Privacy Policy

This Policy was last updated on 12 March 2014.

This Policy sets out Crowies Paints Pty Ltd ABN 67 066 584 950 (“Crowies Paints”, “we” or “us”) policies relating to management of your personal information and credit related personal information. These policies are based on our obligations under the Privacy Act 1988 (Cth) (“Act”) (including Australian Privacy Principles (“APPs”), Part IIIA (“credit reporting provisions”) and the Credit Reporting Privacy Code (“CR Code”).

The definition of Crowies Paints under this Policy includes:

1. Evanstone Hardware Pty. Ltd. ACN 008 172 272
2. Crowies Paints Franchisor Pty Ltd ACN 165 833 545
3. Crowies Paints Campbelltown as the trustee for Staten James Family Trust ABN 56 904 106 384
4. Crowies Paints Pty Ltd ACN 066 584 950 as the trustee for Crowies Paints Trust ABN 75 635 401 389.

By voluntarily supplying us with your personal or credit related personal information, you are agreeing to be bound by this Policy.

This Policy is periodically reviewed. Any amendments to this Policy will be notified to you by posting an updated version on our website, www.crowiespaints.com.au.

Please note that Crowies Paints’ website contains links to other websites. When a user has clicked on a link to another site, they leave the Crowies Paints site and are no longer protected by this Policy.

PART A - MANAGEMENT OF PERSONAL INFORMATION

Collection of personal information

Crowies Paints collects and/or holds the following kinds of personal information:

1. contact information such as name, postal address, private address, email address, telephone numbers and date of birth;
2. financial details;
3. ABN;
4. name of current employer (as applicable); and
5. any other information voluntarily provided by you through our website.

Crowies Paints’ website collects the following information from users:

1. your server address;
2. your top level domain name (for example, .com, .gov, .au etc)
3. the date and time of your visit to the site
4. the pages you accessed
5. the previous site you have visited
6. the type of browser you are using

Purposes for collection

Personal information is collected, held, used and disclosed by Crowies Paints for the following purposes:

1. provide further information about Crowies Paints, the project(s) we are undertaking with you and any other information you may require from time to time;
2. market or promote our services directly to individuals (unless as requested otherwise);
3. arrange and provide credit;
4. assess an applicant’s eligibility for credit (including obtaining credit references);
5. verifying an individual’s identity;
6. resolve a complaint;
7. develop and identify products and services that may interest customers;
8. provide our products and services to you;
9. process payments; and
10. other purpose related to any of the above.

Means of collection and holding of personal information

Crowies Paints collects only the information voluntarily supplied by you through our credit application forms, our website forms and verbally in store. If the personal information is not collected, Crowies Paints may not be able to provide you with the products or services requested.

Crowies Paints holds all personal information in electronic and physical form. We store information in access controlled premises and in offsite electronic databases requiring logins and passwords.

Crowies Paints is committed to keeping secure the personal information you provide us and we will take all reasonable precaution to protect your personally identifiable information from loss, misuse, interference, unauthorised access or alteration.

We aim to achieve this through:

1. imposing confidentiality requirements on our employees;
2. implementing policies in relation to document storage security;
3. implementing security measures to govern access to our systems;
4. only providing access to personal information once proper identification has been given;
5. controlling access to our premises; and
6. implementing website protection measures.

Disclosure and use of personal information

Crowies Paints has a duty to keep our customers’ personal information confidential. Our duty of confidentiality applies except where we have consent to disclose personal information, the disclosure is permitted under the APPs or is compelled by law.

Crowies Paints will only use your personal information for the purposes for which it was collected (“primary purposes”) or a purpose related to the primary purpose, if this use would be reasonably expected by you, or otherwise, with your consent.

Crowies Paints may disclose your personal information to necessary third parties, who assist us to provide, manage and administer our services and products. In which case, your personal information will be dealt with in accordance with that entity’s privacy policy. No personal details are provided to any other individual or organisation, except with your consent. We do not disclose your personal information to overseas recipients.

Access to information and seeking correction

You can contact us at any time to request access to your personal information or for your personal information to be corrected or updated. Please direct your request to the Privacy Officer via the details provided in this Policy.

Crowies Paints will, on request, provide you with access to your personal information or update or correct your personal information, unless the APPs provide an exception to us granting your request. Your request for access to your personal information or to update or correct your personal information will be dealt with by the Privacy Officer as soon as reasonably practicable. If we deny your request, we will provide you with a written notice detailing reasons for the refusal and the process for making a complaint about the refusal to grant your request.

Crowies Paints will take appropriate steps to verify your identity (or verify that you act as a legal guardian or authorised agent of the individual concerned) before granting a request to access your personal information. Where your request for access is accepted, we will provide you with access to your personal information in a manner, as requested by you, providing it is reasonable and practicable to do so.

Upon accepting a request for correction of your personal information, we will take all steps that are reasonable in the circumstances, having regard to the purpose for which your personal information is held, to correct your personal information.

Dealing with us anonymously

The circumstances in which you can deal with Crowies Paints anonymously or using a pseudonym include:

• making a general enquiry about the services that we can offer to you, including in person at one of our stores; and
• posting on our blog.

You may request at the start of any telephone call with us, in relation to a general enquiry, to remain anonymous (or you may use a pseudonym). You will also be given the opportunity to remain anonymous (or use a pseudonym) when completing a website enquiry form.

PART B - MANAGEMENT OF CREDIT RELATED PERSONAL INFORMATION

Collection of Credit Related Personal Information

Crowies Paints may collect, use, hold and disclose the following types of credit related personal information:

• identification information- name, current or previous address type and amount of credit sought;
• publicly available information about an individual’s creditworthiness;
• default information;
• repayment history information;
• payment information in relation to an overdue payment;
• court proceedings information;
• personal insolvency information;
• trade references (with your consent)

Credit related personal information is managed by Crowies Paints in accordance with the procedures set out in Part A of this Policy, unless provided otherwise in this Part B.

Means of collection of credit related personal information

In addition to the methods above, Crowies Paints may collect credit related personal information from other credit providers, subject to any restrictions in the Act.

Request for Access or Correction

A request for access to your credit eligibility information or for the correction of your credit information or credit eligibility information can be made following the procedures set out in Part A of this Policy.

We will respond to your request for access to credit eligibility information within a reasonable time after you make the request and if access is granted, access will be provided within 30 days from your request. Your request for correction will be dealt with within 30 days, or such longer period as agreed by you.

If we deny your request for access or correction, we will provide you with a written notice detailing reasons for the refusal and the process for making a complaint about the refusal to grant your request.

Request for access

We will accept your request for access unless:

• giving access would be unlawful;
• we are required or authorised by law or a court/tribunal order to deny access; or
• giving access is likely to prejudice one or more enforcement related activities conducted by an enforcement body.

Where your request for access is accepted, we will provide you with access to your personal information in a manner, as requested by you, providing it is reasonable to do so.

Request for correction

We will accept your request for correction where we are satisfied that your credit related personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading.

If your request for correction of credit related personal information is accepted we will provide written notice of this correction to any entity to which we have disclosed this information previously, to the extent that this is practicable.

PART C - GENERAL

Complaints

If you believe that Crowies Paints have breached a term of this Policy, the APPs, the credit reporting provisions or CR Code, you may submit a written complaint. The written complaint can be emailed or posted to us using the contact details set out below. You must include contact details for us to contact you regarding your complaint. Our Privacy Officer will consider your complaint and respond as soon as reasonably possible, but not more than 30 days from receiving the complaint.

If you are unsatisfied with the outcome of your complaint you may ask the Privacy Officer to be referred to a higher authority within the company, such as the Managing Director. If you still remain unsatisfied with the outcome, you may refer your complaint to the Office of the Australian Information Commissioner to be resolved.

Contact Us

If you wish to:

• gain access to your personal information;
• make a complaint about a breach of your privacy;
• contact us with a query about how your personal information is collected or used;
• contact us regarding any other matter concerning this Policy,

you can speak directly with our staff who will do their best to try to resolve your issue as simply as possible. Alternatively, you can write to us or send us an email so that our Privacy Officer can consider the matter. We will respond to you as soon as reasonably possible.

Our contact details are as follows:

Phone: (08) 8373 0233
Privacy Officer contact: Daphne Crowhurst, [email protected]
Postal address: 343 Unley Road, Malvern, SA, 5061

For more information on privacy see the Office of the Australian Information Commissioner's website at: http://www.oaic.gov.au