The Critical Factor Pty Ltd respects the privacy of the people we deal with and we uphold high standards of privacy practice and security. This policy explains how we handle personal information and how we interact with you online.
Whenever we handle personal information, we take steps to ensure that appropriate standards of privacy practice and security are applied.
The information we collect
For some of our products and services it is necessary for us to collect ‘personal information’ such as your name, personal information and contact details.
Generally, we do not collect sensitive information about you unless required by law or where you consent for us to do so (and in any event only where it is relevant to your product). We will not collect sensitive information about you where this is expressly prohibited by local law. Sensitive information includes information relating to:
- political or religious beliefs
- sexual orientation and sexual life
- criminal convictions
- membership of professional or trade associations or unions
- biometric and health information
- information about your affiliation with certain organisations, such as professional associations.
Why we collect personal information
We collect personal information about you which is reasonably necessary to:
- provide you with quality products or services.
- conduct marketing and social functions
- maintain your contact details
- fulfil our legal obligations,
Without such information, we may not be able to process your application or provide you with an appropriate level of service. In such circumstances, we will process your application and provide you with the most appropriate level of service that we can.
How we collect your information
We collect personal information about you directly from you — this can be in person, in documents you give us, from telephone calls, emails, competitions you enter, your access to our website or from transactions you make. We take reasonable steps to be transparent about how and why we collect personal data.
We may also collect your personal information from joint account holder(s) or third parties including public sources, your adviser(s), employer (or its affiliates), agents, introducers, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).
How we store your information
We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include processing or storage in the cloud, which may mean in practice that this information is stored outside Australia. Where this occurs, we take steps to protect the security and integrity of personal information.
We also keep records of our interactions with you (including by telephone, email and online) and of your purchase history.
How we use your information
We use personal information about you for the purpose for which it was provided to us, including to:
- process applications
- administer and manage our products and services (including monitoring, auditing, and evaluating those products and services)
- model and test data (in a controlled environment)
- develop scores, risk assessments and related analytical tools
- communicate with you and deal with or investigate any complaints or enquiries
We may also:
- anonymise your data for our own purposes including market research
- use or permit our affiliates to use your personal information for related purposes to the extent that it is lawful to do so without your express permission.
While we may sometimes – where it is lawful and with your permission if necessary – share personal information with companies we do business with (e.g. in product development, joint venture arrangements or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.
When your information is disclosed
Subject in all cases to local law, we may share personal information within the The Critical Factor Pty Ltd , and may disclose personal information outside the The Critical Factor Pty Ltd:
- as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator
- to our service providers, who provide services in connection with our products and services
- to our affiliates
- as contained in the terms and conditions of any specific product or service.
Keeping information secure
We use security procedures and technology to protect the information we hold. Access to and use of personal information within The Critical Factor seeks to prevent misuse or unlawful disclosure of the information — this includes internal policies, auditing, training and monitoring of staff.
If other organisations provide support services, we require them to take appropriate technical and organisational measures to secure the privacy of the information provided to them.
How you can access or correct your information
You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
Dealing with The Critical Factor online
When you visit The Critical Factor websites you will generally browse anonymously unless you have logged into a client portal.
A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. While cookies are not considered personal information, they are generally used on The Critical Factor sites to:
- manage advertising – when you see one of our ads on a third party website, cookies are sometimes used to collect anonymous information about the page you visit and the type of software you are using
- monitor traffic – we use anonymous information to track how people are using the The Critical Factor site. This may include time of visit, pages visited and some system information about the type of computer you are using
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences).
Your rights if you are in the EU
As provided for in the General Data Protection Regulation, you have the right to access your data; to correct or rectify your data; to delete your data subject to applicable law; to have your data processed only in accordance with applicable law; to have copies of your data to be moved to another controller; to object to our processing your data otherwise than in accordance with the law; and to withdraw any consent to our processing your data at any time. Please email email@example.com to exercise any of those rights.
If you have any questions or complaints regarding privacy or information handling, please write to firstname.lastname@example.org or contact us by phone. Please mark communications to the attention of our Privacy Officer. We will respond to let you know who will be handling your matter and when you can expect a further response.