Privacy Policy
ListSure Pty Ltd, its authorised agents, its Related Companies, and relevant third parties (including verification agents, credit reporting agencies and official record holders who provide services to us or on our behalf) collect your personal information and access your personal information lawfully held by third parties to verify your identity, under the Australian Privacy Act 1988, so we can offer you our products and services, or otherwise as permitted by law. Without this information, we cannot offer our products and services to you.
ListSure and the relevant third parties may use your personal information for the purpose of monitoring and improving our services.
Protecting your privacy and the confidentiality of your personal information is important to us. This policy sets out how we aim to do so.
Definitions
In this Privacy Policy:
‘Our’, ‘Us’ and ‘We’ refers to ListSure Pty Ltd ABN 91 613 466 256 of Level 4, 99 Bathurst Street, Sydney NSW 2000 Australia.
‘Personal Information’ is any ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable:
whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.
‘Related Companies’ has the same meaning as related bodies corporate and the meaning in section 50 of the Corporations Act 2001 (Cth).
‘Sensitive Information’ is a sub set of Personal Information defined as information or an opinion about an individual’s:
racial or ethnic origin; or
political opinions; or
membership of a political association; or
religious beliefs or affiliations; or
philosophical beliefs; or
membership of a professional or trade association; or
membership of a trade union; or
sexual orientation or practices; or
criminal record.
‘you’ and ‘your’ refers to our customers and prospective customers. It also refers generally to users of our websites as well as a person sharing their information with us, such as a third party or an agent acting on behalf of you.
Our Commitment
We recognise that your privacy is very important to you. We are committed to protecting the privacy of your Personal Information in accordance with the Privacy Act 1988 (Cth).
The Privacy Act details Australian Privacy Principles that set minimum standards for how government agencies and private sector organisations may collect, use, disclose, store, provide access to and correction of Personal Information.
We are committed to complying with the Australian Privacy Principles.
Currency and Status of our Privacy Policy
Our current privacy policy is detailed below. It is current as of and from 20 December 2021. We suggest that you read it thoroughly.
This policy may change from time to time and all changes will be posted on our web site so please check it periodically. Alternatively, you can contact the Privacy Officer by sending an email to info@listsure.com.au and request a copy of our most recent policy.
Whenever using our website, you should read this policy in conjunction with our Terms of Service.
Personal Information we collect
The Personal Information we collect depends on the products and services we offer you or you use or apply for. Typically, the details we collect and hold include your name, contact details (address, phone and fax number, email address) date of birth, gender and account payment details. We may also collect information that is specific to a particular product.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law.
Why we collect your Personal Information
We collect Personal Information to provide, offer and administer our various products and services, or otherwise as permitted by law. Such purposes include responding to your enquiries, providing you with assistance you request of Us, maintaining and administering our products and services; processing your survey or questionnaire responses; market research and the collection of general statistical information using common internet technologies such as cookies; providing you with marketing information regarding other products and services (of Ours or a third party); quality assurance and training purposes; performing administrative operations (including accounting and risk management) and any other purpose identified at the time of collecting your information.
We may combine or link Personal Information we already hold about you to other Personal Information we collect about you.
If you do not consent to us collecting, using or disclosing all or some of the Personal Information we request, we may not be able to provide you with our products or services. It may also prevent us from maintaining or administering your products or services or the provision of information regarding our products or services or those of any third party.
How we collect your Personal Information
We collect your Personal Information from you in various ways and at several different points, such as telephone conversations (including any form of mobile phone text messaging), our websites, electronic devices or communication and hard copy forms.
Whenever you deal with us we will collect this information directly from you unless it is unreasonable or impracticable for us to do so. In some instances we may collect your information from someone else. This may include our authorised representatives, our distributors or referrers, agents or related entities, family members, anyone you have authorised to deal with us on your behalf, and/or our legal or other advisers. For example, where you make an application in joint names, where it is provided to us by a third party (such as our authorised agents) with your consent or where we need to obtain information from professional experts for the purposes of products and services.
If you provide Personal Information to us about another person, we rely on you to have made or make them aware that you will, or may, provide their information to us and the types of third parties. We may provide it to, the relevant purposes we and any of the third parties will use it for and how they can access it. If you have not done, or will not do, these things, you must tell us before you provide the relevant Personal Information.
A number of interactive tools or facilities may be available on our websites. If you use any of these tools or facilities, we generally do not collect your Personal Information unless a particular tool permits you to suspend or save information and recover those details at a later time. In these circumstances, your Personal Information may be retained on our systems but is not processed or used by us except that it may be used for the purposes of online quoting and subsequent follow up.
Anonymity and Pseudonymity
Unless it is impracticable, you have the option of interacting with us anonymously or by the use of a pseudonym. For example, you may visit and browse our websites and use some of our online facilities without having to reveal any Personal Information.
Cookies and the collection of information through our website
We may use a cookie that collects anonymous traffic data. A cookie is a message given to a web browser by a web server and which is then stored in a text file. Each time the browser requests a page from the server this message is sent back which enables the user’s computer address (IP address) to be identified.
We may use the information provided by cookies and IP addresses to analyse trends, administer the site, or for research and marketing purposes to help us better serve our clients. No information which personally identifies you will be collected through the cookies. You can set your browser to notify you before you receive a cookie so you have the chance to accept it and can set your browser to turn off cookies. No information which personally identifies you will be collected as part of these cookies.
Direct Marketing
On occasion, we may use your Personal Information to provide you with information about the products and services we or our distributors, referrers, agents, business partners, affiliates and any proposed new or incoming insurer may offer. If you do not wish to receive any of this information you can let us know at any time by contacting us.
We never sell, rent or trade Your Personal Information.
We may share Your Personal Information with Our Related Companies and other third parties who provide services to Us or on Our behalf.
Third party marketing service providers may combine the Personal Information we disclose to them with information they already hold about you in order to provide you with more relevant advertising about our or their products and services.
Third parties are prohibited from using your Personal Information for purposes other than those for which it is supplied.
Sharing and Disclosing your Personal Information
We may share your Personal Information with our Related Companies, and other third parties who provide services to us or on our behalf.
We will not share your Personal Information with any unrelated party except under the following circumstances:
in accordance with this Privacy Policy,
as provided in any privacy notice we give you;
where a product or service you apply for is provided or supplied by or through a third party;
where a third party, such as a mailing house, carries out activities on our behalf;
if disclosure is otherwise required in order to provide you with a particular product or service;
in order to ensure our ability to continue providing products and services;
if disclosure is required for the purposes of conducting business analysis in order to improve our products and services;
if disclosure is required by law or requested by a statutory authority; including the Financial Ombudsman Service, other dispute resolution providers, government bodies, regulators and other law enforcement agencies;
where a third party has an interest in the product or service we supply, for example a referral agent, distributor or intermediary;
where it is necessary for a third party to assist us in providing our services, for example, underwriters, insurance intermediaries, reinsurers, insurance credit bureaus, identification services, external IT service providers, external claims data collectors and verifiers, lawyers, accountants, and others involved in management of our products and services;
where you have provided your consent - which may be given expressly or may reasonably be implied by your conduct
Your Personal Information may also be disclosed to some of our service providers who are located overseas, including but not limited to the Philippines. Details of who they are may change from time to time. You can contact us for details. We aim to protect your Personal Information by taking reasonable steps to ensure that the overseas service provider has similar protections in relation to privacy or that we enter into contractual arrangements with the recipient that safeguards and ensures compliance with Australian privacy law and this Privacy Policy. However, in some cases we may not be able to take reasonable steps to ensure they do not breach the Privacy Act and they may not be subject to the same level of protection or obligations that are offered by the Privacy Act.
By proceeding to acquire our services and products you agree that you cannot seek redress under the Act or against us (to the extent permitted by law) and may not be able to seek redress overseas.
Related and unrelated third parties to whom your Personal Information is disclosed are required to keep the information confidential and only use it for the same purposes as we are permitted to use it.
The bodies we deal with to identify you and undertake credit checks are:
Illion - www.illion.com.au
FrankieOne - www.frankieone.com
Credit Information
We may exchange credit-related information for the purposes of assessing your application for products and service.
One of our checks may involve obtaining a credit report about you from a credit reporting body. When we request a credit report, or when we are required to share ongoing information about the credit you hold with us, we need to give the credit reporting body information about you (such as your name and address and other personal information we hold about you) and your application (such as the type and amount of credit you’re applying for) to make sure we receive the correct credit report.
Quality of your Personal Information
We aim to ensure that your Personal Information is accurate, complete and up to date.
During the course of your relationship with us we will ask you to inform us of any changes to your Personal Information. You should, however, contact us at any time to update your Personal Information or advise us that the information we have is not accurate or complete.
Security of your Personal Information
We are committed to keeping your Personal Information secure and will use all reasonable precautions to protect it from loss, misuse or interference and unauthorised access, modification or disclosure, including:
Physically securing external and internal premises;
Maintaining computer and network security such as user identifiers and passwords to control access to computer systems;
Restricting access to your Personal Information to employees or those who perform services on our behalf who are authorised to handle your Personal Information and on a 'needs to know' basis;
Entering into confidentiality agreements with relevant employees and third parties;
Appropriate training of staff;
Retaining your Personal Information for no longer than it is reasonably required to service a policy, continue to provide any products and services to you, and for monitoring and improving our services, unless we are required by law to retain it for longer;
Taking reasonable steps to destroy or de-identify Personal Information that we no longer require or which was unsolicited and we identify that we would not have otherwise collected it from you.
Access to and Correction of your Personal Information
You may generally access the information we hold about you and request corrections. This right is subject to the exceptions detailed in the Australian Privacy Principles. For example, we may refuse access where the:
information may have an unreasonable impact on the privacy of others;
request is frivolous or vexatious;
information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings;
information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.
If we refuse access or to give access in the manner requested by you we will let you know why in writing.
Where providing access would reveal evaluative information in connection with a commercially sensitive decision-making process, we will provide an explanation for the decision rather than direct access to the information.
In most cases, you may access your Personal Information at no cost to you by contacting our Privacy Officer by sending an email to info@listsure.com.au.
For access to complex information or more detailed requests for access to your Personal Information, for example, access to information that is archived, we may require you to place your request in writing and charge you a fee for our reasonable costs of retrieving and supplying the information to you.
In all cases you will be asked to verify who you are before your Personal Information is provided.
All requests for Personal Information will be handled in a reasonable period of time.
Notifiable Data Breaches
The Notifiable Data Breaches Scheme requires us to notify you and the Office of the Australian Information Commissioner (OAIC) of certain data breaches and recommend steps you can take to limit the impacts of a breach (such as password changes).
The scheme requires us to notify about a data breach that is likely to result in serious harm to affected individuals. There are exceptions where notification is not required. Such as where we have already taken appropriate remedial action that removes the risk of serious harm to any individuals.
If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.
If you believe that any personal information we hold about you has been impacted by a data breach, you can contact us.
How to contact us
If you have any questions, suggestions or complaints about our privacy practices or this privacy policy, please contact the Privacy Officer by sending an email to info@listsure.com.au. We will respond to your question, suggestion or complaint as soon as possible.
Depending on the nature of your enquiry we may ask you to put your request in writing. To contact the Privacy Officer you can send an email to info@listsure.com.au or write to:
ListSure
Level 4
99 Bathurst Street
Sydney NSW 2000
Australia
If you are not satisfied with our response to your enquiry or complaint you can contact the Privacy Officer and request that it be reviewed by a senior staff member who will endeavour to resolve your dispute within 30 days. If you are still not satisfied we will tell you about any external dispute resolution avenues which may be available to you.