Your privacy is important to nlc. nlc respects the right of individuals to have the privacy of their personal information maintained. We recognise the importance of personal information privacy and the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)and the (Credit Reporting) Code 2014 with respect to the collection, storage and handling of personal information. We also have obligations in relation to your personal information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Electronic Transactions Act 1999 (Cth) and the Electronic Transaction Amendment Act 2011 (Cth) and the National Consumer Credit Protection Act 2009 (Cth). We are also authorised to collect personal information under the Personal Property Securities Act 2009 (Cth).
It is important for you to understand that we need different types of personal information at different stages of your relationship with us and therefore the policy is divided into four areas:
The first area provides an overview of our information collection and usage practices. The second area addresses information we may collect when you use our website and how we may use this information. The third area addresses information that we may collect if you request a salary packaging report, a quotation or if you complete an application for finance and/or insurance or request motor vehicle advisory and referral services. The final area provides you with detail on how we store your information and how you are able to access it and request changes to it.
1. Overview of Information Collection & Usage Practices
nlc collects personal information that you provide directly to nlc as well as information from publicly available sources and third parties.
nlc only collects personal information that is necessary to carry out our primary business activities, including providing you with information and general marketing activity about our financial products and services, insurance products and services and motor vehicle advisory and referral services.
nlc will not use an identifier assigned by a Federal government agency to identify an individual.
Where nlc provides you with marketing material, nlc will also provide you with the option to opt out of receiving future marketing material.
Where applicable, we may be authorised to collect your tax file number for the purposes of managing your superannuation contributions under a salary packaging which has been agreed between you and your employer. Access to tax file number information for such purposes is required under taxation and superannuation laws such as the Income Tax Assessment Act 1936 and the Superannuation Industry (Supervision) Act 1993. In order to send contributions using SuperStream*, we are also required to collect the unique superannuation identifier (for APRA-regulated funds), electronic service addresses (ESA) for Self-Managed Super Funds and bank account details of your nominated super fund.
*All superannuation contributions made under a salary sacrifice arrangement must be sent using the SuperStream data and payment standard. For more information on SuperStream, please refer to www.ato.gov.au/superstream.
We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to, race, political or religious beliefs, sexual preferences, criminal convictions and, health information.
We may also collect information about your health (particularly if you purchase involuntary unemployment insuranceor make a disclosure or claim relating tothisinsurance) or criminal convictions which are defined as sensitive information in the Privacy Act, with your consent. We may collect, hold, use and disclose personal information about you under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Electronic Transactions Act 1999 (Cth) and Electronic Transactions Amendment Act 2011 (Cth) and the National Consumer Credit Protection Act 2009 and we are authorised to collect personal information under the Personal Property Securities Act 2009 (Cth)
We can only fully advise you if we have all relevant information. Where applying to us for an insurance product, the insurance laws also require you to provide your insurers with all information they need in order to be able to decide whether to insure you and on what terms.
If you do not supply us with your personal information we may be unable to process your application for finance and/or insurance.
2. Website Information Collection & Usage Practices
You can access our home page and browse our website without disclosing your personal information. When you access the site or services, we may collect the following information:
Personal Information - We collect Personal Information when you knowingly provide it, including when you provide feedback or request information
Non-Personally Identifiable Information - nlc automatically receives and records certain "traffic data" on its server logs including your IP address, browser type, browser language, the page you requested, the date and time of this request, your communications and interactions with other site registrants and the page you visited immediately prior to visiting this site. You understand that nlc uses this data to help diagnose problems, analyse trends and develop marketing material communications. nlc may from time to time use information and data collected to send site or operational announcements to Customers by email or other electronic forms.
Cookies - We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them).
The following types of cookies could be placed on your computer:
Social Media Cookies: These cookies are used to integrate our site with popular social media sites (Facebook, Twitter, YouTube, Google+, Add This, etc.). Social Media cookies allows visitors to share content quickly and easily with their social networks. Log data may include information such as IP address, browser type, the referring web page, pages visited, cookies, and other interactions with the social sharing buttons or widgets.
Google Analytics Cookies: These cookies (__unam, __utma, __utmb, __utmc, __utmz) are used to measure website traffic and activity, and improve the user experience by providing us with anonymous, unique and repeat visitor performance data in aggregate format.
Marketing Automation Cookies: We use a 3rd party marketing automation provider, Marketo.com. Marketo tracking cookies (_mkto_trk) allow us to collect information about how you use our site after you have received an email from us. The cookies track data linked to your email address and include data such as how you arrived at the site, how often you've visited, and which pages you looked at. To opt out of this, you can disable cookies or unsubscribe from our emails using the link on the bottom of any marketing email. You understand you can prevent this collection of information by setting your browser to not accept cookies. This will not prevent you from accessing the site; however, it may prevent you from utilising all features of the site.
We may use your personal information for marketing and promotional purposes and may send you information about other services and products that may be of interest to you. Our communication to you may be sent in various forms such as mail, SMS, fax and email. You consent to us sending you marketing communications. If you indicate a preference for a method of communication, we will endeavour to use that method wherever practical to do so. If you do not wish to receive information about our products and services or those of other members of the Group, you may notify us using the contact details provided below or by using any opt-out facilities provided in the marketing communications.
Internet Service Provider
The nlc web site and electronic mail is not managed by a third party Internet Service Provider (ISP).
3. Further Information on Collection & Usage Practices
If you request a salary packaging report, a quotation or if you complete an application for finance and/or insurance or request motor vehicle advisory and referral services you will be required to supply us with personal information as part of the request or application.
Use of Personal Information
nlc may collect, use and disclose your personal information to:
* All superannuation contributions made under a salary sacrifice arrangement must be sent using the SuperStream data and payment standard. For more information on SuperStream, please refer to www.ato.gov.au/superstream.
We will endeavour to only collect your personal information directly from you. However, there are circumstances where we will be required to collect your information from, and disclose information to, third parties. We may collect and disclose personal information about you from/to other parties including:
The types of organisations we may disclose your information to are:
Cross Border Transfers
We disclose personal information outside Australia and we take reasonable steps to ensure that any overseas recipient handles your personal information in accordance with the Privacy Act. We may disclose your personal information to entities located in the following countries:
We comply with all Privacy Law that applies to the collection, use and disclosure of credit information, including the Privacy (Credit Reporting) Code 2014 and a copy of the NLCCreditReporting Policyis available on the nlc web site at: www.nlc.com.au or a copy may be obtained upon request.
4. Information Storage & Access Practices
Securing Your Data
We take reasonable steps to protect all information which we hold (including your personal information) from misuse, loss, unauthorised access modification or disclosure. However, security of communications over the Internet cannot be guaranteed, and therefore nlc cannot provide absolute assurance that information will be secure at all times.
nlc have implemented security measures to protect the personal information we hold from unauthorised access.
Privacy Statement and Requests for Access
If we collect your personal information, you have the right to request access to your personal information. However, we will need to establish and verify your identity before we can disclose information to you. The process of verification will vary depending on our assessment of the appropriate level of security required for the information which is being disclosed.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request an amendment of it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it and provide upon request, nlc's reasons for denial of access or a refusal to correct personal information.
If you have any questions in relation to our information handling procedures, or you would like to request a copy of our Privacy Statement, or you wish to lodge a request for access or amendment to the personal information we hold, please contact the Privacy Officer at the address set out below;
How can I contact nlc?
Please address all correspondence to:
The Privacy Officer
NLC Pty Ltd
Level 3, 102 Albert Road
South Melbourne, Victoria 3205
T 03 8699 7000
F 03 8699 7199
Privacy Complaint Form
If you believe we have not complied with our obligations concerning your personal information we invite you to contact us and lodge a complaint. Complaints can be lodged on the Feedback Form. This form also provides a link to our Complaints Policy which details the process nlc will use to manage your complaint.
This form is to assist you in making a complaint if nlc holds your personal information and you feel your privacy has been infringed by nlc; and
If your complaint is not resolved to your satisfaction you can contact the Office of the Privacy Commissioner on 1300 363 992.