1. About us
2. Your privacy is important to us
We protect your information and aim to be clear and open about what we do with it.
You do not have to provide us with your personal information. However, if you don’t do so it may affect our ability to assist you or provide you with a product or service. If you want to deal with us while not identifying yourself (i.e. anonymously or by using a pseudonym) we will allow you to do so where it is practical (for example, where you make a general enquiry of us). Please tell us if you wish to do this and we will indicate whether, given the nature of the transaction, it is practical.
3. What information do we collect, how & from where?
We collect personal information about you when you use our products or services, or deal with us. We may also collect personal information about you from other people and organisations.
How your information may be collected & from where
Information we may collect
Information that you (or others) share with Upkeep+, our group members, agent distributors, service providers and external providers, such as information collected:
Over the phone
In person, including at your property
Over the internet, including via our website, mobile or web applications, online forms, surveys, emails or cookies
In writing, including via hard copy forms
Your name, date of birth, gender;
Contact details (such as your postal address, phone number or email);
Property details (such as, but not limited to, your property address, property type, postcode, number of bedrooms and bathrooms, number of stories, construction materials, roofing properties);
Photos, illustrations, text, video, still images, audio, schematics, virtual tours or floor plans;
Details of the layout, construction and condition of your property (such as, but not limited to, room types, electrical wiring condition, plumbing system, HVAC system and other home systems, construction materials and condition in each room, roofing condition, evidence of pests);
Information you have shared with Upkeep+ during customer surveys or interviews;
Other information provided when you register for a service or product directly with Upkeep+ or through a vendor; and
We may also match your property address with other records held by Insurance Australia Limited and its related entities, to obtain additional information about your property (such as, but not limited to, claims history, aerial imagery and other property information).
Information automatically collected from your devices, such as:
Device information: such as IP address, unique device identifier, browser type, time zone, postcode, and other operating system data available to the mobile or web application.
Mobile or web application analytics information and other information about how you use the application: such as how often you use the application, referral URL and exit page, the events that occur within the application, aggregated usage, performance data, and the application marketplace from where you downloaded or accessed the application.
Where we collect sensitive information, we will generally not use it for any other purpose other than the purpose we collected it for. We will only use sensitive information for another purpose:
where you would reasonably expect the information to be used in that way;
if the purpose is directly related to the purpose we collected it for; or
if you give us consent to do so.
4. How do we use your information?
We’re careful about how we collect, hold, use and disclose your personal information. We use it to deliver our products and services. We also use your personal information for other purposes, such as to better understand your needs, and to let you know about other products and services you may be interested in.
Purpose for use of your information
How your information may be used by us
Serving you as a customer:
To provide you with products and services (these products and services may be offered by ourselves, our related entities, service provider or other external parties);
To manage our relationship with you, including verifying your identity, maintaining your account, and processing payments you have authorised;
To contact you, for example, to respond to your queries or complaints, or if we need to tell you something important; and
To provide you with assistance you may request of us.
Enhance our products and services:
For product development, model development, and statistical analysis to improve our products and services;
For refining our risk modelling and analytics;
To study how our customers, use products and services from us and other organisations;
To test new products; and
To develop new ways to meet our customers’ needs and to grow our business.
Facilitating our business operations:
For example, for managing our IT infrastructures, databases, websites and statistical and maintenance purposes.
Fraud, crime and misuse prevention:
To detect, investigate, report and seek to prevent and deter fraud and crime;
To prevent and deter the misuse of our products and services and as required by law;
To manage risk for us and our customers; and
To respond to complaints and seek to resolve them.
Responding to regulatory requirements:
To comply with our legal obligations and assist government and law enforcement agencies or regulators.
Using any special categories of data as needed to establish, exercise or defend legal claims.
To provide you with updates, offers and information about products and services that we think may be of interest to you. These products and services may be offered by ourselves, our related entities or other external parties, outlined in section 5.
If you no longer wish to receive promotional communications from us, you can contact us at any time to opt-out or use the opt-out instructions provided in the communication. If you decide to opt-in again just let us know.
For any other purpose communicated to you at the time we collected your personal information or as required or permitted by law.
5. Who do we share your information with?
We may share your personal information with other members of the IAG Group (meaning Insurance Australia Group Limited and its related bodies corporate). We may also share your information with others for the reasons outlined in section 4.
We may disclose your personal information to the entities listed in the table below. They will only be authorised to use that information for the specific purposes outlined in section 4.
Our group members, agents and distributors.
Our related entities and their agents and distributors: for example, NRMA Insurance; and
Our agents and distributors: for example, someone who offers you one of our products or services on our behalf.
For example, suppliers, advisers, market researchers, marketing agencies, mailing houses, call centres, payment service providers, investigators, assessors, repairers, experts and IT providers and agents or sub-contractors of any of those providers; and
May also include overseas service providers.
Your family members – for example, if they contact us with your authority;
Australian Financial Complaints Authority – for example if they contact us about a complaint you make with them; and
Other sources such as information service providers or a publicly maintained record.
Sending information overseas.
Some of the entities listed above operate in countries outside of Australia, such as the United States, Singapore, New Zealand, South Africa, Philippines, Brazil and India. We may disclose your personal information to these parties located outside Australia. If we do this, we do all we can to ensure that there are arrangements in place to protect your personal information.
Upon sign-up, your identity and payment details are provided to the following external parties:
Identity details are provided to the external identity and access management provider that we use, Amazon Cognito. Information about Cognito data usage, privacy and security can be found here: https://aws.amazon.com/privacy/
Payment details are provided to the external payment processor that we use, Stripe Payments Australia Pty. Ltd. Information about Stripe data usage, privacy and security can be found here: https://stripe.com/au/ssa#section_d
6. Keeping your information safe
Our staff are trained in how to keep your personal information safe and secure. We use secure systems and buildings to hold your personal information. We aim to only keep your information as long as we need it.
We hold personal information electronically and may also hold information physically. We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
These processes and systems include:
The use of identity and access management technologies to control access to systems on which information is processed and stored;
Requiring all employees to comply with internal information security policies and keep information secure;
Requiring all employees to complete training about information security; and
Monitoring and regularly reviewing our practise against our own policies and against industry best practice.
We also require third parties to protect your information in accordance with our strict information security policies that align with generally accepted information security standards.
We store personal information for as long as necessary for us, our group members, service providers and related entities described above in section 5, to provide products and services to you and others, to comply with legal obligations, or to administer any product or service.
7. Accessing, updating & correcting your information
You can contact us and ask to view your personal information. For more detailed information, you may need to fill out a request form. If your information isn’t correct or needs updating, let us know straight away.
Can you see the information we have?
You can request access or correction of the personal information that we hold about you by contacting us (see section 10). So that we can provide access quickly and efficiently, we may ask you to complete a ‘Personal Information Access Request Form’ which can be located here.
Is there a fee?
There is no charge for requesting access to your personal information, but we may charge you a reasonable amount to cover matters such as retrieving, copying and sending out information in connection with an access request. There is no charge for correcting your personal information.
How long will it take?
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
Can we refuse to give you access?
There are some circumstances in which we are not required to give you access to your personal information. We’ll let you know if we are unable to give you access, if it is practical to do so.
Updating your information
It’s important that we have your correct details, such as your current home, email addresses and phone number. You can check or update your information by contacting us (see section 10).
8. Making a privacy complaint
If you have a concern or complaint about your privacy, let us know and we’ll try to fix it. If you’re not satisfied with how we handle your complaint, there are other things you can do.
How can you make a complaint?
If you have a complaint about our handling of your personal information, please contact us via email at firstname.lastname@example.org with details of your complaint.
How do we manage complaints?
promptly acknowledge your complaint;
determine if the complaint relates to a service provided by a service provider or other external party, in which case we will pass the complaint on to them and notify you;
carefully investigate any complaint relating to services delivered by us (e.g. billing, subscriptions) and determine the steps that we will undertake to resolve your complaint;
contact you if we require any further information and provide you with our determination once it is made; and
if you are unhappy with our determination, provide you details on how to take your complaint further.
What else can you do?
If you remain unhappy with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) (in Australia) or the Privacy Commissioner (www.privacy.org.nz) (in New Zealand) for guidance on alternative courses of action which may be available.
8. Making a privacy complaint
We’re Here To Help
If you need further information, want to update your personal information, have a privacy concern, or want to update your preferences – help is just a few clicks away.
write to us at Upkeep+, Level 3, Tower 2, 201 Sussex Street, Sydney NSW 2000; or