Aqipa privacy and
credit information policy

Aqipa Australia PTY LTD 
49 Babbage Drive
Dandenong South, VIC 3175
Australia

ACN 616 579 947

PRIVACY STATEMENT

• Your rights in relation to privacy

Aqipa Australia Pty Ltd (ACN 616 579 947) (Aqipa Australia) understands the importance of protecting the privacy of an individual’s personal information.  This statement sets out how Aqipa Australia aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Aqipa Australia and the way Aqipa Australia collects, holds, uses and discloses your personal information.

In handling your personal information, Aqipa Australia will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. To the extent Aqipa Australia handles your credit information, Aqipa Australia will also comply with the Credit Reporting Code.  This policy statement may be updated from time to time.

• What kinds of personal information does Aqipa Australia collect?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.  During the provision of its products and/or services, Aqipa Australia may collect your personal information.

Generally, the kinds of personal information Aqipa Australia collects are #[Delete or amend as relevant]:

1. contact and identification information such as your name, address, telephone number and email address;
2. where acting as the representative for your employer, details of your employment and employer;
3. financial information about your assets, occupation and income, account balances, account activities, payment history and transactions with us or third parties;
4. credit information, being credit related personal information  lawfully created and accessible within the Australian credit reporting system including:
   1. identification information;
   2. consumer credit liability information which includes information about your credit providers and credit accounts, including the dates on which the accounts are opened and closed, their limits, and their terms and conditions (or any changes to their terms and conditions);
   3. whether you have or have not met any monthly repayment obligations;
   4. whether you have defaulted on a payment (ie. a payment that is at least 60 days overdue and over $150 in value) provided Aqipa Australia has notified you in accordance with the Privacy Act;
   5. whether you have paid any amount previously reported as being in default;
   6. that another credit provider has sought credit-related personal information about you from a credit reporting body;
   7. information about the types of consumer or commercial credit, and the amounts of credit, you have sought from a credit provider;
   8. information about court proceedings related to credit provided to you or for which you have applied;
   9. personal insolvency information and other publicly available information relating to your credit worthiness;
   10. a credit provider’s reasonable belief that you have committed a serious credit infringement; and
   11. any other information lawfully obtainable within the Australian credit reporting system;
       
        
5. credit eligibility information which is credit-related information about you that Aqipa Australia obtains from a credit reporting body such as Dun & Bradstreet (Australia) Pty Ltd (D&B) or Equifax Pty Ltd (previously known as Veda, Veda Advantage Information Services Solutions Limited, or otherwise part of the Veda group of companies) (Equifax) (the details of which are set out in paragraph 5), together with information Aqipa Australia derives from such information based on its own analysis including internally generated scores, ratings and other assessments used to evaluate your credit worthiness.  Aqipa Australia generally receives from D&B and Equifax information about [#insert details e.g. existing credit accounts, previous defaults, repayment history information etc];
6. [#insert if and as applicable:]sensitive information including:
   1. health information:
      1. where you consent to the collection of such information and if relevant to the provision of Aqipa Australia’s products and/or services; or
      2. where you are applying for a position with Aqipa Australia and it is relevant to the recruitment process through which you must progress following your application to Aqipa Australia; and
   2. where you are applying for a position with Aqipa Australia, criminal record information where relevant to Aqipa Australia’s assessment of whether you are able to perform the inherent requirements of the particular role; and
7. [#insert if and as applicable:]other information such as [#insert description of any other types of personal information].

In some circumstances Aqipa Australia may also hold other personal information provided by you.

1. How does Aqipa Australia collect personal information?

Generally, Aqipa Australia collects your personal information directly from you, through [#insert description of how personal information is collected e.g. the completion of a manual or online form (including but not limited to a form for a trading and/or credit account), an interaction or exchange in person or by way of telephone, facsimile, email, post or through the use of the Aqipa Australia website].  There may be occasions when Aqipa Australia collects your personal information from other sources such as from [#insert, delete or amend as applicable]:

1. your employer, where necessary for Aqipa Australia to provide its products and/or services to your employer through you;
2. the completion of an application form by another person or entity that lists you as a director, guarantor or trade reference;
3. D&B, Equifax or other credit reporting bodies;
4. other credit providers;
5. an information services provider;
6. a publicly maintained record or other publicly available sources of information including social media and similar websites;
7. Aqipa Australia’s own records about you, from which Aqipa Australia may internally generate its own scores, assessments or deductions, particularly in relation to your credit worthiness;
8. if for recruitment purposes, an external recruitment or background screening services provider; or
9. [#insert other party or description of types of third party entity from which personal information may be collected]. 

Generally, Aqipa Australia will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you. 

1. Why does Aqipa Australia need your personal information?

Aqipa Australia collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:

1. distributing and marketing accessories for consumer electronics;
2. providing other products and/or services;
3. assessing an application for, and if successful, administering, a commercial trading and/or credit account with Aqipa Australia;
4. accounting, billing and other internal administrative purposes;
5. identifying and informing you of products and services that may be of interest to you from Aqipa Australia or selected third parties;
6. assessing your application for employment with Aqipa Australia or otherwise for the purpose of engaging you as a contractor or consultant; and/or
7. any other legal requirements.

Aqipa Australia may also use your personal information for purposes related to the above purposes and for which you would reasonably expect Aqipa Australia to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.

Where personal information is used or disclosed, Aqipa Australia takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Aqipa Australia.  However, without certain information from you, Aqipa Australia may not be able to provide its products and/or services to you.

1. To whom does Aqipa Australia disclose your personal information?

Aqipa Australia discloses your personal information for the purpose for which Aqipa Australia collects it.  That is, generally, Aqipa Australia will only disclose your personal information for a purpose set out at paragraph 4.  This may include disclosing your personal information to [#insert, delete or amend as applicable]:

1. third parties engaged to perform administrative or other business management functions;
2. people or entities considering acquiring an interest in Aqipa Australia’s enterprise or assets;
3. Aqipa Australia’s professional advisors, contractors, consultants and related bodies corporate;
4. insurance providers;
5. regulatory bodies if and as necessary; and
6. [#insert any other parties to which personal information may be disclosed].

Aqipa Australia may also disclose your personal information, including your credit information, to lenders, other credit providers and the credit reporting bodies, D&B and Equifax (contactable on the details set out below). In particular, Aqipa Australia may disclose to D&B and Equifax information about you failing to meet your payment obligations or if you commit a serious credit infringement. D&B and Equifax may include any information it is provided by Aqipa Australia in reports provided to other credit providers for the purpose of such credit providers assessing your credit worthiness. 

Aqipa Australia’s disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with law.  Aqipa Australia may also disclose your personal information with your consent or if disclosure is required or authorised by law.

D&B can be contacted:

• in accordance with its privacy policy at: http://dnb.com.au/privacy-policy.html; and/or
• via:

Phone: 13 23 33 or Email: clientservices@dnb.com.au (Business Information Client Services Centre);
Phone: 1300 734 806 or Email: PACaustral@dnb.com.au (Consumer Credit Information Public Access Centre)

Equifax can be contacted:

• in accordance with its privacy policy at: http://www.equifax.com.au/privacy; and/or
• at:

Equifax Australia Personal Solutions Pty Ltd
PO Box 964
NORTH SYDNEY NSW 2059
or otherwise through the ‘contact us’ form at https://www.equifax.com.au/contact.

Equifax’s policy on its management of credit related personal information can be accessed through its website at: http://www.equifax.com.au/privacy.

1. Overseas disclosure

Aqipa Australia may disclose personal information, including credit related personal information, to overseas recipients, including its parent company in Austria and other related bodies corporate, in order to provide its products and/or services and for administrative, data storage or other business management purposes. Recipients of such disclosures are located in Austria and may also be located in [#insert countries as necessary e.g: Germany, Switzerland and Spain]. 

Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, Aqipa Australia takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law. If you have any queries or objections to such disclosures, please contact Aqipa Australia’s Privacy Compliance Officer on the details set out in paragraph 10.

1. Direct marketing

Aqipa Australia may use and disclose your personal information in order to inform you of products and/or services that may be of interest to you.  In the event you do not wish to receive such communications, you can opt-out by contacting Aqipa Australia via the contact details set out in paragraph 10 or through any opt-out mechanism contained in a marketing communication to you. 

Aqipa Australia will not use or disclose credit-related personal information for direct marketing purposes except to the extent permitted under the Privacy Act, for the purpose of D&B or Equifax assessing your eligibility to receive direct marketing communications sent on behalf of Aqipa Australia. You may make a request directly to D&B and Equifax not to use your credit-related personal information for these purposes.

1. Security of your personal information

Aqipa Australia takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.  Aqipa Australia holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.  Credit eligibility information, such as information Aqipa Australia receives from D&B or Equifax for the purpose of assessing credit worthiness, is stored through equally secure methods. [#Insert if applicable: Staff are bound by security policies and confidentiality agreements, which are regularly revised and re-issued.]

Aqipa Australia will destroy or de-identify personal information in circumstances where it is no longer required, unless Aqipa Australia is otherwise required or authorised by law to retain the information. 

If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you may request D&B and Equifax not to use or disclose credit related personal information it holds about you by contacting D&B and Equifax on the details set out in paragraph 5.

1. Can you access and correct the personal information that Aqipa Australia holds about you?

Aqipa Australia takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.  Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by Aqipa Australia.  If at any time you would like to access or correct the personal information that Aqipa Australia holds about you, or you would like more information on Aqipa Australia 's approach to privacy, please contact Aqipa Australia’s Privacy Compliance Officer on the details set out in paragraph 10 below.  Aqipa Australia will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. 

Where necessary to resolve a request for correction of your credit related personal information, Aqipa Australia may also consult with other relevant entities, including but not limited to D&B and Equifax.  Aqipa Australia’s use or disclosure of your credit related personal information for correction purposes is permitted by the Privacy Act.

To obtain access to your personal information:

1. you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
2. Aqipa Australia requests that you be reasonably specific about the information you require; and
3. Aqipa Australia may charge you a reasonable administration fee, which reflects the cost to Aqipa Australia, for providing access in accordance with your request.

Alternatively, if you would like to access personal information held about you by D&B, or Equifax please contact D&B or Equifax on the contact details set out in paragraph 5.

Aqipa Australia will endeavour to respond to your request to access or correct your personal information within 30 days from your request.  If Aqipa Australia refuses your request to access or correct your personal information, Aqipa Australia will provide you with written reasons for the refusal and details of complaint mechanisms. Aqipa Australia will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of Aqipa Australia.

If you are dissatisfied with Aqipa Australia’s refusal to grant access to, or correct, your credit related personal information, you may make a complaint to the Office of the Australian Information Commissioner.  [#insert details, including contact details, of an External Dispute Resolution Service of which Aqipa Australia is a member].

1. How to contact us

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Aqipa Australia 's Privacy Compliance Officer at sohan.karunaratne@aqipa.com.au.

1. Privacy complaints

Please direct all privacy complaints to Aqipa Australia’s Privacy Compliance Officer.  At all times, privacy complaints:

1. will be treated seriously;
2. will be dealt with promptly;
3. will be dealt with in a confidential manner; and
4. will not affect your existing obligations or affect the commercial arrangements between you and Aqipa Australia.

Specifically, if your complaint relates to credit related personal information and/or Aqipa Australia’s failure to comply with its obligations regarding credit related personal information under the Privacy Act and/or the Credit Reporting Code:

1. Aqipa Australia will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless Aqipa Australia informs you otherwise and seeks your agreement in writing;
2. Aqipa Australia may consult with relevant third parties, such as D&B, Equifax or other credit providers, in order to sufficiently and expeditiously resolve the complaint; and
3. if your complaint relates to Aqipa Australia’s refusal to provide  access to, or correct, your credit related personal information, you may complain directly to the Office of the Australian Information  Commissioner or [#insert details, including contact details, of external dispute resolution service provider].

Aqipa Australia’s Privacy Compliance Officer will commence an investigation into your complaint.  You will be informed of the outcome of your complaint following completion of the investigation.  In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Aqipa Australia will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner,  or if the complaint relates to your credit information, the [#insert details, including contact details, of external dispute resolution service provider].