OUR COMMITMENT TO PRIVACY
Value Comparisons Australia Pty Ltd (ACN 137 786 979) and its related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth)) (Related Bodies Corporate) (together Compare Broadband, usor we) is an Australian company which assists you with your internet, energy and other needs. We own and operate the:
- https://www.comparebroadband.com.au (Compare Broadband Website); and
- https://www.compareenergy.com.au (Compare Energy Website),
(together, the Websites).
We respect the privacy of everyone who uses the Websites and related comparison services we offer and we are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act).
Our Websites work in a number of different ways to assist you with your internet, energy and other needs.
We work with an extensive range of participating internet, energy and other service providers who:
- we feature on our Websites;
- are listed on our Websites;
- advertise with us; or
- we otherwise have a commercial relationship with.
(a Participating Provider).
- the Compare Broadband Website allows you to compare plans from Participating Providers offering products and services, including but not limited to, NBN ADSL2+, Naked DSL, cable, Pay TV and mobile broadband.
- the Compare Energy Website allows you to provide information about you and your energy requirements which we then share with our Participating Providers so they (or their agent) can contact you to discuss the different options available to you.
The Websites are free to use. However, we may receive a fee or commission from Participating Providers if:
- we have an advertising or other commercial relationship with the Participating Provider; or
- you choose one of their plans and sign up through us; or
- you call a Participating Provider using the phone number listed on our Websites; or
- you provide your contact details in a completed enquiry and a Participating Provider calls you.
OTHER TERMS WHICH MAY APPLY TO YOU
Other terms may also apply to you and the information we hold about you. For example, our Terms and Conditions of Use apply to users of the Websites.
Sometimes we also provide a privacy collection statement at the time we collect personal information from you, for example, when you enter your personal information into a form on one of our Websites. This privacy collection statement may include additional terms.
If you are employed with us, you may also have specific privacy terms in your employment contract with us.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
When you use our Websites or comparison services
We generally deal directly with you when you use one of our Websites or comparison services. When you make an enquiry or request a quote on our Websites, by telephone or other means we make available, or you purchase a plan from one of our Participating Providers through us (whether through our Websites, over the telephone or by other means we make available), or we otherwise do business with you, a record is made which may include your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the purpose for which we are dealing with you, but will typically include:
- personal details such as your name, date of birth, title, email address, postal address and phone number;
- your answers to questions we ask about your internet or energy usage, needs and preferences;
- your answers to questions about your household;
- geolocation information based on your interactions with us online;
- any additional personal information you provide to us, or authorise us to collect, as part of your interaction with us; and
- other contact details and information regarding our interactions and transactions with you.
We do not generally collect personal information that is classified as “sensitive information” under the Privacy Act. However, in specific circumstances our third party service providers or agents may collect sensitive information on our behalf. Sensitive information is generally only ever collected to the extent that it is relevant to providing you with comparison services or for the purposes of a transaction with our Participating Providers and otherwise in accordance with the Privacy Act.
We collect personal information when recruiting people to work with us, such as your name, title, date of birth, gender, contact details, qualifications and work history (including references and other information included in a CV or cover letter as part of the application process). Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). We may collect additional details such as your tax file number and superannuation information after offering you a position and other information necessary to conduct background checks to determine your suitability for certain positions.
We may also collect relevant information from third party sources such as LinkedIn and other professional websites.
There may be other relevant privacy terms which apply to you in your employment contract.
Visitors to our Websites
The way in which we handle the personal information of visitors to our Websites is discussed further below.
What happens if you don’t provide your personal information?
You can always decline to give us any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested or we may not be able to do business with you effectively. For example, we may not be able to process your quote. If you have any concerns about personal information we have requested, please let us know.
HOW AND WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
We generally collect personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person.
We may also collect personal information about you from other sources, publicly available sources of information or from other persons or organisations (including related and third party contractors and suppliers who assist us to operate our business).
For example, we may use a third party provider to call you on our behalf who may collect personal information about you and provide it to us so that we can provide you with our comparison services. Or we may collect personal information about you from an advertising or marketing partner we work with. We may use third parties to collect feedback and reviews of our services and automate online transactions.
We collect personal information reasonably necessary to carry out our business, to assess and manage your needs, and to provide our Website and comparison services. We may also collect information to fulfil administrative functions associated with these services.
The purposes for which we usually collect and use personal information depends on the nature of your interaction with us, but may include:
- comparing broadband, mobile, Pay TV or energy plans or other products or services offered by Participating Providers;
- customising the plans we show you based on your preferences and circumstances;
- assessing your eligibility for plans offered by Participating Providers;
- responding to requests for information and other general inquiries in respect of our Websites;
- to share your personal information with a Participating Provider so that they can contact you directly about your needs;
- managing our relationship with you if you use our Website or related services are a supplier, Participating Provider or other business partner;
- undertaking marketing, promotional and related activities (discussed further below);
- researching, developing and expanding our Websites and services;
- informing you of our activities, competitions and promotions;
- informing you of products and services offered by Participating Providers;
- obtaining feedback and reviews of our services;
- responding to enquires and complaints; and
- comparing or selling any other products, plans or services we may offer from time to time;
- recruitment processes.
We may also use some of your information for other business purposes which you would expect. For example:
- for our reasonable commercial purposes (including quality control and administration, and assisting us to develop new and improved services);
- to confirm your identity or as otherwise required by law;
- to follow up with you after you request information or further assistance from us;
- to comply with any requirement of any applicable statute, regulation, rule or good practice, whether originating from Australia or elsewhere;
- we may monitor, record and analyse any telephone calls, online communication and other communications between you and us, to check your instructions;
- to analyse, assess and improve our services to you;
- for training and quality purposes;
- to keep you informed (through our Websites and your account with us, by post, email or telephone, SMS, MMS and other communication channels) of additional deals, products or offerings offered by us or a Participating Provider, unless you indicate that you do not wish us to do so; and
- to improve the relevance of marketing messages we may send you (which you can opt out of as explained below).
We also collect and use personal information for market research purposes and to innovate our delivery of comparison services. We may sometimes provide aggregate and de-identified information to our Participating Providers or other third parties for market research purposes.
HOW DO WE INTERACT WITH YOU VIA THE INTERNET?
A cookie is a small text file that is placed on your device (such as your computer, smartphone or other internet-enabled device) when you visit a site or page to collect data about the usage of our Websites at a later date. The cookie will help the Websites, or another website, to recognise your device the next time you visit the site. Most web browsers are set by default to accept cookies.
In addition to cookies, we may also use web beacons and other storage technologies to collect information from our Websites. Like cookies, web beacons and similar storage technologies collect data about the usage of our Websites and can recognise your device the next time you visit.
The types of cookies we use
Specifically, we may use from time-to time use the following cookies:
- Strictly necessary cookies that are required for the operation of our Websites. If you opt to disable these cookies, you may find that certain sections of our Websites do not work properly for you (for example, you may not be able to access all of the content that we make available).
- Performance cookies which recognise and count the number of users to our Websites and help us see how users move around our Websites. These cookies do not collect information that identifies a visitor. We only use such information to improve our Websites. This information helps us to find out how well our Website are working and highlight where it can be improved.
- Functionality cookies which are used to recognise you when you return to our Websites and assist us to personalise your content and Website experience by remembering your preferences. These cookies are also used to provide services you have asked for. Information collected by functionality cookies may or may not be anonymised, but they cannot track your browsing activity on other websites.
- Targeting cookies which are used to record your visit to our Websites, the pages you have visited and the links you have followed. These cookies are used to advertise relevant products to you on other websites, based on the products and categories you looked at on our Websites.
Third party cookies and technologies
Third party cookies are cookies that are set by a domain other than the one being visited by you. If you visit one of our Websites and a separate company sets a cookie through that Website this would be a third party cookie.
To try and bring you offers and advertisements that are of interest to you, we may have relationships with third party companies including, Google and other social media platforms and providers (Third Party Providers) and allow them to place cookies on our Websites.
These Third Party Providers may:
- use third party cookies, web beacons, and other storage technologies to collect or receive information from our Websites and elsewhere on the internet;
- compare de-identified information from us with information collected elsewhere on the internet; and
- use that information to provide measurement services and target ads to you.
How you can manage your cookies?
Some of the websites that let you control what information is collected about you are:
Our Websites may contain links to third party websites. We are not responsible for the content or privacy practices of websites that are linked to our Websites.
CAN YOU DEAL WITH US ANONYMOUSLY?
We will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is not practicable for us to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our promotions.
HOW DO WE HOLD INFORMATION?
We store information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
We maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY US?
- legal and regulatory requirements and guidance;
- limitation periods that apply in respect of taking legal action;
- our ability to defend ourselves against legal claims and complaints;
- good practice; and
- the operational requirements of our business.
Our Websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our Websites are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.
DO WE USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
We may use and disclose the personal information you provide to us so that we or our agents, subcontractors, Participating Providers or other business partners can inform you about great deals, products, services, offers and promotions, where these may be of interest to you. You may be contacted or receive direct marketing content via:
- electronic messaging (such as SMS or MMS);
- social media;
- other direct marketing channels.
By providing your personal information to us, you understand that we will use and disclose your personal information in this way.
However, if you do not want to receive direct marketing communications, you can opt out at any time by contacting us using the contact details below or using the opt-out functionality contained in the relevant electronic message.
If you opt-out of receiving marketing material from us, we may still contact you in relation to our ongoing relationship with you (for example, if you have separately asked us to call you back about a specific query).
We also use your phone number to call you back when you have submitted your phone number on one of our Websites. If your phone number is on the Do Not Call Register, for the purposes of the Do Not Call Register Act 2006 (if it applies) by submitting your telephone number to us, you give your consent (via the relevant privacy collection statement and / or when you agree to our Terms and Conditions to be contacted by telephone on that number by either us or one of our Third Party Providers, agents or partners engaged or directly by a Participating Provider offering their products and services on our Websites so we can deal with your specific query or request.
You understand and confirm that in this context the communication is solicited. However, you otherwise provide your consent to being contacted by telephone for this purpose.
For certain activities we conduct, we may be required by law to obtain your ‘explicit, informed, consent’. If this is required by law, we will ask for your ‘explicit, informed, consent’ clearly.
HOW DO WE USE AND DISCLOSE PERSONAL INFORMATION?
Using our Websites and comparison services
The purposes for which we may use and disclose your personal information will depend on the reason we are interacting with you. Key examples are set out below.
Disclosures to Participating Providers
If you choose to sign up to a plan with a Participating Provider through us, we may disclose information about you to our Participating Providers where required to provide you with that plan.
In addition to the above, when you have submitted your details on one of our Websites (such as filling out an enquiry form) or otherwise provided your personal information to use, we may share your personal information with Participating Providers we have partnered with so they (or their agents) can contact you directly about your needs.
Disclosure to contractors and other service providers
We may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for logistical services, data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
We also disclose your personal information to our trusted partners and service providers who provide call centre and customer relation services on our behalf. These trusted partners and service providers may then contact you directly.
Personal information may also be shared between Related Bodies Corporate of Compare Broadband, located in Australia and overseas.
Third party privacy policies
Third parties (including our service providers, agents, partners and Participating Providers) to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Use and disclosure for administration and management
We will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
- administering billing and payments and debt recovery;
- planning, managing, monitoring and evaluating our services;
- quality improvement activities;
- statistical analysis and reporting;
- training staff, contractors and other workers;
- risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
- responding to enquiries and complaints regarding our products and services;
- obtaining advice from consultants and other professional advisers; and
- responding to subpoenas and other legal orders and obligations.
Business sale or corporate transaction
We may share your personal information with third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us).
Other uses and disclosures
DO WE DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?
It is likely that your personal information will be disclosed to overseas recipients including to service providers who may handle, process or store your personal information on our behalf.
The recipients of such information may be located in Australia, United Kingdom and other jurisdictions from time-to-time.
We only ever disclose your personal information outside Australia where we are permitted to do so under Privacy Act. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.
There are other circumstances where we may disclose your personal information to an overseas recipient. For example, where you have provided your consent or we are otherwise permitted to do so under the Australian Privacy Principles or other relevant laws.
HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You are entitled to access your personal information held by us on request. To request access to your personal information please contact us using the contact details set out below.
You will not be charged for making a request to access your personal information but you may charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?
You may make a complaint about privacy by contacting us at [email protected].
We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within 7 days.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that we may have breached the Australian Privacy Principles or the Privacy Act 1988 (Cth), a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
HOW CAN YOU CONTACTUS?
If you need to contact us, please do so by:
- emailing [email protected]
- by phoning 1300 764 000
- by mailing Compare Broadband, PO Box 241, Woodend VIC 3442.