The EPH Group is committed to protecting your privacy and Personal Information when you deal with the EPH Group and ensuring that it collects, stores and deals with your Personal Information appropriately and lawfully, including in accordance with the relevant privacy legislation.
The Privacy Act 1988 (Cth) (‘Privacy Act’) and the Australian Privacy Principles (APPs), as contained in the Privacy Act, apply to the collection of personal information by the EPH Group. The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.
- what types of Personal Information the EPH Group collect and hold;
- the purposes for which the EPH Group collect, hold, use and disclose Personal Information;
- how the EPH Group collect Personal Information;
- how you may access, update, and/or complain in relation to the Personal Information that the EPH Group hold in relation to you and seek any correction to that information;
- how the EPH Group’s collections, uses stores, and discloses credit information and commercial credit eligibility information;
- how the EPH Group disclose Personal Information; and
- disclosure of Personal Information to overseas recipients.
3. Personal Information
The Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) commenced in March 2014 and has replaced the definition of ‘personal information‘ in the Privacy Act 1988 (Cth) with the following: ‘personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. (‘Personal Information’).
4. Purpose of Collecting, Holding or Using Personal Information
The EPH Group collects, holds, discloses and uses your Personal Information:
- to provide you with booking services;
- to administer the EPH Group relationship with you including responding to queries;
- for internal administrative purposes, such as but not limited to procedural assessment, credit approval, risk management, staff training, accounting, billing, product and service reviews;
- to determine the provision of credit in accordance with the terms of the EPH Group Application For Commercial Credit;
- to assess or exchange information relating to your creditworthiness, credit history or credit capacity in accordance with the terms of the EPH Group Application For Commercial Credit;
- to assist in the collection of overdue payments;
- to comply with legislative requirements such as under the Personal Property and Securities Act 2009 (Cth);
- to monitor activity on the EPH Group website(s);
- to identify and inform you about other products or services that may be of interest to you;
- to provide you with information about products, services and offerings that may be of interest to you;
- To distribute our newsletters and other communications either directly or with the assistance of third party services providers
By submitting your Personal Information to the EPH Group, you consent to the EPH Group using your Personal Information in the above ways.
5. Types of Personal Information the EPH Group Collect and Hold
The types of Personal Information the EPH Group may collect from our external parties and hold include (without limitation):
- Your name, gender, date of birth, contact details, image, drivers licence, copy signature;
- Payment details (such as credit/debit card number and expiry date) provided in connection with the purchase of our products and services;
- Insurance provider’s details,
- Company details, company contact details, business premises details;
- Your trade references;
- Financial details including annual earnings, bank account details
- Details of the products and service provided;
- Credit history information;
- information about any application for commercial credit you make with us including the amount of commercial credit you apply for;
- commercial credit reporting information about you from a credit reporting body
6. How the EPH Group Collects Personal Information
The EPH Group may collect personal information about you when you use services provided by the EPH Group or purchase the EPH Group’s goods, make or update a booking to use the EPH Group services, register to receive the EPH Group newsletters or other communications, visit the EPH Group websites, the EPH Group Facebook page or other multimedia platform or otherwise interact with the EPH Group. As well as collecting information directly from you, there may be occasions when the EPH Group collects information about you from a third party. These third parties may include:
- Third Parties making bookings on your behalf, or otherwise interact with the EPH Group on your behalf, including when you make an inquiry with a representative agent but do not proceed to a booking;
- Other related entities to the EPH Group;
- Credit providers and credit reporting bodies; and
- Publicly available sources of information.
7. How the EPH Group Hold Information and Keep it Secure
The EPH Group holds your personal information in a combination of hard copy and electronic files. The EPH Group use third party information system providers who may store or have access to your personal information.
The EPH Group has physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference and loss, and from unauthorised access, modification and disclosure.
The EPH Group may combine personal information it receives about you with other information the EPH Group holds about you. This includes information received from our related entities and/or third parties.
8. Use and Disclosure
The EPH Group understands the importance of keeping Personal Information private, and will only disclose such information to others in limited circumstances. Other parties to which the EPH Group may disclose Personal Information include:
- credit providers and credit reporting bodies in accordance with the terms of the EPH Group’s Application For Commercial Credit;
- the EPH GRoup’s professional advisers;
- government and regulatory authorities;
- The EPH Group related entities;
- Credit Risk Insurers;
- Trade Credit Insurance Providers; and
- Credit Reporting Bodies (default information).
In connection with (or for reasons directly related to) any of the purposes set out in this policy. The EPH Group also discloses Personal Information to contractors who provide services to the EPH Group or who manage services provided to an individual on the EPH Group’s behalf. Personal Information is only disclosed to contractors to the extent necessary to enable them to provide these services.
The EPH Group may be permitted or obligated to disclose Personal Information to other third parties where:
- The EPH Group reasonably believes that the disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety and it is unreasonable or impracticable to obtain your consent to the disclosure;
- there is reason to suspect that unlawful activity, or misconduct of a serious nature, is occurring and that the disclosure is necessary for the EPH Group to take appropriate action in relation to this matter;
- The EPH Group is required or authorized to do so by law and/or an enforcement body; or
- as otherwise permitted by the Privacy Act.
9. Disclosure to Overseas Recipients
The EPH Group shall not directly disclose your personal information to overseas recipients without your prior consent.
10. Retention and Destruction of Personal Information
The EPH Group maintains procedures and standards and takes reasonable steps to prevent unauthorized access to, use, modification, or disclosure of, Personal Information. The EPH Group takes reasonable steps to protect an individual’s information from misuse, interference or loss including the use of firewalls, anti-virus software and ongoing internal monitoring. Once an individual’s information is no longer needed by the EPH Group, reasonable steps are taken to destroy or de-identify it (except where archiving is required for the purposes for which the information was collected).
11. Sensitive Information
Sensitive Information includes information or an opinion about a person’s racial or ethnic origin, political opinions, philosophical or religious beliefs or affiliations, membership of a political, trade or professional association or trade union, sexual preferences or practices, criminal record, health or genetic information, biometric information that is used for the purpose of biometric verification or identification, or biometric templates. The EPH Group will only collect, hold or disclose Sensitive Information if: the individual has consented or the collection is required or authorized by or under law or a court/tribunal order.
12. Credit Information & Commercial Credit Eligibility Information
The EPH Group collects credit information about you which includes, but is not limited to, your identification information and information about any application for commercial credit you make with the EPH Group.
The EPH Group also collects and holds commercial credit eligibility information about you which includes, but not limited to, commercial credit reporting information that the EPH Group receives about you from a credit reporting body – i.e. Australian Securities Investment Commission extracts adverse or default reports, business summaries and profiles, PPSR Registrations, financial performance reports, trade credit reporting information and trade references.
The EPH Group may also collect personal information about any other applicants and/or guarantors included in your application for commercial credit. If you provide personal information about any such third party to the EPH Group, you confirm that you have authority from the applicable individual(s) to your disclosure of their personal information to the EPH Group and to the EPH Group’s use and disclosure of their personal information in accordance with this Policy.
So as to assess an application for commercial credit and your commercial credit standing at any time in the future, the EPH Group may:
(a) collect your personal information (including information about other applicants and any guarantors (if applicable)) from any application for commercial credit you make with the EPH Group;
(b) collect personal information (including credit information) about you, any other applicants and any guarantors (if applicable) from other sources including, but not limited to, any of the EPH Group related entities, credit reporting bodies and credit or debt collections agencies; and
(c) obtain commercial credit reporting information from a credit reporting body about you, any other applicants and any guarantors (if applicable).
The EPH Group may also use your information and, if necessary, disclose it to third party agencies (including, without limitation, the EPH Group’s credit risk insurers) in connection with any credit insurance arrangements that the EPH Group choose to implement, as well as, to register any security interest granted to the EPH Group under the terms of any commercial credit contract that the EPH Group enter into with you.
The EPH Group may also obtain commercial credit reporting information from time to time during the continuation of any commercial credit contract that the EPH Group enter into with you.
The EPH Group may also receive from and/or disclose to any other credit provider or any credit reporting body, personal information relating to your commercial credit worthiness for the purposes of exchange of information, assessing commercial credit worthiness, and/or notification of default at any time whether now or in the future.
Information the EPH Group disclose to a credit reporting body (including default information) in accordance with this Policy may be held by such credit reporting body on its system and used to provide its credit reporting services (including maintaining its credit information files and disclosing information to its subscribers), in accordance with the Privacy Act.
If you default in your payment obligations to the EPH Group, the EPH Group may also disclose information relating to that default account to a collections agency for the purpose of receiving any or all of the amounts outstanding.
The EPH Group may also disclose your personal information, including commercial credit reporting information, to the EPH Group trade credit insurance providers.
13. Access to and Correction of Personal Information/Privacy Complaints
APPs 12 & 13 under the Privacy Act makes it clear that individuals have a right to request access to their personal information, credit information, commercial credit eligibility information and to request its correction. The EPH Group will provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception which applies under the APPs.
The EPH Group may recover from you its reasonable costs of supplying you with access to this information. However, the EPH Group will not charge you for the making of the request or to correct or update your personal information.
Your request to provide access to the personal information about you as held by the EPH Group will be dealt with within a reasonable time.
The EPH Group takes reasonable steps to ensure that the personal information, credit information, commercial credit eligibility information the EPH Group collect, use or disclose is accurate, complete and up to date, relevant, and not misleading. If your personal information, credit information, commercial credit eligibility information is incorrect or changes, please contact the EPH Group’s Privacy Officer in any of the ways set out below so that the EPH Group can update your Personal Information.
If the EPH Group refuses to provide you with access to, or correct, the information, the EPH Group will notify you of its reasons for the refusal to the extent required and how you may complain about the refusal.
If you are not satisfied with the EPH Group’s response, you may also contact the Office of the Australian Information Commissioner: by email: firstname.lastname@example.org; by phone: 1300 363 992; by writing: GPO Box 2999, Canberra, ACT 2601 or GPO Box 5218, Sydney, NSW 2001