Insurance at 60 Privacy Policy

Effective 25 May 2020

This policy describes what personal information about you we collect and how it is used and shared.

Our commitment to protecting your privacy

At Open, we believe that your data is always yours, and that personal information should remain private unless you choose otherwise. We strive to protect the confidentiality and security of the information that you share with us.

What kinds of information do we collect?

Things you do and information you provide

When you sign up or subscribe to Open, we collect personal information from you depending on what information you choose to disclose to us and how you use the Open Services, which may include:

• your name, date of birth, gender;
• contact details such as your residential address, telephone numbers, email and social media handles;
• information relevant to providing a product or service, such as:
  • underwriting information like your claims history and driving history; and
  • financial institution account details like your credit card or bank account number, for example if the product or service is paid for in this way or to make a claim payment;
• information obtained as part of the management and processing of a claim, for example information on a police report;
• details of insurance policies you hold or have held;
• sensitive information such as health information (for example, where health is relevant to underwriting an insurance policy or dealing with, managing or processing a personal injury claim) or criminal records (for example where this information is relevant to underwriting an insurance policy or processing a claim);
• your location or activity including IP address, and whether you’ve accessed third party sites; and
• other information we think is necessary.

We also collect the content and other information you provide when you use our products or services, including when you sign up for an account, purchase a financial product, make a change to a product or make a claim. We also collect information about how you use our products or services, such as the types of content you view or engage with, or the frequency and duration of your activities.

Device information

We collect information from or about the computers, phones, or other devices where you install or access our products or services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent products and services across your devices. Here are some examples of the device information we collect:

• attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers;
• device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals; and
• connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

Information from third-party partners

We collect your personal information directly from you when we can. However, there may be occasions where we collect your personal information from someone else, like:

• our authorised representatives, distributors, referrers, agents, business partners, affiliates, insurers or related companies;
• our service providers;
• third parties for the purposes of assessing a claim;
• people you have authorised us to deal with about your policy;
• the Australian Financial Complaints Authority or any other external dispute resolution body;
• the Insurance Reference Services, by accessing the Insurance Reference Services database; and
• any other organisation or person where you have consented to them providing your personal information to us or consented to us collecting personal information from them.

Telephone, email and chat conversations

We record and securely store all telephone conversations with customers for quality and coaching purposes. All emails and chat sessions are also stored securely.

Government related identifiers

Open doesn’t ask for, use or disclose government related identifiers of an individual (e.g. your tax file number). Should Open come into possession of any such identifier we will notify you in writing by email, and take steps to de-identify and destroy the information as soon as practicable.

How do we take care of your personal information?

We care about the security of your personal information and we take steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

• confidentiality requirements and privacy training of our employees;
• security measures to control access to our systems and premises;
• only giving access to personal information to a person who is verified to be able to receive that information;
• ensuring third parties meet Open’s privacy obligations; and
• electronic security systems, such as firewalls and data encryption on our website.

We only keep your information for as long as we require it for our purposes or as required by law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

How do we use your information?

We will use your personal information for the purposes we collected it, as well as purposes that are related, such as the following purposes:

• handling your enquiries;
• considering your application for a product or service;
• pricing an insurance policy (including deciding what excess to offer and ascertaining if any discounts are available);
• providing a product or service;
• handling and processing claims;
• debt collection;
• handling complaints;
• managing our business operations (including our IT infrastructure, website, and statistical/maintenance purposes) and company research and development;
• conducting market research and communicating details about our products and services, including for marketing purposes;
• auditing, quality assurance and training; or
• any other purposes communicated to you at the time we collect your personal information and as permitted by law.

You may contact us at any time to “opt out” of receiving marketing communications or unsubscribe by following the links in any relevant electronic messages.

How is your information shared?

We share your information with third-party service providers for the purposes of providing our products and services to you.

We may also share your personal information:

• if we are required to by a court order, subpoena or other legal requirements;
• you have consented to us sharing it with a third-party for a particular purpose;
• with an insurance broker or agent acting on your behalf or who you have designated to act on your behalf;
• where it is necessary for a third-party to assist us in providing our products and services, for example, reinsurers, insurance intermediaries, insurance reference bureaus, lawyers, accountants, loss adjusters and others involved in the providing of products and services or claims handling processes; or
• for any other purposes which are within reasonable expectations or where permitted by law.

Some examples of these third parties that we may share your personal information with are:

• our authorised representatives, distributors, referrers, agents, business partners, affiliates;
• our insurers or underwriters;
• Insurance Reference Services (a member-based organisation supporting Australian general insurance company members with understanding policyholder claims history);
• our service providers; and
• our professional advisers.

Third-parties will only be provided with access to your information as is reasonably necessary and we will require that such third parties comply with this privacy policy, our data security requirements and any applicable laws.

Sharing outside of Australia

If your personal information is collected or supplied to an organisation outside of Australia we will ensure it will be held, used or disclosed only in accordance with the Privacy Act. We may store your information in cloud or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is held in this way, disclosures may occur in overseas countries. If this occurs, we will ensure that it will be held, used or disclosed only in accordance with the Privacy Act.

How will we notify you of changes to this Policy?

From time to time we may need to update this Policy. We will notify you by email of any changes to this Policy. Your continued use of the Service after notification of such a change means that you accept the changed content.

How can I access or correct information about me?

We will always give you access to your personal information unless there are legal reasons why we can’t. You can ask us to access or correct your personal information that we hold by calling us on 1300 811 224 or emailing [email protected]. We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover the costs when giving you access, but we’ll always check with you first.

If we can’t give you access, we will explain why in writing. If you have concerns, you can make a complaint to us by contacting us – see ‘How to contact Open with questions or complaints’.

What happens if something goes wrong

Where any of the personal information under our control is compromised as a result of a breach of security, we’ll take reasonable steps to investigate. In accordance with the Notifiable Data Breaches Scheme, we will notify you in the event your personal information is involved in a data breach that is likely to result in serious harm. This notification will include recommendations about the steps you should take in response to the breach. We will also notify the Office of Australian Information Commissioner (OAIC) of eligible data breaches.

How to contact Open with questions or complaints

If you have any questions about this policy, or a complaint about our handling of your personal information, or if you believe that your privacy has been breached, please contact us using the contact information below.

Chat: @ beopen.com
Email: [email protected]
Phone: 1300 811 224