At Primus Law Pty Ltd (ACN 168 915 393) (Primus, we, us), we respect privacy and your rights to control your personal data. Our principle guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to third parties unless we are given express permission by yourself to do so. This Privacy Policy deals with personal information of users of our website, our customers, our service providers and other third parties. It covers the personal information that we collect and how we protect that information in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. This policy is also subject to any applicable state or territory health information laws.
What is collected
We collect personal information necessary to provide our services when you request or apply to us for services or deal with us over the telephone, via SMS, online forms (including via our website) or email.
This information can include:
- personal information such as your name, address, email address, telephone number and date of birth;
- government identifiers and related information, such as your driver's licence and passport, depending on the circumstances of your claim/case or hire;
- details about other parties involved in your accident or claim, including facts or opinions in supporting or rebutting material, e.g. statutory declarations;
- details about your family, business, financial details, insurance company (and claim number and policy number), car registration, occupation and income, and transactions with us or third parties; and
- information you otherwise submit about yourself, or someone else, to us, or our website, including enquiries, complaints and other feedback.
We may also monitor and record telephone calls for training and security purposes.
In some circumstances, Primus may collect sensitive information about you, for example in relation to insurance claims, such as information about injuries you may have suffered in your accident, and other health information. We will only collect sensitive information about you where we are permitted to do so by law.
How do we collect information
We collect the majority of the personal information directly from you — including when you interact with us in person, over the phone or electronically, when you access our website, or via email and when we provide our services to you.
We may receive and gather personal information from third parties, including repairers, insurers or any other referring partners. If we do, we will protect it as set out in this Privacy Policy. We will only collect your personal information from third parties if you give the third party your consent to provide the information to us or it would be reasonably expected. We will only collect sensitive information with your consent.
If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.
How information is used
We use the personal information provided for purposes consistent with the reason you provided it, or for a directly related purpose, where required or permitted by law or where you have provided us with your express or implied consent. These purposes include, but are not limited to:
- provision of commercial and consumer vehicle leasing arrangements, including accident repair and replacement vehicle services;
- processing a product application or service or purchase request;
- managing our products and services or other relationships and arrangements;
- processing receipts, invoices and payments and servicing customer accounts, including determining liability for payment;
- responding to customer enquiries about applications, accounts, products or services;
- understanding customer needs and offering products and services to meet those needs;
- assessing, processing and investigating insurance risks or claims and (with your consent) referring your potential personal injury claims to third party solicitors;
- accounting, billing and other internal administrative purposes;
- from time to time we may use your personal information (but not sensitive information) to provide you with information on our services by direct mail, email/SMS or telephone — you may request that your information is not used for these purposes;
- considering, and contacting you about, any application you make for a job with us;
- enforcing our rights, including undertaking debt collection activities and legal proceedings; and
- any other legal and regulatory requirements.
Disclosure of your personal information
We may disclose your personal information to any of our employees, officers, insurers, professional advisors, agents, suppliers, partners or subcontractors insofar as reasonably necessary for the purposes set out in this policy. This may include, but is not limited to:
- our related entities in Australia and United Kingdom;
- administrative services providers, such as marketing and IT systems providers, mailing houses, printers and call centre operators;
- legal, settlement, valuation and recruitment service providers;
- regulatory bodies, law enforcement authorities and toll operators in Australia;
- any person who is considering whether to acquire or who has acquired any part of our business, or the rights or obligations under our contract with you;
- insurers, reinsurers, loss adjusters, assessors and underwriters;
- brokers and other distributors; and
- debt collectors and investigators.
We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena or warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
Information that we collect may from time to time be processed in or transferred between our offices overseas. As at the date of this policy we may use technical support in the Philippines or the UK, but such technical support does not require the transfer or storage of personal information.
By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this policy.
Security of your personal information
Primus is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure, such as password protection and multi-factor authentication.
Information is retained for the period required for business purposes or by law. Files in electronic or hard format are usually stored for 7 years to meet legal requirements. We will destroy or de-identify personal information where it is no longer required, unless we are required by law to retain it.
We will seek to secure any breach, notify you if your information is compromised, take steps to prevent any further breaches and report serious breaches to the appropriate authorities.
Access and correction of your information
You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act. If you would like a copy of the information which we hold about you, or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].
To obtain access to your personal information we suggest that you provide proof of identity and be reasonably specific about the information you require. We may charge a reasonable administration fee reflecting the cost of providing access. We will not charge you for making the request.
We will respond to your request within a reasonable period of time. We reserve the right to refuse access in certain circumstances set out in the Privacy Act, and will explain any refusal in writing.
Changes to our Privacy Policy
We may modify this policy at any time in our sole discretion. All modifications will be effective immediately upon posting on our website. Please check back from time to time to review our Privacy Policy.
Website
When you visit our website we may collect certain information such as browser type, operating system and how you came to our website. This information is used in an aggregated manner to analyse how people use our website so that we can improve our service.
We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you return and to store details about your use of the website. We may use traffic log cookies to identify which pages are being used. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings — this may prevent you from taking full advantage of the website.
Our website may from time to time have links to other websites not owned or controlled by us. Please be aware that Primus is not responsible for the privacy practices of such websites. We encourage our users to read the privacy statements of each and every website that collects personal identifiable information.
Are you an EU citizen?
Even though Primus is not within the jurisdiction of the EU privacy regulations (GDPR), we do value your privacy and are happy to comply with any requests regarding your rights as stated in the GDPR. These requests can be submitted to [email protected].
We only offer our products and services to people in Australia. Primus may engage employees that reside in the UK — these employees log in to our servers based in Australia. No data transfer takes place and no services are offered to UK individuals.
Complaints about privacy
We take complaints very seriously. Every complaint is investigated, replied to within a reasonable period of time and in a confidential manner. Following a complaint, our Privacy Officer will commence an investigation. We may seek further information from you in order to provide a comprehensive and complete response. You will be informed of the outcome following completion of the investigation.
If you have any complaints about our privacy practices or believe we have breached privacy law, please contact the Privacy Officer at [email protected] or by post at the address below.
You may also make a complaint to the Office of the Australian Information Commissioner (OAIC) via telephone on 1300 363 992, by submitting a complaint online at www.oaic.gov.au, or by writing to the OAIC at GPO Box 5218, Sydney NSW 2001.