dun and Bradstreet

Attn: Public Access Centre

PO Box 7405

Experian Australia Attn: Credit Report PO Box 1969
NORTH SYDNEY  NSW 2059

1300 762 207

 ST KILDA RD VIC 3004

1300 734 806

 NORTH SYDNEY  NSW 2060

1300 783 684
corrections@qequifax.com.au pac.austral@dnb.com.au creditreport@au.experian.com
www.mycreditfile.com.au www.dnb.com.au www.experian.com.au

The above credit reporting bodies are required to have a policy about how they manage credit-related

personal information. This policy can be accessed on each credit reporting body’s website or by contacting

them directly.

You have the right to request that the above credit reporting bodies do not use your credit reporting information for the purposes of pre-screening of direct marketing. You also have the right to request that the above credit reporting bodies do not use or disclose your credit reporting information if you believe on reasonable grounds that you have been, or are likely to be, the victim of fraud (i.e. if you suspect someone

may use your identity to apply for credit). You must contact the above credit reporting bodies directly if this is the case.

Direct marketing communications

We will only send you direct marketing communications (either through mail, SMS or email), including any news, offers, promotions, or communications regarding events and webinars, where you have consented for us to do so.

You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt- out facilities provided in the direct marketing communications.

Does personal information leave Australia?

We store personal information in servers located in Australia.  We may disclose your personal information to overseas recipients, such as where you request us to do so (for example, so you can be contacted by a software vendor for troubleshooting) or to the extent that is necessary for a service provider who has a presence overseas to provide its products and services.

Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information do not breach the Australian Privacy Principles stated in the Privacy Act in relation to such information.

How do we protect your personal information?

We strive to ensure the security, integrity and privacy of your personal information and will take reasonable precautions to protect it from misuse, loss, or unauthorised access, modification or disclosure.  While we review and update our security measures in light of current technologies, the Internet is inherently insecure and we cannot guarantee the security of transmission of personal information you disclose to us

online.  Accordingly, you transmit your personal information to us online at your own risk.

We will endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. The Notifiable Data Breaches Scheme (NDB scheme) in Part IIIC of the Privacy Act sets out obligations for notifying affected individuals, and the Australian Information Commissioner (Commissioner), about a data breach which is likely to result in serious harm.

Where serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations. You may contact our Privacy Officer via the contact details below should you require additional information.

How long do we keep your personal information?

Generally, we will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy) unless a longer retention period is required by law or if it is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security.

When personal information is no longer required, we will take reasonable steps to delete the personal information from our systems or de-identify the personal information.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting

  1. us. Additionally, you may contact us to obtain confirmation of whether or not we hold credit eligibility information about y We will provide access to that information in accordance with the Privacy Act, subject to any exemptions that may apply. We may charge a reasonable administration fee in limited circumstances for providing you with access to your personal information.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us.

What is the process for complaining about a breach of privacy?

If you have any questions, concerns or complaints about our collection, use, disclosure or management of your personal information, please contact us in writing using the contact details below.

We will make inquiries and your complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.

If you are unsatisfied with the outcome, you may make a complaint to the Information Commissioner within the Office of the Australian Information Commissioner (www.oaic.gov.au).

Changes to this Privacy Policy

We may change this Privacy Policy from time to time at our discretion.  Amendments to this Privacy Policy will be posted on our websites.  Your continued dealings with us, for example use of our websites, products or services, will signify your agreement to this Privacy Policy as amended.

How to contact us

If you have a query, concern or complaint about the manner in which your personal information has been collected or handled by us or would like to request access to or correction of the personal information we hold about you, please contact using the details provided below:

Attention: Privacy Officer

Comvision

Suite 1.08, 202 Jells Road

Wheelers Hill, VIC 3150 privacy@cvv.com.au

Last updated: November 2023