How we handle your personal information
1. Your privacy is important to us.
How we collect, use, exchange and protect your information is important to you. That’s why protecting your information and being clear about what we do with it is a vital part of our relationship with you. This Privacy Policy is for our customers. It also includes our policy on the handling of credit reports and other credit related information. Please note that during the course of our relationship with you, we may tell you more about how we handle your information.
2. About Comfort Cool Engineering Pty Ltd (“Comfort Cool”).
Comfort Cool provides air conditioning products and services to our customers. We are bound by the Privacy Act 1988 and the Australian Privacy Principles (APPs), upon which this policy is based.
3. Information we collect.
Information we collect from you:
We collect information about you and your dealings with us. One example is when you request that we open a credit account or purchase our products or services. The information we collect from you may include your name, address and contact details, your date of birth, your employment and income details, your bank account details, the details of the products and services provided to you by us, details of your dealings with us, including records of telephone, email and online interactions, your credit-related personal information your identity and contact details such as financial information.
Information we collect from others:
We collect information about you from others, such as other credit providers and credit reporting bodies, other entities who provide services to Comfort Cool related to the products and services provided to you by Comfort Cool and information from publicly available sources.
Information obtained from the use of our Website:
When you use our website, we collect information that is sent by your browser to our website. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses. We also use Lead Handling System and Google Analytics to collect this information about your interaction with our websites.
We use this information to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, direct marketing and advertising.
Through the use of a ‘cookie’, we can record information about your visit to our website including the clickstream to, through and from our site (including date and time), the pages visited, page interaction information and methods used to browse away from the page. This information is used anonymously and in aggregate, and is collected and logged for statistical purposes. Through analysis of these records, we are able to provide an improved service when users revisit our websites.
A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and your preferences. The only personal information a cookie can contain is information you personally supply. A cookie cannot read data from your hard disk or read cookie files created by other websites.
Comfort Cool uses cookies to track user traffic patterns and to provide a better service for users when they visit the website. Users can set their browsers to provide notification when a cookie is received, and the opportunity to accept or reject the cookie. Users can also refuse all cookies by turning the function off in their browsers, although this may affect your browsing experience.
Sensitive information:
The Privacy Act also protects your sensitive information. If we need to obtain this type of information, we will ask for your consent, except where otherwise permitted by law.
4. How do we use your information?
We collect, use and exchange your information so that we can:
(a) Assess Account Applications made by you.
(b) Assess whether to provide or continue to provide goods, services or credit to you.
(c) For the purpose of a credit reporting body or another credit provider assess any other application for credit or managing credit provided to you.
(d) For our internal management purposes, that are directly related to the provision or management of consumer, commercial or other credit, to assess the provision of credit.
(e) Assess particular commercial credit related purpose in relation to you or any guarantor.
(f) Assess a credit guarantee purpose of ours in relation to you or any guarantor.
(g) Assisting you or any guarantor to avoid defaulting on your, his or her obligations in relation to consumer credit provided by us to you or any guarantor.
(h) Assist for the purpose of a prospective guarantor considering your potential liability considering whether to offer to act as a guarantor in relation to the credit or to offer property as security for the credit.
(i) Assist for a purpose related to the enforcement, or proposed enforcement, of any guarantor’s guarantee.
(j) Assist for the purpose of collecting payments that are overdue in relation to consumer or commercial credit provided by us to you or a guarantor.
(k) To provide you with the products and services requested by you.
(l) To make you aware of Comfort Cool’s other products and services.
(m) To offer to you products and services provided by Comfort Cool alone or with its business partners or associates.
We may also collect, use and exchange your information in other ways where are permitted by law.
Direct Marketing:
If you don’t want to receive direct marketing, you can tell us by advising our compliance officer.
5. Who do we exchange your information with?
We exchange your information with our related company Comfort Cool Controls Pty Ltd (“Comfort Cool Controls”), so that our company and Comfort Cool Controls may adopt an integrated approach to its customers. Comfort Cool Controls may use this information for any of the purposes mentioned in section 4.
Third parties:
We may exchange your information with third parties where this is permitted by law or for any of the purposes mentioned in section 4.
Third parties include:
(a) Guarantors.
(b) Government and law enforcement agencies or regulators.
(c) Credit reporting bodies and credit providers.
(d) Entities established to help identify illegal activities and prevent fraud.
Sending information overseas:
We use Symantec EV Cloud in Amsterdam to securely store the information. In the future we may use other third parties who operate or hold data outside Australia. Where we do this, we make sure that appropriate data handling and security arrangements are in place. Please note that Australian law may not apply to some of these entities.
6. Credit checks and credit reporting.
When you apply to us for credit or propose to be a guarantor, we need to know if you are able to meet repayments under your agreement with us. We also want to avoid giving you further credit if this would put you in financial difficulty. One of our checks involves obtaining a credit report about you.
Credit reports
A credit report contains information about your credit history which helps credit providers assess your credit applications, verify your identity and manage accounts you hold with them. Credit reporting bodies collect and exchange this information with credit providers like us and other service providers such as phone companies. The Privacy Act 1988 limits the information that credit providers can disclose about you to credit reporting bodies, as well as the ways in which credit providers can use credit reports.
What information can we exchange with credit reporting bodies?
The information we can exchange includes your identification details, what type of credit you have, how much is your credit limit, whether or not you have met your loan or credit payment obligations and if you have committed a serious credit infringement (such as fraud). We also ask the credit reporting body to provide us with an overall assessment score of your creditworthiness. The credit reporting bodies we use are Veda Advantage Information Services and Creditor Watch. You can download their respective privacy policies at:
Veda – www.veda.com.au
Experian – www.creditorwatch.com.au
What we do with credit‐related information?
We use information from credit‐reporting bodies to confirm your identity, assess applications for credit, manage our relationship with you and collect overdue payments. We may also use this information as part of arriving at our own internal assessment of your creditworthiness. We store credit‐related information with your other information. You can access credit‐related information we hold about you, request us to correct the information and make a complaint to us about your credit‐related information. See sections 8 and 9.
Other rights you have: Credit providers may ask credit reporting bodies to use their credit‐related information to pre‐screen you for direct marketing. You can ask a credit reporting body not to do this. Also, if you have been, or have reason to believe that you’re likely to become, a victim of fraud (including identity fraud), you can ask the credit reporting body not to use or disclose the credit‐related information it holds about you.
7. Keeping your information secure.
We keep your hard‐copy or electronic records on our premises and systems or offsite using trusted third parties. Our security safeguards include:
Staff education: We train and remind our staff of their obligations with regard to your information.
Taking precautions with overseas transfers and third parties: When we send information overseas or use third parties that handle or store data, we ensure that appropriate data handling and security arrangements are in place.
System security: When you transact with us on the internet via our website we encrypt data sent from your computer to our systems. We have firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing our systems. When we send your electronic data outside our company we use dedicated secure networks or encryption. We limit access by requiring use of passwords.
Building security: We have protection in our buildings against unauthorised access such as alarms, cameras and guards (as required).
Destroying data when no longer required: Where practical, we keep information only for as long as required (for example, to meet legal requirements or our internal needs)
8. Accessing, updating and correcting your information.
You can ask for access to your basic information (for example what transactions you have made) by calling us. To obtain a copy of current credit‐related information we hold about you, you can visit our office or call our compliance officer at our NSW Head Office.
For more substantial information, such as details of what is recorded in your credit file, please call us or send a written request to our compliance officer at our NSW Head Office.
There is no fee for making the initial request, but in some cases there may be an access charge to cover the time we spend locating, compiling and explaining the information you ask for. If there is an access charge, we will give you an estimate up front and confirm that you’d like us to proceed. Generally, the access charge is based on an hourly rate plus any photocopying costs or other out‐of‐pocket expenses. You will need to make the payment before we start, unless you’ve authorised us to debit your account.
We try to make your information available within 30 days of your request. Before we give you the information, we will need to confirm your identity.
In certain circumstances we are allowed to deny your request or limit the access we provide. For example, we might not provide you access to commercially sensitive information. Whatever the outcome, we will write to you explaining our decision.
It is important that we have your correct details, such as your current address and telephone number by writing to our compliance officer at our NSW Head Office. You can ask us to correct any inaccurate information we hold or have provided to others (including credit‐related information) by contacting our compliance officer. If the information that is corrected is information we have provided to others, you can ask us to notify them of the correction. We do not charge a fee for these requests.
If your request relates to credit‐related information provided by others, we may need to consult with credit reporting bodies or other credit providers. We will try to correct information within 30 days. If we cannot complete the request within 30 days, we will let you know the reason for the delay and try to agree to a timeframe with you to extend the period.
If we are able to correct your information, we will inform you when the process is complete.
If we disagree with you that information should be corrected, we will let you know in writing our reasons. You can ask us to include a statement with the relevant information, indicating your view that the information is inaccurate, misleading, incomplete, irrelevant or out‐of‐date. We will take reasonable steps to comply with such a request.
9. Making a privacy complaint.
We accept that sometimes we can get things wrong. If you have a concern about your privacy (including credit‐related matters), you have a right to make a complaint and we will do everything we can to put matters right.
To lodge a complaint, please write to our compliance officer. We will review your situation and try to resolve it straight away.
We acknowledge every complaint we receive and provide our name, a reference number and contact details of the investigation office. We keep you updated on the progress we are making towards fixing the problem.
Usually, it takes only a few days to resolve a complaint. However, if we are unable to provide a final response within 45 days, we will contact you to explain why and discuss a timeframe to resolve the complaint.
If your complaint is about our practices relating to credit‐related information, then we may need to consult with other organisations, including credit reporting bodies or credit providers.
We will acknowledge receipt of the complaint within seven days. If we cannot resolve the matter within 30 days, we will contact you and explain the reason for the delay, the expected timeframe to resolve the complaint and seek your agreement to extend the period.
If you are not satisfied with our handling of your matter, you can refer your complaint to external dispute resolution. We suggest you do this only once you have first followed our internal complaint processes set out above.
If your complaint is about the way we handle your personal information, you may also contact the Office of the Australian Information Commissioner by calling them at 0421211712, online at admin@comfortcool.com.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.
10. How to contact us or find out more.
Our website: comfortcool.com.au
OR
Telephone: 0421211712