In this privacy policy (“policy”), “we”, “our”, “us” means Neilson Financial Services Pty Ltd, ABN 52 668 314 896 and its related entities. “You” and “your” means the individuals whose personal information we may collect, use and disclose in accordance with this policy. Neilson Financial Services Pty Ltd trades under the following names:

• Dignity Insurance
• Golden Insurance
• Direct Cover

This policy has been provided to let you know how we use and look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send to you. The policy also tells you about your privacy rights and how the law protects you when (i) we contact you (ii) you contact us (iii) you visit our website.

Your consent

By visiting our websites, applying for, renewing or using our products or services or providing us with your personal information, you will be deemed to agree to the terms of this policy and consent to us collecting, holding, using and disclosing your personal information in accordance with this policy, and as may be permitted under the Commonwealth Government’s Privacy Act 1988 (Privacy Act).

The Privacy Act details the Australian Privacy Principles (APPs) which forms the basis of the privacy protection framework in Australia. The APPs govern standards, rights and obligations around:

• the collection, use and disclosure of personal information.
• an organisation or agency’s governance and accountability.
• integrity and correction of personal information.
• the rights of individuals to access their personal information.

It is important that you read this policy carefully. You should also read this policy in conjunction with our Terms of Use and any specific privacy statements or privacy notices provided to you based on your relationship with us, such as those during the policy application and claims process.

This policy is current as of 06 November 2024. We may occasionally update this policy and all changes will be posted on www.dignityinsurance.com.au/privacy-policy/, replacing all previous privacy policies. You should review this policy periodically for changes.

Our commitment to you

Your privacy is important to us. We are committed to fully complying with all applicable privacy responsibilities. We shall endeavor to ensure all appropriate safeguards are in place to keep any personal information we collect and hold about you safe and private, and that the personal information we obtain and use will always be held, used, transferred and otherwise processed in accordance with the Privacy Act.

Types of information we may collect

We collect personal information that is necessary for us to provide you with the financial products and services you have requested from us. The types of personal information we collect will depend on your relationship with us, such as whether you are a customer, website user, a claimant, a health service provider or another third party (such as a financial adviser or an existing or potential business partner).

• Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable:

              a) whether the information or opinion is true or not; and

              b) whether the information or opinion is recorded in a material form or not.

Personal information includes a broad range of information which may include (but is not limited to) an individual’s name, signature, address, phone number, date of birth, sensitive information and internet protocol (IP) addresses.

• Sensitive information is a subset of personal information that includes information or an opinion about an individual’s racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information and some aspects of biometric information.

The types of personal information we may need to collect and hold about you include your name, address, email address, and telephone number. We may also collect other information, including sensitive information, where necessary. This can include, but is not limited to, your age, gender, occupation, financial information (including bank account and credit card details), health and lifestyle information, and government related identifiers.

We also collect details about your interactions with us, like phone calls and emails, as well as information about your use of our website or applications using cookies or other digital tracking technology.

Where we collect personal information from

We collect personal information from you when you contact us over the telephone or by email, when you complete application forms and when you access our website. We may also collect personal information about you from third parties.

Information you provide:

• when you apply for products and services
• when you talk to us on the phone
• when you use our websites
• in forms, letters and emails
• when you make a claim and from other supporting documents
• when you participate in surveys and questionnaires
• social media

We may also receive information from:

• third parties we work with
• companies that introduce you to us
• comparison websites
• general practitioners, other medical professionals, your treating hospital, or other health service providers
• other people or organisations who might be representing you
• publicly available sources of information

The categories of personal information that we may obtain from third parties are:

• name
• gender
• contact details (email address and telephone number)
• birth date
• address and postcode
• health and lifestyle information

When you provide us with personal information about others, you confirm you have their consent to do so including giving us consent to process and use their personal information as detailed in this policy. You should inform the individual about the content of this policy and any other applicable privacy notices provided to you.

Information we collect when you use our services

• Personal information that can help us identify you.
• Personal information that can help us contact you.
• Personal information to assess your application for cover. This may include information about your health and lifestyle. We will only collect this information if the law allows us to do so.
• Payment and transaction data.
• Any profile you create or information you provide when you connect to our internet, mobile and telephone services (we do this using cookies, further details can be found under the heading “Cookies”).

Cookies

We use cookies on our website(s) and other similar technologies to collect anonymous information so that we can improve and enhance your experience when you use our services.

“Cookies” are small pieces of text files which are sent to your browser and stay on your computer or mobile device when you visit our website. Cookies do not damage your device, they are used to ‘remember’ you when you visit our website again. Cookies alone cannot be used to identify you. A cookie will transport information about how you use our website to us. The cookie does not keep any of the information it collects.

Cookies allow us to:

• Make our website work as effectively and efficiently as possible.
• Enhance your browsing experience.
• Arrange content to match your preferred interests more quickly.
• Collect statistical information to provide us with information on how our customers use our website and our products.

We will collect information about how you use our website to:

• Remember how far you are in the online application form you are completing.
• Provide advertising that is more relevant to you when you are visiting our, or other, websites promoting our products, for example via retargeting cookies.
• Track the effectiveness of our online and offline marketing campaigns.

Your web browser provides settings that allow you to manage or switch off cookies. If you do switch off cookies, remember that you may not be able to use all the services on our website.

We also use social media cookies which are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools. These social media services have their own privacy policies which will be applicable to you when you access social media links and features.

How we use your personal information

We use your personal information for legitimate business purposes and as may be permitted or required by law. Examples of how we may use your personal information includes (but is not limited to):

• to inform you about products or services which we think may be of interest to you.
• to assess your eligibility for any insurance products or services we distribute.
• to provide administration services in respect of any insurance products or services we distribute.
• to respond to questions and other requests raised by you.
• to optimise your experience on our website.
• for internal purposes, such as analysing and managing our business and improving our products and services.
• to manage complaints and disputes, and report to dispute resolution bodies.
• to manage, train and develop our employees and representatives.
• for other everyday business purposes that involve use of personal information.
• to satisfy our legal and regulatory requirements.

More detail may be provided to you in a separate privacy notice when you contact us or, where relevant, in a separate contractual arrangement with you.

We ensure that we have an appropriate legal basis to deal with your personal information in these ways. This includes how we share information outside of Neilson Financial Services Pty Ltd. We will only process personal information in the following circumstances:

• If it is necessary to fulfil and administer a contract we have with you.
• When it is in our legitimate business interest to do so.
• When we have a legal duty to.
• When you consent to it.
• Where a ‘permitted general situation’ exists such as to lessen or prevent a serious threat to life, health or safety.

Who we share your personal information with

We may use and share your personal information with service providers and financial institutions who we partner with. This includes the insurer and reinsurer when you apply for insurance through us.

Our service providers and partners will process your personal information for the following business purposes:

• making decisions about whether to provide insurance and assistance services (such as claim assessment, claim processing and claim settlement);
• administering the policy, assessing and paying claims, and general customer service activities (including complaint resolution and claims disputes);
• detecting, investigating and preventing crime, including fraud and money laundering;
• carrying out market research and analysis;
• providing information about your policy in connection with any reinsurance; and
• complying with applicable laws and regulatory obligations (including laws and regulations outside of country of residence).

In addition, we may share your personal information with third parties we partner with, to provide you with additional products, services or promotional offers you have applied for. Other third parties we may share your personal information with, where applicable, can include investigators, legal professionals, accountants, health professionals, your beneficiaries, or the executor of your estate.

We may also share your personal information with law enforcement, government and regulatory bodies and industry disputes resolution bodies, to fulfil a legal or regulatory obligation, assist with an investigation, or demonstrate compliance.

If we sell our company or part of it, we will share your information with the purchaser, who may then provide you with information on their products and services.

Transferring your personal information outside of Australia

We may disclose personal information to an overseas recipient and transfer personal information you provide to us outside of Australia. Again, we will ensure that all appropriate safeguards are in place in connection with such transfer and that all necessary consent has been obtained, if required.

We may need to transfer your personal information to our related entities, partners and service providers who are predominately located in the United Kingdom, the Republic of Ireland and the United States of America. Our related entities, partners and service providers may have other foreign relationships with entities in different countries. This means that your personal information may be accessible to law enforcement and regulatory authorities in those countries. However, if we transfer your personal information to third parties outside Australia, we will ensure that such third parties protect your personal information in a manner which is consistent with this policy and the privacy laws in Australia. This includes checking that the third party:

• is subject to the Privacy Act because they do business in Australia;
• will adequately protect the information, e.g. by using model contract clauses; or
• is subject to privacy laws that provide comparable safeguards to the Privacy Act.

If none of the above criteria apply, we will only make a cross-border disclosure with your consent or where it is permissible by law.

If you choose not to give personal information

You do not have to provide us with your personal information, but if you choose not to do so, we may not be able to provide certain products or services to you, such as processing your application for insurance and maintaining or administering your policy.

We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to administer your policy. It could also mean that we cancel a product you have with us.

Any information collection that is optional will be made clear at the point of collection.

Direct Marketing

We may use your personal information to send you marketing messages to tell you about relevant products and services or offers that may be of interest to you.

You can ask us to stop sending you marketing messages and update your choices by contacting us at any time (see under the heading “How to contact us”).

Whatever you choose, you will still receive important information such as changes to your existing products.

Anonymity and pseudonymity

You have the option of dealing anonymously or by pseudonym with us unless we are required or authorised by law or a court or tribunal to identify you, or it is impracticable for us to deal with you anonymously or by a pseudonym.

How we will protect your personal information

We have appropriate safeguards in place to protect your personal information against loss, theft, and unauthorised access, disclosure, copying, use or modification. This includes strictly limiting access to your personal information to those of our employees, partners and service providers who require access to it, training our employees to understand privacy and information protection requirements, and using various systems and services (including technical measures) to securely store your information.

While we take steps to protect your personal information, please be aware that no internet transmission is ever completely secure or error- free. If you provide any personal information to us over the internet or send us an email, or if we provide information to you by these means, the privacy, security and integrity of any information transfer over the internet cannot be guaranteed. When you share information with us over the internet or by email, it is at your own risk as factors beyond our control include the security of the device and/or program you use to communicate with us, and steps you take to protect your login details and password. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us (see under the heading “How to contact us”).

Our website may also contain links or references to other websites or social media platforms not subject to this policy. You should check their own privacy policies before providing your personal information.

We will retain your personal information only for as long as is necessary for legal, regulatory, or operational reasons, such as to administer any insurance products or services we distribute to you or for tax and other reporting requirements. We will take reasonable steps to destroy or de-identify personal information that we no longer require.

Your rights to access and correct your personal information

You are entitled to request access to any personal information which we hold about you.

You may also challenge the accuracy and completeness of any personal information which we hold about you. Where any personal information is inaccurate or incomplete, you are entitled to request that the inaccurate or incomplete personal information is appropriately amended.

You may exercise your rights set out above at any time by contacting our Privacy Officer. You can email, write or call us (for our contact details, see under the heading “How to contact us”).

There may be a reasonable charge incurred in connection with us providing any copies of your personal information or we may be unable to comply with your request fully, but we will inform you beforehand if this is the case unless we are prohibited from doing so by law.

You must keep us informed of any changes to your information, like your contact details or address, to ensure your details remain accurate, up-to-date and complete.

How to withdraw your consent

If we have relied upon your consent to process your personal information, you can withdraw your consent at any time. Please contact us if you wish to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will let you know.

You also have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it.

However, there may be occasions when we will not be able to delete personal information if a legal or regulatory requirement prevents us from doing so.

How to contact us (including to make a complaint)

You can email, write or call us using the following contact details if you have any questions and requests regarding this policy and your privacy:

Phone: 1800 089 426

Email: care@dignityinsurance.com.au

Address: PO Box R985, Royal Exchange, NSW 1225

If you wish to make a complaint about a breach of this policy, the APPs or the Privacy Act, you can contact us using the contact details above. Your complaint will be referred to our Privacy Officer who will look to review and resolve your complaint within 30 days of the date it is received.

If you are not satisfied with the response to your complaint, we will tell you about any external dispute resolution provider which may be available to you. You can also contact the Office of the Australian Information Commissioner (OAIC) on:

Phone: 1300 363 992

Address: GPO Box 5288, Sydney, NSW 2001

Website: http://www.oaic.gov.au