Privacy Policy

Our website address is: https://rewards.vbp.au.

What personal data we collect and why we collect it

This policy outlines how Vital Business Partners (VBP), ACN 165 837 623 (“we”, “us”, “our”) collects, uses, discloses, retains, and manages your personal information, and how we comply with our obligations under the Privacy Act 1988.

Unless you advise us otherwise, you acknowledge and consent to us using your personal information as set out in this Privacy Policy or as otherwise permitted under the Privacy Act or other applicable law.

1 What personal information do we collect?

(a) When we are contacted or provide our services, the personal information we collect may include a person’s name, contact numbers, email address, residential or business address, financial details, insurance details, credit card details, and other personal data. This may include sensitive information (as that term is used in the Privacy Act).

(b) When our server is accessed, it automatically records information that the browser sends when it connects to our website. This information may include:

(i) the accessing party’s Internet Protocol (IP) address, domain name, browser type, and language;

(ii) information about usage and online activities (for example, by way of cookies), including when our website is accessed, other sites accessed from our website, content uploads and downloads, and usage of the services available on our website; and

(iii) information provided through the use of any downloading facilities on our website.

(c) Our website uses cookies. Cookies do not identify you personally, but they may link back to a database record about you. With most Internet browsers, you can erase or block cookies or receive a warning before a cookie is stored. Refer to your Internet browser instructions for guidance on this.

2 How do we collect personal information?

(a) We collect personal information:

(i) from the individual;

(ii) from you, our clients, when we provide services to them. This includes personal information about your customers and clients (“Your Clients”);

(iii) via a file-sharing arrangement with a client, or when a client provides access to their customer relationship management (CRM) or other software systems and third-party websites to enable us to provide the services;

(iv) when sent to us by email or other communications from third parties;

(v) from publicly available sources of information;

(vi) when we are required to do so by law; and

(vii) from our own records.

(b) We are committed to ensuring that the information we hold is accurate and up to date. We update personal information when we are advised of changes, and at other times as necessary.

3 Provision of personal information to us by you and Your Clients

If you provide us with the personal information of another person (including Your Clients):

(a) you must disclose to that person that you are providing their personal information (including any sensitive information) to us, and that the information may be disclosed offshore in accordance with clause 7; and

(b) you represent — and we accept — that you are authorised to act on behalf of that client, and that the relevant person has consented to the disclosure of their information to us.

4 How we use your personal information

(a) Generally, we collect, use, and hold personal information to:

(i) provide our services, including services involving Your Clients;

(ii) facilitate our internal business operations, including fulfilling any legal requirements

(iii) advise you of additional services or information that may be of interest;

(iv) provide your contact details to our partners who have agreed to offer you relevant services;

(v) analyse our services and customer needs with a view to developing and improving existing and new products and services;

(vi) maintain and update our business infrastructure and systems;

(vii) compile statistical data; and

(viii) promote and advertise our business, products, and services.

(b) If we do not collect personal information, we may be unable to provide our services or any assistance requested.

(c) If the personal information provided to us is incomplete or inaccurate, we may be unable to provide our services, or the quality of those services may be adversely affected.

5 Disclosing your information

We may disclose personal information we hold about you to third parties in certain circumstances, including:

(a) if you or Your Client agree to the disclosure;

(b) to employees, contractors, and service providers who assist us in operating our business and delivering our services, as well as those service providers you require us to work with;

(c) where you or Your Client would reasonably be expected to consent to the disclosure of information of that kind to a third party;

(d) for the purposes for which the information was collected (for example, to provide our services or respond to an enquiry);

(e) where disclosure is required or permitted by law;

(f) to our related entities;

(g) if disclosure is necessary to prevent or lessen a serious and imminent threat to someone’s life or health; or

(h) where disclosure is reasonably necessary for the enforcement of criminal law, a law imposing a pecuniary penalty, or for the protection of public revenue.

6 Disclosing your information

(a) We provide services to you and Your Clients under our Client Services Agreement. These services are performed by our related company incorporated in the Philippines, VBP Back Office Solutions Inc.

(b) The services include:

(i) general administrative support;

(ii) updating client databases and records;

(iii) researching clients’ existing financial products;

(iv) data entry and preparation of file notes;

(v) preparation of insurance quotes;

(vi) preparation, application, and lodgement of insurance, superannuation, investment, and other product applications;

(vii) coordinating and obtaining, where applicable, medical reports, medical tests, and financial reports to provide to underwriters for new insurance applications; and

(viii) preparation of client review documents and fee disclosure statements.

(c) To provide our services, we — including VBP Back Office Solutions Inc. — receive personal information from you about Your Clients. This may include sensitive information.

(d) We have security measures in place to protect that personal information, including supervision, specialist security software, disabled flash drive functionality, employee training, password protection, and investigation software.

(e) VBP will take all necessary steps to ensure that VBP Back Office Solutions Inc., as a recipient of personal information, complies with its obligations under the Privacy Act 1988 and the Australian Privacy Principles — in particular, Australian Privacy Principle 8 (Cross-border disclosure of personal information).

7 Considerations when you send information to us

(a) While we take all reasonable steps to protect your privacy and the privacy of Your Clients — including investing in specialist security software — no data transfer over the internet is ever 100% secure.

(b) If you or Your Clients provide personal information to us electronically, there are steps you and Your Clients can take to help maintain the security of that information, including

(i) always closing your browser when you have finished your user session;

(ii) avoiding the use of public computers to provide personal information;

(iii) never disclosing your username or password to another person; and

(iv) not sending information to a VBP employee’s personal or web-based email account, or by any means other than through approved file-sharing applications (e.g. Dropbox) specifically provided and authorised by VBP.

(c) You are responsible for all actions taken using your username, email, or password. If you believe your credentials have been compromised, you should change your password immediately and contact us without delay.

(d) If we suspect a data breach resulting in the compromise of personal information stored or held by us, we will activate our Data Breach Response Plan, which includes:

(i) notifying you and any affected Clients;

(ii) notifying relevant regulatory authorities, if required — which may include the Office of the Australian Information Commissioner (OAIC) and the Australian Federal Police; and

(iii) undertaking appropriate remedial action, depending on the type, amount, and nature of the personal information involved.

In implementing and managing our Data Breach Response Plan, we refer to the OAIC’s publication “Data Breach Notification: A Guide to Handling Personal Information Security Breaches.” Our Privacy Officer is primarily responsible for developing and executing this plan and may engage VBP staff, agents, or external experts as required, depending on the nature, extent, and impact of the suspected breach.

8 How your information is stored

(a) We take reasonable steps to securely store personal information, including both electronic and physical security measures.

(b) When personal information we collect is no longer required, we destroy or delete it in a secure manner.

9 How you can update, correct, or delete your personal information

(a) You and Your Clients have the right to request access to the personal information we hold about you and Your Clients, and to ask us to correct it if you believe it is inaccurate or out of date.

(b) You and Your Clients may also request information about the source of any personal information we have collected from a third party. We will provide this information at no cost unless, under the Privacy Act or other applicable law, there is a valid reason for withholding it.

(c) To request access to or correction of personal information, you or Your Clients may contact our Privacy Officer at contactus@vbp.au.

(d) If there is a reason under the Privacy Act or other law for us not to provide access to information, we will issue a written notice of refusal outlining:

(i) the reasons for the refusal, except to the extent it would be unreasonable to do so; and

(ii) the mechanisms available to you to lodge a complaint about the refusal.

(e) You or Your Clients should contact us immediately if:

(i) someone has gained unauthorised access to your or Your Clients’ personal information;

(ii) you believe we have breached our privacy obligations or your or Your Clients’ privacy rights in any way; or

(iii) you or Your Clients would like to discuss any aspect of this Privacy Policy.

10 Your authority and opting out

(a) By using our services and providing us with personal information, you consent to us collecting, maintaining, using, and disclosing your personal information in the manner described in this Privacy Policy.

(b) We do not use the personal information of Your Clients for marketing purposes.

(c) If at any time you no longer wish to receive marketing materials from us, or do not want your information disclosed for direct marketing purposes, please email contactus@vbp.au, and we will remove your details from our marketing database.

(d) If you close your account or opt out, we will remove or de-identify your personal information as soon as reasonably practicable. However, we may retain certain personal information as necessary to comply with applicable laws, prevent fraud, meet insurance and governance requirements, maintain IT backups, recover outstanding payments, or resolve disputes.

11 Limitation of liability

(a) To the extent permitted by law and subject to our obligations under the Privacy Act 1988 (Cth), we will not be liable to you or any third party for any loss, damage, or claim (including, but not limited to, consequential loss or loss of profits) arising from our collection, use, management, or disclosure of personal information in accordance with this Privacy Policy.

(b) Where liability cannot be excluded by law, and to the extent permitted under applicable law — including the Australian Consumer Law — our liability to you will be limited to the re-performance of any services we have provided to you.

(c) Links on our website or websites we set up for you may take you outside our network. These links are provided in good faith. However, we are not responsible for third-party sites and accept no responsibility for the content, accuracy, security or function of third-party sites.

12 Changes to our Privacy Policy and Complaints Handling Procedure

(a) This document sets out our current Privacy Policy.

(b) Our Privacy Policy may be updated from time to time. You should review this Policy each time you visit our website or provide us with personal information to ensure you are aware of any changes.

(c) If you would like further information about our Privacy Policy, or if you have any concerns or complaints regarding the protection or handling of personal information you have provided to us or that we have collected from others, please contact our Privacy Officer:

Email: contactus@vbp.au
Mail: Level 10, 88 Phillip Street, Sydney NSW 2000, Australia

(d) We endeavour to handle all privacy-related complaints promptly, seriously, and confidentially. To help us investigate your complaint quickly and efficiently, we ask that you or Your Clients:

(i) put your complaint in writing; and

(ii) provide your name and contact details, the nature of the complaint, any relevant supporting information or documents, and the outcome(s) you seek.

(e) Our Privacy Officer will:

(i) acknowledge receipt of your complaint;

(ii) investigate the complaint, considering the information provided and any additional information that may assist in resolving the matter;

(iii) notify you of our findings and any actions we have taken or propose to take

(iv), if possible, discuss options to resolve the issue; and

(v) provide information on how to make a complaint to the Office of the Australian Information Commissioner (OAIC) if you are dissatisfied with the outcome.

(f) More information about your privacy rights and our obligations, including how to make a complaint, is available from the OAIC:

Website: www.oaic.gov.au
Mail: GPO Box 5218, Sydney NSW 2001
Email: enquiries@oaic.gov.au

 

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Additional information

• How we protect your data
• What data breach procedures we have in place
• What third parties we receive data from
• What automated decision making and/or profiling we do with user data
• Industry regulatory disclosure requirements