Effective date: To be confirmed
Folio Digital Pty Ltd (ACN 685 514 550) (Folio, we, us, our) is committed to protecting your privacy and to handling Personal Information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, hold, use, disclose and protect Personal Information.
1. Scope and about this Policy
This Policy applies to Personal Information we handle through the Folio Broker Platform (Platform), our websites, and our dealings with customers, users and other individuals. ‘Personal Information’ has the meaning given in the Privacy Act.
Our customers are typically insurance brokers and their businesses (Clients). Where a Client inputs Personal Information about its own clients and contacts into the Platform (Client-Controlled Data), the Client is primarily responsible for how that information is collected and used. We handle Client-Controlled Data on the Client’s behalf to provide the Platform, in accordance with our agreement with the Client and this Policy, and not for our own independent purposes except as permitted by law.
2. The Personal Information we collect
Depending on your dealings with us, we may collect:
- identity and contact details (such as name, business name, email, phone and role);
- account and login information for users of the Platform;
- billing and payment details;
- records of your communications with us;
- technical, usage and device information when you use the Platform or our websites (such as IP address, log data and analytics information); and
- any other information you choose to provide.
Client-Controlled Data may include Personal Information about a Client’s own clients and contacts (such as policyholders and their representatives), which the Client inputs or which is synchronised from the Client’s other systems at the Client’s direction.
3. How we collect Personal Information
We collect Personal Information directly from you (for example, when you register, contact us, or use the Platform), from the Client organisation you are associated with, automatically through your use of the Platform and websites (including through cookies and analytics), and, where relevant, from third parties you authorise (such as connected systems).
If you provide us with Personal Information about another person, you must ensure you are authorised to do so and, where required, that the person is aware of this Policy.
4. Why we collect, hold, use and disclose Personal Information
We use Personal Information to: provide, support, secure and improve the Platform; administer accounts and users; process billing and payments; communicate with you; maintain security and prevent misuse; comply with our legal obligations; and, where permitted, tell you about our products and services (which you can opt out of).
We may use aggregated or de-identified information, which does not identify any individual, to operate, analyse and improve the Platform.
5. Disclosure of Personal Information
We may disclose Personal Information to: our service providers and sub-processors (such as hosting, infrastructure, analytics, payment and support providers) who are bound to protect it; entities within the Folio group; a party involved in a sale or restructure of our business; and regulators, law enforcement, or others where required or authorised by law. We do not sell Personal Information.
6. Overseas disclosure
Some of our service providers may store or process Personal Information outside Australia (for example, in countries and regions to be confirmed). Where we disclose Personal Information overseas, we take reasonable steps to ensure it is handled consistently with the APPs.
7. Data security and data breaches
We take reasonable technical and organisational steps to protect Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure. No method of storage or transmission is completely secure.
If an eligible data breach occurs, we will comply with the Notifiable Data Breaches scheme under the Privacy Act, including notifying the Office of the Australian Information Commissioner (OAIC) and affected individuals where required, and we will cooperate with any affected Client.
8. Cookies and analytics
Our websites and the Platform may use cookies and similar technologies, and analytics tools providers to be confirmed, to operate the service, remember your preferences, and understand usage. You can control cookies through your browser settings, though some features may not function properly without them.
9. Direct marketing
Where permitted, we may send you marketing communications about our products and services. You can opt out at any time using the unsubscribe facility in the message or by contacting us. We handle electronic marketing in accordance with the Spam Act 2003 (Cth).
10. Accessing and correcting your Personal Information
You may request access to, or correction of, the Personal Information we hold about you (APPs 12 and 13) by contacting our Privacy Officer. We may need to verify your identity. In limited circumstances we may decline a request as permitted by law, in which case we will explain why. Where the relevant information is Client-Controlled Data, we may refer you to the relevant Client.
11. Complaints
If you have a privacy complaint, please contact our Privacy Officer. We will acknowledge and investigate your complaint and respond within a reasonable time. If you are not satisfied with our response, you may complain to the OAIC (oaic.gov.au).
12. Retention and destruction
We retain Personal Information for as long as necessary to provide the Platform, meet our legal and record-keeping obligations, and resolve disputes, after which we take reasonable steps to destroy or de-identify it. Client-Controlled Data is retained and deleted in accordance with our agreement with the relevant Client.
13. Changes to this Policy
We may update this Policy from time to time. The current version, with its effective date, will be available on our website.
14. Contact us
Privacy Officer, Folio Digital Pty Ltd — privacy email to be confirmed, postal address to be confirmed. If you have any questions about this Policy or how we handle Personal Information, please contact us.
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