Privacy Policy

Definitions in this Privacy Policy

‘Our’, ‘Us’ and ‘We’ refers to Club 4×4 Pty Ltd ABN 41 606 776 274, of PO Box 1118, Maroochydore, QLD 4558, Australia.
‘Personal Information’ is any 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 the information or opinion is recorded in a material form or not.

‘Related Companies’ has the same meaning as related bodies corporate and the meaning in section 50 of the Corporations Act 2001 (Cth).

‘Sensitive Information’ is a sub set of Personal Information defined as information or an opinion about an individual’s:

racial or ethnic origin; or
political opinions; or
membership of a political association; or
religious beliefs or affiliations; or
philosophical beliefs; or
membership of a professional or trade association; or
membership of a trade union; or
sexual orientation or practices; or
criminal record; or

‘You’ and ‘Your’ refers to Our customers and prospective customers. It also refers generally to users of Our websites.

Our Commitment

We recognise that Your privacy is very important to You. We are committed to ensuring the privacy of Your Personal Information.
The Privacy Act details Australian Privacy Principles that set minimum standards for how private sector organisations such as Us should collect, use, disclose, store, provide access to and correction of Personal Information.
This Privacy Policy outlines how We manage Your Personal Information.
Currency and Status of Our Privacy Policy
Our current Privacy Policy is detailed below. It is current as of and from 30 September 2022. We suggest that You read it thoroughly.
By visiting Our website, applying for, renewing or using any of Our products or services, making a claim or providing Us with Your Personal Information, You agreed to Your Personal Information being collected, held, used and disclosed as set out in this Privacy Policy.
This policy may change from time to time and all changes will be posted on Our websites so please check it periodically. Alternatively, contact our Privacy Officer at privacy@edagroup.com.au, by calling us on 03 7003 8458 or by writing to PO Box 1118, Maroochydore, QLD 4558 and request a copy of Our most recent policy.
Whenever using Our websites You should read this policy in conjunction with Our collection notification and the relevant website’s terms of use.

Types of Personal Information We Collect

The Personal Information We collect depends on the products and services We offer You or You use or apply for (and may also require Us to collect Personal Information about other people such as a co-insured, or Your spouse, partner or children). Typically the details We collect and hold include Your name, contact details (address, phone and fax number, email address), date of birth, gender and payment details. We may also collect information that is specific to a particular product.
Why We collect Your Personal Information
We collect Personal Information to provide, offer and administer Our various products and services, or otherwise as permitted by law. Such purposes include responding to Your enquiries, providing You with assistance You request of Us, maintaining and administering Our products and services (for example processing requests for quotes, applications for insurance, underwriting and pricing policies, issuing You with a policy, managing claims, processing payments); processing Your survey or questionnaire responses; market research and the collection of general statistical information using common internet technologies such as cookies; providing You with marketing information regarding other products and services (of Ours or a third party); quality assurance and training purposes; performing administrative operations (including accounting and risk management) and any other purpose identified at the time of collecting Your information.

We will only collect ‘Sensitive Information’ where it is relevant to underwriting an insurance policy or dealing with, managing, or processing a claim. We may use or disclose it by giving it to Related Companies and Our appointed third parties for research and analysis and to design, test or underwrite new insurance products or features. Your Sensitive Information will not be used or disclosed for any other purpose unless We have Your permission.

We may combine or link Personal Information We already hold about You to other Personal Information We collect about You. Third party marketing service providers may combine the Personal Information We disclose to them with information they already hold about You, in order to provide You with more relevant advertising about Our or their products and services.

Third parties are prohibited from using Your Personal Information for purposes other than those for which it is supplied.
If You do not consent to Us collecting, using or disclosing all or some of the Personal Information We request, We may not be able to provide You with Our products or services such as processing Your application for insurance, Your claim or any payment due to You. It may also prevent Us from maintaining or administering Your policy or the provision of information regarding Our products or services or those of any third party.

How We collect Your Personal Information

We collect Your Personal Information from You in various ways and at several different points, including via telephone (including any form of mobile phone text messaging), Our website, hard copy forms or email.
Unless it is unreasonable or impracticable for Us to do so, We collect Your Personal Information directly from You. There may, however, be occasions where We collect Your Personal Information from someone else.

Collecting, Sharing and Disclosing Your Personal Information

We may collect Personal Information from and/or share Your Personal Information with Our Related Companies and other third parties who provide services to Us or on Our behalf.

We may collect and/or share Your Personal Information with other third parties or any unrelated party under the following circumstances:

in accordance with this Privacy Policy;
as provided in any collection notice We give You;
where You have provided Your consent (which may be given expressly or may reasonably be implied by Your conduct or Our existing business relationship);
for purposes related to: research (including market research), planning, service development, security, testing and risk management;
where a product or service You apply for is provided or supplied by or through a third party;
where a third party, such as a mailing house, carries out activities on Our behalf;
if disclosure is otherwise required in order to provide You with a particular product or service;
where information is received from another insurer (for reasons including to assess insurance risks or to assist with an investigation);
in order to ensure Our ability to continue providing products and services;
if disclosure is required for the purposes of conducting business analysis in order to improve Our products and services;
if disclosure is required by law or requested by statutory, regulatory or ombudsman authorities or law enforcement agency;
to an insurance broker or agent acting on Your behalf or who You have designated to act on Your behalf;
where a third party has an interest in the product or service We supply, for example a mortgagee, referral agent, third party beneficiary, distributor, insurance intermediary, business partner, affiliate or any other insurer;
Our professional advisors including Our accountants, auditors and lawyers, contracted advisors and service providers;
where a third party acquires, or considers acquiring, an interest in Us;
where We are authorised, required or permitted by law to use or disclose information; and
where it is necessary for a third party to assist Us in providing Our services, for example, reinsurers, insurance intermediaries, insurance reference bureaus, lawyers, accountants, loss adjusters and others involved in the providing of services or claims handling processes.

Your Personal Information may also be disclosed to some of Our service providers who are located overseas. Who they are may change from time to time and We may need to disclose Personal Information to other countries. We aim to protect Your Personal Information by taking reasonable steps to ensure that the overseas service provider has similar protections in relation to privacy or that We enter into contractual arrangements with the recipient that safeguards and ensures compliance with Australian privacy law and this Privacy Policy. However, in some cases We may not be able to take reasonable steps to ensure they do not breach the Privacy Act and they may not be subject to the same level of protection or obligations that are offered by the Privacy Act. By proceeding to acquire Our services and products You agree that You cannot seek redress under the Act or against Us (to the extent permitted by law) and may not be able to seek redress overseas.

Related and unrelated third parties to whom Your Personal Information is disclosed are required to keep the information confidential and only use it for the same purposes as We are permitted to use it.
Quality and Security of Your Personal Information
We aim to ensure that Your Personal Information is accurate, complete and up to date.
During the course of Your relationship with Us We will ask You to inform Us of any changes to Your Personal Information. You should however contact Us at any time to update Your Personal Information or advise Us that the information We have is not accurate or complete.

We are committed to keeping Your Personal Information secure and will use all reasonable precautions to protect it from loss, misuse, interference and unauthorised access, modification or disclosure including:

physically securing external and internal premises;
maintaining computer and network security (such as user identifiers and passwords) to control access to computer systems;
restricting access to Your Personal Information to employees or those who perform services on Our behalf who are authorised to handle Your Personal Information and on a ‘need to know’ basis;
entering into confidentiality agreements with relevant employees and third parties;
appropriate training of staff;
retaining Your Personal Information for no longer than it is reasonably required to service a policy or continue to provide any products and services to You, unless We are required by law or any contractual obligation to retain it for longer; and
taking reasonable steps to destroy or de-identify Personal Information that We no longer require or which was unsolicited and We identify that We would not have otherwise collected it from You.
Access to and correction of Your Personal Information
You may generally access the information We hold about You and request corrections. This right is, subject to the exceptions detailed in the Australian Privacy Principles.
For example, We may refuse access where the:
information may have an unreasonable impact on the privacy of others;
request is frivolous or vexatious;
information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings; or
the information would reveal Our intentions in relation to negotiations in such a way as to prejudice those negotiations.

If We refuse You access, or to give access in the manner requested by You, We will let You know why in writing.
Where providing access would reveal evaluative information in connection with a commercially sensitive decision-making process, We will provide an explanation for the decision rather than direct access to the information.

In most cases, You may access Your Personal Information at no cost to You by contacting Our Privacy Officer at privacy@edagroup.com.au, by calling us on 03 7003 8458 or by writing to PO Box 1118, Maroochydore, QLD 4558. For access to complex or Sensitive Information or more detailed requests for access to Your Personal Information, for example, access to information that is archived, We may require You to place Your request in writing and charge You a fee for Our reasonable costs of retrieving and supplying the information to You.
In all cases You will be asked to verify who You are before Your Personal Information is provided. All requests for Personal Information will be handled in a reasonable period of time.

How to contact Us about Privacy

If You have any questions, suggestions or complaints about Our privacy practices (including a complaint about a breach of the Privacy Act or Australian Privacy Principles) or this Privacy Policy, You can either email Our privacy officer at privacy@club4x4.com.au or by writing to PO Box 1118, Maroochydore, QLD 4558. We will respond to Your question, suggestion or complaint as soon as possible.
If You are not satisfied with Our response to Your enquiry or complaint You can contact the privacy officer and request that it be reviewed by a senior staff member who will endeavour to resolve Your dispute within 30 days. If You are still not satisfied We will tell You about any external dispute resolution avenues which may be available to You.