BINKS & ASSOCIATES PTY LTD PRIVACY POLICY

Binks complies with the Australian state and commonwealth privacy laws including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (collectively, “Privacy Laws”). Binks is committed to the privacy of its clients and potential clients (collectively, “Clients”) and to continue providing services in a confidential and safe manner. This Privacy Policy summarises how Binks handles personal information with respect to any services provided by or to a customer by Binks (collectively, “Services”). Binks will respect and keep secure all personal and sensitive information provided to Binks by Clients in accordance with applicable privacy laws and this Privacy Policy. By continuing to use the Services, a Client acknowledges acceptance of this Privacy Policy as updated from time to time.

INFORMATION BINKS COLLECTS AND HOLDS

Personal information

Personal information is defined by the Privacy Laws as “information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.” From time to time, Binks may collect certain of a Client’s personal information. Binks only collects that personal information that is reasonably necessary for or related to Binks’s business or to facilitate the use of the Services by Clients. Generally, the only personal information Binks collects about a Client is that information which a Client choose to disclose to Binks or which a Client authorises Binks to obtain.

The type of information Binks collect may include a Client’s:

(a) personal name

(b) age

(c) gender

(d) residential/work address

(e) email addresses

(f) telephone number

(g) physical location

(h) property ownership profile

Sensitive Information

Sensitive information is a special category of the most sensitive personal information including racial or ethnic origin, political opinion, police record, health and disability information etc.

Binks does not collect sensitive information.

How Binks collects and holds personal information

Where possible, Binks will collect a Client’s personal information directly from a Client, but information may also be collected via:

(a) IP loggers;

(b) wi-fi routers; and

(c) GPS devices

Personal and sensitive information may be collected from a Client when a Client provides it to Binks directly.

Binks has established appropriate physical, electronic and managerial procedures to safeguard any information Binks collects. This helps prevent unauthorised access, maintains data accuracy and ensures that the information is used correctly.

All data transferred to and from Binks’s servers is encrypted and a firewall is in place to prevent intrusion. All data stored within Binks’s systems is designed to only be able to be accessed by Binks’s officers, employees, contractors and the relevant hosting facility.

The purposes for which Binks collects, holds, uses and discloses personal information.

Binks collects personal information that Binks considers relevant for the purpose of providing Binks’s services or the Services. Binks will not use or disclose personal information collected about an individual for the purposes of direct marketing unless the individual has given Binks consent to do so. Binks will not disclose any personal information to any third-party overseas recipients unless the individual has given Binks consent to do so.

How Binks may use personal information

Some of the ways Binks uses personal information includes to:

(a) communicate with a Client and others as part of Binks’s business including the Services

(b) enable Binks to provide a service

(c) personalise a Client’s Binks experience

(d) send a Client information regarding changes to Binks’s policies, other terms and conditions, on-line services and other administrative issues

(e) manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing, credit scoring and staff training, collecting debts and market or client satisfaction research)

(f) prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks

(g) verify information given to Binks

(h) carry out market research and analysis, including satisfaction surveys

(i) provide marketing information to a Client (including information about other products and services offered by selected third party partners) in preferences a Client have expressed

(j) manage Binks’s infrastructure and business operations and comply with internal policies and procedures, including those relating to auditing accounting billing and collections IT systems data and website hosting business continuity and records, document and print management

(k) resolve complaints and handle requests for data access or correction

(l) comply with applicable laws and regulatory obligations (including laws outside a Client’s country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism

(m) comply with legal process and respond to requests from public and governmental authorities (in outside a Client’s country of residence)

(n) establish and defend legal rights protect Binks’s operations or those of any of Binks’s group companies or insurance business partners, Binks’s rights or property and/or that of Binks’s group companies, a Client or others and pursue available remedies or limit Binks’s damages

To whom does Binks disclose a Client’s personal information?

Binks may disclose a Client’s personal information to:

(a) government authorities (where required by law including workers compensation laws)

(b) third parties involved in court action (where required by law)

(c) other parties that provide support services to Binks including support services, merchant services, online marketing programs for the purposes of marketing Binks products only

(d) professional advisers

(e) potential business partners or purchasers

What happens if a Client doesn’t provide personal or sensitive information?

If a Client does not provide some or all of the information requested, Binks may not be able to provide the services to such Client.

Using a pseudonym or engaging with Binks anonymously

Where practicable, a Client will be given the opportunity to engage with Binks on an anonymous basis or using a pseudonym. Due to the nature of Binks’s services, in most cases, the use of a pseudonym anonymity will not be possible.

Credit card details

Binks does not collect or store credit card numbers.

Website cookies and usage information

When a Client access Binks’s website, Binks may use software embedded in Binks’s website and Binks may place small data files (or cookies) on a Client’s computer or other device to collect information about which pages a Client’s view, how a Client reach those pages, what a Client does when a Client visits a page, the length of time a Client remains on the page and how Binks performs in providing content to a Client. A cookie does not identify individuals personally, but it does identify computers.

A Client can set a Client’s browser to notify a Client when a Client receive a cookie and this will provide a Client with an opportunity to either accept or reject it in each instance.
 Binks may gather a Client’s IP address as part of Binks’s business activities and to assist with any operational difficulties or support issues with Binks’s services. This information does not identify a Client personally.

External links

The Binks website may contain links to other websites. When a Client accesses these links, Binks recommends that a Client read the website owner’s privacy statement before disclosing a Client’s personal information. Binks does not accept responsibility for inappropriate use, collection, storage or disclosure of a Client’s personal information collected outside Binks’s website.

Opting out of direct marketing communications

Where Binks uses a Client’s personal information to send a Client marketing and promotional information by post, email or telephone, Binks will provide a Client with an opportunity to opt-out of receiving such
information. By electing not to opt-out, Binks will assume Binks has a Client’s implied consent to receive similar information and communications in the future. Binks will ensure that Binks’s opt-out notices are clear, conspicuous and easy to activate. If a Client wish to opt out of communications from Binks, please use the contact details below.

Cross-border disclosures of a Client’s personal information

Binks does currently use off-shore service providers with regard to storage of personal information data including email services, support service and telephonic services. Binks reserves the right to use data hosting facilities and third-party service providers both in Australia and overseas to assist Binks with providing our goods and services.

Right to opt out of personal information use

Binks will comply with any request from a Client to process or cease using their personal information data as soon as practicable.

Unless a Client specifically opts-out of use of personal information for marketing purposes, Binks will assume Binks has a Client’s implied consent to receive similar information and communications in the future.

Right to rectification

Binks has obligations to take reasonable steps to correct personal information held by Binks if Binks is satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading for the purpose for which it is held.

Binks will comply with any request from a Client to update and/or correct their personal information data within 28 days.

Binks may take reasonable steps to verify a Client’s identity before making any such changes.

In cases where the information was provided by a third party, Binks may not be able to correct information and a Client may have to contact the third-party that gave information to Binks.

How to contact Binks regarding privacy

To exercise a right under this Privacy Policy, make further inquiries or to complain about a breach of the law (including the Australian Privacy Principles or a registered Australian Privacy Principles code, if applicable) a Client should contact Binks as follows:

The Privacy Officer

BINKS & ASSOCIATES PTY LTD

P.O. Box 67 Surrey Hills VIC 3127

Email: privacy@binksandassociates.com.au

Binks will take all complaints regarding privacy of information seriously. Binks will respond to any requests, questions, or complaints as soon as possible in a reasonable time frame.

Policy changes

Binks may revise this Privacy Policy from time to time by updating this page. The revised Privacy Policy will take effect when it is posted on Binks’s website or otherwise communicated to a Client. Binks suggests that a Client review Binks’s Privacy Policy regularly.

In this Privacy Policy, “Binks” means BINKS & ASSOCIATES PTY LTD [ACN 006546381] and any “Related Body Corporate” within the meaning of the Section 50 of the Corporations Act 2001 (Cth)