Wilson & Bradley Pty Ltd (W&B) is committed to managing personal information in accordance with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth) (the Privacy Act), and in accordance with other applicable privacy laws (Privacy Laws). To the extent W&B handles your credit-related personal information, W&B will also comply with the Privacy (Credit Reporting) Code 2014 (Version 2.1) (Credit Reporting Code).
We only collect, use or disclose personal information (which may include sensitive information as defined in the Privacy Act), including credit-related information, in accordance with Privacy Laws, the Credit Reporting Code and this Policy.
In this Policy, “we”, “us” and “our” means W&B.
Your privacy is important to us
We understand that the privacy and confidentiality of your personal and credit-related personal information is important.
Our intention is to use the personal information provided by you to us and credit-related personal information obtained by us to make any dealings with W&B better suited to your needs.
Our Policy describes how we collect, hold, use and may disclose your personal information through our website (https://www.wilbrad.com.au/) (Website), and other interactions (e.g. customer service inquiries, etc.) you may have with us (collectively, the Services).
Our aim is to ensure the quality, integrity and security of your personal information, including credit-related information.
What information do we collect?
We collectpersonal information – that is, any information or opinion about an identified individual or individual who is reasonably identifiable.
The personal information that we collect about you will depend on the Services we provide to you, or that you may enquire about.
Some examples of personal information we collect may include (but is not limited to): your name and date of birth; contact details such as telephone number, email address or delivery address; payment or banking information (including related payment verification information); and, any other information you choose to provide us with.
We do not collect sensitive information, unless you provide it to us. Sensitive information includes (but is not limited to), information about a person’s health (including medical information), race or ethnic origin, political opinions, religious or philosophical beliefs, and criminal history.
We may also collect credit information, being credit related personal information lawfully created and accessible within the Australian credit reporting system including:
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);
whether you have or have not met any monthly repayment obligations;
whether you have defaulted on a payment (ie. a payment that is at least 60 days overdue and over $ 150.00 in value) provided we have notified you in accordance with the Privacy Act;
whether you have paid any amount previously reported as being in default;
that another credit provider has sought credit-related personal information about you from a credit reporting body;
information about the types of consumer or commercial credit, and the amounts of credit, you have sought from a credit provider;
information about court proceedings related to credit provided to you or for which you have applied;
personal insolvency information and other publicly available information relating to your credit worthiness;
a credit provider’s reasonable belief that you have committed a serious credit infringement;
any other information lawfully obtainable within the Australian credit reporting system;
credit eligibility information which is credit-related information about you that we obtain from a credit reporting body such as CreditorWatch (the details of which are set out below), together with information we derive from such information based on its own analysis including internally generated scores, ratings and other assessments used to evaluate your credit worthiness. We generally receive from CreditorWatch information about existing credit accounts, previous defaults, repayment history information etc.
Why do we collect personal information?
We collect personal information, including credit-related information from you when it is reasonably necessary in the course of our business. We collect it to provide you with the purposes for which it was collected (and related purposes) which would be reasonably expected by you; purposes to which you have consented; to supply you with the products and Services that you have requested from us and to provide you with the best possible service; or as otherwise authorised by law.
Reasons we may collect personal information include: to communicate with you, including by email, telephone and mail; to answer your questions and comments and provide you with information or advice; to obtain payment for our products and Services, assess a credit application for, and if successful, administering your credit application and account; and, to comply with laws or regulations or to comply with any directions given by regulators or authorities.
4. How do we collect personal information?
We collect your personal information in a number of ways and for various purposes, including:
You give it to us when you interact with us.
This may happen when you contact us, sign up to our newsletter, create an account, purchase our products online, or use our Services.
We collect information when you use our Services.
The purpose of collection is to improve users experience of the site and for record keeping purposes. Such information may include:
information from our website www.wilbrad.com.au including the number of visits, dates of visits, pages viewed and navigation of the site; and
transaction information including the type of Services you requested or provided, your order details, delivery information, date and time the service was provided, amount charged, and payment method.
We obtain information from outside sources like marketing mailing lists, public information (including public posts to social networking sites) and commercially available personal, identity, geographic and demographic information. If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
We may also collect your personal information to comply with legal requirements or obligations, law enforcement, and for public safety purposes.
If you provide personal information about another person to us, we require that you:
inform that person you have done so and provide them with a copy of this policy; and
confirm to us that you have that person’s consent to provide such information for the purpose specified.
5. How do we use your information?
We will only use and disclose your personal information:
for the purposes outlined in Section 4; or
if we otherwise get your consent to do so, in accordance with this Policy and the Privacy Act.
We may also disclose your personal information, including your credit information, to lenders, other credit providers and credit reporting bodies, CreditorWatch (contactable on the details set out below). In particular, we may disclose to CreditorWatch information about you failing to meet your payment obligations or if you commit a serious credit infringement. CreditorWatch may include any information provided to it by us in reports that are then provided to other credit providers for the purpose of such credit providers assessing your credit worthiness. Our disclosures of your personal information to third parties are on a confidential basis, in accordance with relevant non-disclosure agreements, and/or otherwise in accordance with law. [Creditor Watch can be contacted:
at: GPO Box 276, Sydney NSW 2001 or otherwise by phone on 1300 50 13 12.
We will not use your personal information for any purpose for which you would not reasonably expect us to use your personal information.
We will only use or disclose your personal information for the purposes of direct marketing if:
we collected the information directly from you;
it is reasonable in the circumstances to expect that we would use or disclose the information for direct marketing purposes;
we provide you with a simple means to ‘opt-out’ of direct marketing communications from us; and
you have not elected to ‘opt-out’ from receiving such direct marketing communications from us.
We will not use or disclose credit related personal information for direct marketing purposes except to the extent permitted under the Act, for the purpose of CreditorWatch assessing your eligibility to receive direct marketing communications sent on our behalf. You may make a request directly to CreditorWatch not to use your credit related personal information for these purposes.
You may opt-out of receiving marketing information from us at any time by:
clicking on a link in the email communications sent to you; or
contacting our Privacy Officer.
Please allow a reasonable period for your request to be actioned.
6. Cookies and Third Party Technologies
You may adjust your browser to refuse to accept cookies, remove cookies or notify you when a cookie is set by editing your web browser preferences or options. Each browser is different, so check the “Help” menu on your browser to learn how to change your cookie preferences. You do not have to accept all cookies sent to you by our website. However, depending on the particular cookie you reject, you may not be able to use some features of our website.
7. Sharing your personal information
To ensure that we can meet your specific needs, we may share your personal information with third parties where the law otherwise allows, including:
third parties engaged by us to perform functions or provide products or services on our or their behalf such as mail outs, marketing or advertising;
third parties that sponsor or promote us;
credit reporting bodies and credit providers;
our professional advisors, including our accountants, auditors and lawyers;
persons authorised by you to receive information held by us; and
any person as required or permitted by any law.
Generally, we require that third parties who handle or obtain personal information as service providers to acknowledge the confidentiality of your personal information, undertake to respect an individual’s right to privacy and comply with the Privacy Act and this Policy.
We may also disclose aggregate or de-identified data that is not personally identifiable with third parties. Aggregate data is created by pooling information about individuals and describing the data in the aggregate (e.g. 20% of customers who clicked on the X promotion participated in the promotion).
8. Access and correction of personal information
If you require access to your personal information, please contact our Privacy Officer.
We reserve the right to charge you reasonable expenses for providing access to or updating your personal information, for example, a fee for photocopying any information requested by you.
We endeavour to ensure that the personal information it holds is accurate, complete and up-to-date. Please contact our Privacy Officer if you believe the information we hold about you is inaccurate, incomplete or out-of-date.
Where necessary to resolve a request for correction of your credit related personal information, we may also consult with other relevant entities, including but not limited to [Creditor Watch. Our use or disclosure of your credit related personal information for correction purposes is permitted by the Privacy Act.
We are not obliged to correct any of your personal information if we do not agree that it requires correction. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
We will respond to all requests for access to or correction of personal information within a reasonable time.
9. Storage and security of your personal information
We will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you the products and Services. We will also retain your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where we no longer need to process your personal information for the purposes set out in this Policy, we will delete your personal data from our systems.
We hold your personal information in a combination of hard copy and electronic files. Electronic files may be stored in servers that are operated and maintained by us and third parties under contract with us and they are located in Australia. Credit eligibility information, such as information we receive from CreditWatch for the purpose of assessing credit worthiness, is stored through equally secure methods set out in this paragraph.
We take reasonable and appropriate measures to protect your personal information from loss, misuse, alteration, disclosure or interference and unauthorised access.
We endeavour to keep information, including your personal information provided by you or on your behalf, secure and confidential. However, we cannot guarantee or warrant the security of any information you send to us using online communication. You submit information online at your own risk.
Links to other websites
Our Services may provide a link or otherwise provide access to third party websites. We provide these links because we believe you may find them useful and informative. Please be aware, however, that we have no control over, do not review, and are not responsible for third party websites, their content, or any goods or services available through the third party websites.
Our Policy does not apply to third party websites, and any information that you provide to third party websites, you provide at your own risk. We encourage you to review the privacy policies of any third party websites that you may interact with.
10. Notifiable Data Breaches
Despite our every effort to protect your personal information, there remains the possibility that a breach of our security could occur. In the event of any loss, or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will:
seek to rapidly identify and secure the breach to prevent any further breaches;
engage the appropriate authorities where criminal activity is suspected;
assess the nature and severity of the breach including the type of personal information involved and the risk of harm to affected individuals;
notify the affected individuals directly if appropriate and where possible;
if appropriate, put a notice on our website advising our customers of the breach; and
notify the Australian Information Commissioner (at the OAIC) if the breach is significant.
11. Privacy complaint
If you have a complaint about how we collect, use, disclose, manage or protect your personal information, or otherwise consider there may be a breach of the Privacy Act or the APPs, please contact our Privacy Officer. You will need to provide us with sufficient details regarding your complaint as well as any supporting evidence and/or information.
If your complaint relates to credit related personal information and/or our failure to comply with our obligations regarding credit related personal information under the Privacy Act and/or the Credit Reporting Code:
we will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless we inform you otherwise and seek your agreement in writing;
we may consult with relevant third parties such as CreditorWatch and/or other credit providers, in order to sufficiently and expeditiously resolve the complaint; and
if your complaint relates to our refusal to provide access to, or correct, your credit related personal information, you may complain directly to the Office of the Australian Information Commissioner.
The Privacy Officer will investigate the issue and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or complain to the Australian Information Commissioner via www.oaic.gov.au.
12. How to contact us
If you have any questions about W&B and privacy, wish to provide feedback about this Policy, would like to access information held by W&B about you, or wish to make a privacy related complaint, please contact our Privacy Officer at:
1800 633 507
The Privacy Officer Wilson & Bradley Pty Ltd 94 Bell Street Preston VIC 3072
Please submit any complaint in writing. We will respond to your complaint as soon as possible.
13. Further information
Further information about the application of the Privacy Act can be found at the website of the OAIC at www.oaic.gov.au.