Effective Date: November 1st, 2023
This Policy sets out the basis on which we collect personal information (as defined below) from you and the way in which it will be processed by us. Please read this Policy carefully to understand practices regarding your personal information and how we shall treat it. We are committed to protecting and respecting your privacy.
It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements any other such notices and is not intended to override them.
If you have any questions about this Policy, including if you wish to send us a request to exercise any of your legal rights, please contact us at contact@battleface.
Access and Corrections
We take reasonable steps to ensure that your personal information is accurate, complete and up to date. You have the right to request access to or correction of your personal information. If you wish to access the personal information we may hold about you or if you believe that the personal information we hold about you is not accurate, complete or up to date, please contact us. We reserve the right to refuse access to personal information under the grounds permitted by the Privacy Act.
By providing us with personal information, you consent to us using and disclosing your personal data as set out below. This consent remains valid until you alter or revoke it. If you wish to withdraw your consent, including for things such as receiving information regarding our products, services and offers that may be of interest to you, please contact us.
CHANGES TO THIS POLICY
We may update this Policy from time to time. We will notify you of any changes by posting the updated Policy on this page.
TYPES OF PERSONAL INFORMATION WE COLLECT
“Personal Information” is essentially 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 recorded in a material form or not. Please refer to the Privacy Act for full details. We may collect, use, store and transfer different kinds of personal information or ‘personal data’ meaning any information which identifies (or from which we can identify) a natural person. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- “Identity Data”, which comprises your first name, middle name, last name, age and date of birth
- “Contact Data”, which comprises your address, email address and telephone number(s)
- “Technical Data”, which comprises your IP address, browser type and version, time zone setting and location, geolocation, browser plug-in types and versions, operating system and platform and other technology on the device(s) you use to access our website
- “Usage Data”, which comprises information about how you use our website, products and services
- “Profile Data”, which comprises your username and password, insurance policy and claims details
- “Marketing and Communications Data”, which comprises your preferences in receiving marketing from us and third-parties, your communication preferences, and recordings of telephone conversations we have from time to time
- “Transaction Data”, which comprises information enabling us to provide products and services, travel plans, age categories of individuals to be insured, information about your trip and your policy such as the destination, insurance rating and policy, payment card information, and information about any insurance claims you make, including bank information required to process loss payments, and health information required to pay health expenses
We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data may be derived from your information but does not constitute “personal data” in law as it does not directly or indirectly reveal your identity. For example, we may aggregate (i.e. combine with information relating to others) your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be handled in accordance with this Policy.
Special Categories of Personal Data
“Special Categories” of personal data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. This also, for the purposes of this Policy, includes information about criminal convictions and offences.
We may need to collect certain Special Categories of personal data about you in order to provide you with the services you have requested, such as any pre-existing medical or other health condition. If you have consented to provide us with this information, we will only use this to assess the availability of the cover you have requested and where necessary to provide You with the benefits under the Policy in the event of a claim. You are not under any obligation to consent for us to process your health information, however, we may be unable to provide the services you have asked for without this information.
You may request that we not use Special Categories at any time by emailing contact@battleface. If you do so, however, this may result in us applying a restriction on your policy or in some instances, withdrawing your cover altogether.
We do not knowingly collect any personal data about children. If you are a parent or guardian and you are aware that your child has provided us with any personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers.
Minimum Required Information
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide the minimum required data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the product or service you have purchased). In that event, we may have to cancel our agreement with you to provide a product or service you have requested and will notify you if this is the case at the time. For example, if you have asked us to arrange a certain type of cover for you, we may ask for further details in order to assess your application and complete our identity, money laundering and credit checks before we are able to do so.
WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?
We may collect information on you in the following ways:
Information that you voluntarily provide to us
When you request a product or service from us, consult with our customer service team, send us an email, request a brochure, fill in forms on our website, enter a competition, promotion or survey, or communicate with us in any way, you are voluntarily giving us information that we collect. We also collect information you give to us when we contact you during the course of entering into a contract with you or in the process or managing your customer account. That information may include your Identity Data, Contact Data, Transaction Data, Technical Data, Profile Data and Marketing and Communications Data.
Information that we collect automatically
Information from other sources
From time to time we may obtain information about you from third-party sources, such as public databases (for example, the Electoral Register) and other third-party data providers. We take steps to ensure that such third-parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioural data (such as information about your use of social media websites, page view information and search results and links) from analytics providers and search engine providers (for example, Google). We use this information, alone or in combination with other information (including personal data) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
WHY WE COLLECT YOUR PERSONAL DATA AND HOW WE USE IT
We have set out below a description of all the ways we intend to use any personal information. We may use and disclose your personal information for the following purposes:
Entering into an agreement with you and to provide our services
In providing you with our products or services, we will use your Identity Data, Contact Data, Transaction Data, Technical Data, Profile Data and Marketing and Communications Data. We will also use this information to process your insurance application, process any payments, to manage your customer account, to keep adequate records of your past purchases, and to contact you regarding our agreement with you, including providing customer support and detecting, preventing and addressing technical issues. We may also collect information to facilitate the delivery of assistance services, including medical information to manage emergency situations.
To manage our relationship with you
We may send you important updates about changes to the way in which our products or services work. We may also invite you to provide feedback on our products and services whether by email or by telephone. We may also, unless you have opted out, send you information electronically about our own products or services. We do this in order to keep you updated about products and services you have purchased, develop our range of products and services and to grow our business.
If we have obtained your express opt-in consent, we may send you, or permit selected third-parties to send you, other forms of marketing, for example regarding other products and services. We shall make sure it is clear when you are able to give us permission to do this, for example, we have an online form and boxes that you need to tick if you wish to receive any such marketing materials. You may discontinue direct marketing at any time by contacting us.
To administer and protect our business and this website
We may also use your information in order to protect our business and our website, and to help us monitor or improve the products or services that we offer. This includes troubleshooting, statistical and data analysis, testing, system maintenance, support, reporting and hosting of data. We also use your information to improve our website so that content is presented in the most effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure. We use this for the running of our business, provision of administration and IT services, network security and prevention of fraud. We may also need to use your information in the context of a business reorganisation or group restructuring exercise. Please note that we record telephone conversations for training and monitoring purposes and that we may also use this information in the event of any legal or regulatory matter, such as in the event of the exercise or defence of any legal claims.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another lawful reason. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
We may disclosure your personal information to other companies in the battleface group and other third-party service providers for the purposes outlined above or where disclosure is permitted by law. These entities may be located in Australia or overseas including but not limited the United Kingdom, the United States or countries where overseas medical or assistance services are provided.
We require all third-parties to respect the security of your personal information and to treat it in accordance with the law. We shall not share your personal information with any third-parties for marketing purposes without your express consent.
Where personal information is disclosed overseas, in addition to any local data privacy laws, we make all reasonable efforts to ensure that the arrangements we have in place impose appropriate privacy and confidentiality obligations on those parties to ensure that imparted personal information is kept secure and that such information is only used for the purposes noted above.
WHERE WILL WE HOLD AND STORE YOUR PERSONAL INFORMATION?
All personal data that you provide to us is stored on secure servers provided by Amazon Web Services Canada, Inc. We use appropriate measures to ensure that your personal information is treated securely and in accordance with this Policy and comply with the relevant data protection legislation.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third-parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please note that the transmission of information via the internet is not completely secure. Although we shall do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we shall use effective safeguarding procedures and security features to try to prevent any unauthorised access to your personal data.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
HOW DO YOU MAKE A COMPLAINT ABOUT HOW WE HANDLE YOUR PERSONAL INFORMATION?
If you have a complaint about our handling of your personal information or an alleged breach of the privacy principles contained in the Privacy Act, please contact our Compliance Officer on the details listed in the Policy under ‘Contact Us’. Your complaint will be reviewed and you will be provided with a written response.
If your complaint cannot be resolved by our internal dispute resolution process within 30 calendar days, you can lodge the complaint with the Office of the Australian Information Commissioner (‘OAIC’). You can contact the OAIC at: