Assurant Services Australia Ltd - Privacy Notice Telstra & Assurant Enterprise Trade In Program
How We Use & Disclose Collected Information
This Privacy Notice (“Notice”) describes how Assurant Services Australia Pty Ltd ABN 18 613 632 367 (a company incorporated in Australia) referred to as “Assurant”, “We”, “Us”, “Our” throughout this Policy, collects, holds, uses and discloses personal information in compliance with and pursuant to the Privacy Act 1988 (Cth) as amended (the “Act”) and the Australian Privacy Principles. Assurant Services Australia Pty Ltd is an affiliate of Assurant, Inc (NYSE AIZ), a global provider of risk management solutions.
Assurant respects your concerns about privacy. Assurant is providing a Consumer Device Trade-In Program website https://tradein.assurant.com.au/telstra/enterprise-trade-in the “Service” to serve Our Telstra enterprise and Government customers. The Service allows users of the website (consumer and small business Telstra customers) to enter into a trade-in transaction for the sale of eligible devices with Us (“Trade-In Transaction”). In order to provide this Service, Assurant collects and processes your personal information as set forth in this Notice and pursuant to applicable privacy legislation.
We manage your personal information in an open and transparent manner and employ safeguards designed to protect your information, including to:
- comply with the Australian Privacy Principles (“APPs”).
- ensure that we manage your personal information transparently.
- collect only the personal information reasonably necessary to provide the Service to you.
- tell you how We use your personal information.
- let you know if we disclose your personal information to anyone else (including anyone overseas) and if so, under what circumstances this may happen.
- employ safeguards designed to protect your personal information.
- respond to any request received from you regarding marketing communications.
- make sure your personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by Us; and
- ensure that, where, appropriate, you may access and correct your personal information that is held by us in the context of the Service.
This Notice describes how We collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use the Service, and how We comply with the Act and the APPs.
You must read this Notice before providing Us with any personal information or using the Service. By providing Us with your personal information and using the Service, you are confirming your agreement to this Notice.
This Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided associated with each.
If you have any concern about providing information to Us or your information being used in any manner permitted by this Notice and the Terms of Service, you should not visit Our Web Portal or otherwise use the Service.
1. What information We collect
We collect your personal information in the following ways:
1.1 When you use our Service
When you use the Service; so that We can administer the Service, We ask users to provide Us with their: (i) first name and surname and (ii) contact details, including email address, and phone number.
1.2 When you communicate with Us
When you contact Us through the Service. We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).
You may report any problems or security concerns with the Service by contacting customer support at: by e-mail at:enterprise.services@assurant.com.
The customer support centres are located within Australia and are operated by Us.
2. We process your personal information for the following purposes:
We collect and process your personal information to provide the Service to you and to contact you in relation to the provision of the Service, including.
- providing the Service to you.
- verifying your identity.
- managing your account.
- preventing fraud and other criminal activities.
- to assist us to operate Our business and to improve Our services and performance, including staff training, risk management, recordkeeping, developing and enhancing the Service.
- recognizing you on the Service, improving your experience, increasing security of Our networks and systems, and measuring use and effectiveness of Our Service.
- communicating with you and customizing Our support responses.
- conducting market research and customer surveys
- investigating complaints received from you and others about the Service, or Our products and services and tracking potential issues and trends to better serve you.
- making decisions about, and implementing, reorganizations or sales of all or part of Our business.
- where you give Us consent.
- to enforce Our Terms of Service, protect your safety or the safety of others, investigate fraud, or respond to a government request; and
- to comply with our legal obligations.
2.1 Withdrawing consent
Wherever We rely on your consent, you can always withdraw your consent at any time with effect for the future by contacting customer support by e-mail enterprise.services@assurant.com.
2.2 Automated decision making
We do not use automatic decision making or profiling.
3. How We share your personal information
3.1 Sharing information with affiliates
Our affiliates (meaning entities controlled by, controlling or under common control with Assurant, Inc.) may have access to your personal information for the purposes stated in this Notice. For example, your support enquiry may be handled by technical support staff located within or outside Australia (such as in India, Singapore, the United Kingdom, the Philippines or the United States). Your personal information may be shared with Our affiliates, such as the Assurant group company through which you obtained the Service, for customer relationship management purposes (for example – when you make a complaint).
3.2 We employ third parties to help Us with the Service.
We employ third party companies and individuals to facilitate the Service (for example, customer support, analysis, audit, application, database hosting). These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your personal information is limited to those individuals which are authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorize such third parties to disclose or use it for other purposes.
Please see Our List of Service Providers to learn more about the service providers We use and the services that they provide to Us.
3.3 Sharing personal information with other recipients
We may disclose your personal information to public authorities if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.
We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to lawyers and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.
3.4 Data processing outside of your country
Your personal information may be transferred to, and processed by, personnel at our affiliates located in the United States and United Kingdom (“Overseas Recipients”) in order to support the program and fulfil services pursuant to this Notice. Prior to disclosing your personal information to an Overseas Recipient, We have an obligation under APP 8(1) to ensure that the Overseas Recipient meets at least one of the requirements of APP 8(1) as relates to the privacy laws and obligations that apply to that Overseas Recipient in relation to your personal information, as well as an obligation under APP 8(1) that the requirements of APP 6 Use or disclosure of personal information are met. We take reasonable steps to comply with Our Overseas Disclosure Obligations. By using the Service, you authorise the disclosure of your personal information in the manner and to the third parties and locations described in this Notice.
4. Your Choices and Rights
4.1 Your choices and rights
You have the following rights with regard to the data processed by Us:
- the right of access to your personal data stored by us in accordance with APP 12; and
- the right to rectify incorrect or complete correct personal data stored by us in accordance with APP 13.
4.2 Additional information
You can exercise any of your rights by contacting Us through the customer support centre at: 1300 117 083 or by e-mail at: enterprise.services@assurant.com.
You can also send Us your request by writing to Us at the address provided in the “Contact Us” section of this Notice. In order to safeguard your personal information from unauthorised access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.
In certain situations, and subject to applicable laws, including data protection laws, We may not be able or obliged to comply with all or part of your request. For example, We may not comply with an access request if doing so would reveal personal data about another person or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping.
If you have unresolved concerns, you have the right to complain to an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) to have your concerns heard and assessed.
5. Data Retention
We retain personal information you provide while your service contract is active or as needed to provide the Service, and up to 15 years in accordance with applicable law. We may retain your personal information if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Notice and Our Terms of Service We may retain personal information, for a limited period of time, if requested by law enforcement.
6. Important Information
6.1 Minimum age
We do not knowingly collect personal information from anyone under the age of 18 or such equivalent minimum age for consenting to data processing in the relevant jurisdiction. You must be at least 18 years of age (or ensure a person of 18 years of age or older is present for the duration of a service), or the equivalent minimum age in the relevant jurisdiction, to use the Service.
6.2 Changes to this Privacy Notice
We may update this Notice from time to time. If We make any material changes to this Notice, We will notify you via the relevant website, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. As We may make changes to this Notice, We suggest that you review it each time you access and use the Service. Please review changes carefully. If any changes are made to this Notice, We will revise the Effective Date that is indicated on the Notice.
6.3 Security Procedures
We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.
6.4 Contact Us
If you have questions or comments about this Notice, please contact Us online or by postal mail.
We welcome your questions or comments regarding this Notice. Please send enquiries to Data Protection Officer, Assurant Services Australia Pty Ltd, Level 4, Deutsche Bank Place, 126 Phillip Street Sydney 2000 NSW, or send Us an email at dataprotectionofficer.apac@assurant.com
You also have the right to file a complaint directly with the Office of the Australian Information Commissioner under applicable local data protection law. You may make a complaint with the OAIC.
List of Service Providers
This List of Service Providers identifies the third party service providers (who are not considered to be part of the Assurant group companies) We use in connection with the Mobile App and :
| Service Provider (Name) | Amazon Web Services |
| Location (Country) | Australia |
| Service Provider’s Processing Purposes | Mobile app hosting |
| Service Provider (Name) | Salesforce |
| Location (Country) | Australia |
| Service Provider’s Processing Purposes | In-app chat service provider |
| Service Provider (Name) | MixPanel |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Mobile analytics to improve user experience |
| Service Provider (Name) | SendGrid |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Email for mobile app users |
| Service Provider (Name) | LogMeIn |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Remote support via remote device control and screen sharing |
| Service Provider (Name) | Rollbar |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Mobile app crash monitoring. |
| Service Provider (Name) | Intercom |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Sending User Messages |
| Service Provider (Name) | Firebase |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Supports measurement of mobile app performance (for example – when the app crashes) |
| Service Provider (Name) | Fing |
| Location (Country) | United Kingdom |
| Service Provider’s Processing Purposes | Scans the users’s Wi-Fi network to attempt to detect & identify connected devices which can be automatically added to the user’s device inventory |
| Service Provider (Name) | Ookla |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Network speed test |
| Service Provider (Name) | IP-API |
| Location (Country) | Romania |
| Service Provider’s Processing Purposes | ISP lookup services |
| Service Provider (Name) | Datadog |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Infrastructure performance monitoring |
| Service Provider (Name) | Nice |
| Location (Country) | Australia |
| Service Provider’s Processing Purposes | Customer contact management |
Effective Date: 2 April 2024