1. Introduction

Simplygreen Australia Pty Ltd (ABN 60 123 823 914) (“Simplygreen”, “we”, “us”, or “our”) is committed to managing personal information in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, hold, use and disclose personal information in connection with the provision of our salary packaging and novated leasing services.

By providing personal information to us, or by otherwise engaging with our services, you acknowledge that you have read and understood this Privacy Policy.

2. Scope and Application

This Policy applies to personal information collected by Simplygreen:

·     via our website (www.simplygreen.com.au);

·     directly from individuals;

·     from employers, financiers, insurers and other third parties in connection with our services.

This Policy does not apply to acts or practices which are exempt under the Privacy Act.

3. Types of Personal Information

We collect and hold personal information that is reasonably necessary for the conduct of our business, including:

·     identity information (such as name and date of birth);

·     contact details;

·     employment and payroll information;

·     financial information (including banking details and lease obligations);

·     taxation-related information;

·     vehicle, insurance and asset information;

·     supporting documentation (including invoices, receipts, agreements and statements);

·     transaction history and account records; and

·     technical and usage data relating to our website and systems.

We do not generally collect sensitive information (as defined in the Privacy Act) unless it is reasonably necessary and you have consented, or we are otherwise authorised or required by law.

4. Collection of Personal Information

4.1 Direct Collection

We collect personal information directly from individuals when they:

·     apply for or participate in salary packaging or novated leasing;

·     submit forms or supporting documentation;

·     communicate with us.

4.2 Indirect Collection

We may also collect personal information from third parties, including:

·     employers and payroll providers;

·     finance providers and lenders;

·     insurance providers and underwriters;

·     fleet, fuel and maintenance providers;

·     referral partners and intermediaries (with appropriate authority).

Where personal information is collected indirectly, we take reasonable steps to ensure individuals are made aware of such collection where required under the Privacy Act.

5. Purposes of Collection, Use and Disclosure

We collect, hold, use and disclose personal information for purposes including:

·     administering salary packaging arrangements;

·     facilitating, implementing and managing novated lease agreements;

·     processing payroll deductions, reimbursements and payments;

·     liaising with employers, financiers, insurers and service providers;

·     complying with taxation, regulatory and legal obligations;

·     managing customer relationships and providing support;

·     improving our systems, processes and services; and

·     marketing our services where permitted by law.

We will not use or disclose personal information for purposes unrelated to those described above unless permitted or required by law.

6. Disclosure of Personal Information

We may disclose personal information to:

·     employers and payroll providers;

·     finance companies and lenders;

·     insurance providers and underwriters;

·     payment processors and financial institutions;

·     fleet, fuel, maintenance and roadside assistance providers;

·     IT service providers, cloud hosting providers and system administrators;

·     professional advisers (including legal, accounting and audit);

·     regulatory authorities (including the Australian Taxation Office);

·     law enforcement agencies where required or authorised by law.

We take reasonable steps to ensure that recipients of personal information are subject to obligations of confidentiality and privacy.

7. Cross-Border Disclosure

Personal information may be disclosed to, or stored by, service providers located outside Australia.

Where this occurs, we take reasonable steps to ensure that such recipients handle personal information in a manner consistent with the APPs or are otherwise subject to substantially similar privacy obligations.

8. Data Security

We implement reasonable technical and organisational measures to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

These measures include, but are not limited to:

·     secure cloud-based systems and infrastructure;

·     access controls and authentication protocols;

·     encryption and data protection mechanisms;

·     managed IT and cybersecurity services;

·     internal policies and staff confidentiality obligations.

Notwithstanding these measures, no method of transmission or storage of data is completely secure, and we do not guarantee the absolute security of personal information.

9. Data Retention

We retain personal information only for as long as necessary to:

·     fulfil the purposes for which it was collected;

·     comply with legal, regulatory and contractual obligations; and

·     establish, exercise or defend legal rights.

When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

10. Notifiable Data Breaches

In the event of a data breach involving personal information that is likely to result in serious harm, we will comply with our obligations under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.

This includes:

·     assessing the suspected breach in a timely manner;

·     taking reasonable steps to contain and mitigate the breach; and

·     notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.

11. Access and Correction

Individuals may request access to, or correction of, personal information held by us.

We will respond to such requests within a reasonable period and in accordance with the Privacy Act. We may refuse access in circumstances permitted by law.

12. Marketing Communications

We may use personal information to provide information about our services where permitted by law.

Individuals may opt out of receiving marketing communications at any time by:

·     using the unsubscribe function; or

·     contacting us directly.

13. Website and Cookies

Our website may collect technical information via cookies and similar technologies, including:

·     IP address;

·     browser type;

·     device information;

·     pages visited and interaction data.

This information is used to improve website performance and user experience.

Users may adjust browser settings to disable cookies, although this may affect functionality.

14. Complaints

If you believe we have breached the Privacy Act or the APPs, you may submit a complaint using the contact details below.

We will:

·     acknowledge the complaint within a reasonable timeframe;

·     investigate the matter; and

·     provide a written response outlining the outcome.

If you are not satisfied, you may refer the complaint to the Office of the Australian Information Commissioner (OAIC).

15. Amendments

We may amend this Privacy Policy from time to time.

The current version will be published on our website and will take effect upon publication.

16. Contact Details

Simplygreen Australia Pty Ltd

ABN 60 123 823 914

Level 4, 54 Wellington Street

Collingwood VIC 3066

Email: info@simplygreen.com.au

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