PRIVACY
INTRODUCTION
The following Statement sets out the Privacy Policy of Capricorn Society Ltd (ACN 008 347 313), (“CSL”) and its wholly owned subsidiaries including but not limited to Capricorn Society Financial Services Pty Ltd (ACN 129 134 667) (“CSFS”), Capricorn Mutual Management Pty Ltd (ACN 129 143 479) and Capricorn Travel Australia Pty Ltd (ACN 008 926 645) (“Capricorn Travel”) (collectively the “Capricorn Group”). The Privacy Statement of Capricorn Mutual Limited (ACN 104 601 194) is available at the Capricorn Mutual Limited website ( http://capricornmutual.com ). Unless specified otherwise, the word Capricorn in this statement indicates any and all entities within the Capricorn Group.
In December 2000, the Federal Parliament passed the Privacy Amendment (Private Sector) Act 2000, an amendment to the Privacy Act 1988 (Cth). This Amendment Act introduced 10 National Privacy Principles (NPP’s) for the private sector. Capricorn is bound by these 10 NPP’s.
Capricorn is committed to ensuring the privacy of the personal information you provide to Capricorn. Capricorn believes that respect for your privacy forms part of the ongoing trust Capricorn wishes to develop with you. The following Statement sets out Capricorn’s general policy for the protection of your privacy.
Capricorn takes reasonable steps to protect your personal information that Capricorn holds from misuse, loss and unauthorised access, and to destroy personal information Capricorn no longer requires, unless Capricorn is otherwise required by law to keep it. Capricorn operates under policies and procedures that ensure that personal information is stored securely and is accessible only to those respective employees of the Capricorn Group who require access to the information to perform their duties. Capricorn employees are obligated not to disclose any information about Capricorn’s business operations (including the personal information Capricorn collects) to third parties without the appropriate authorisation.
Your personal information is relevant to your application for membership of CSL.
Capricorn reserves the right to change this Privacy Policy Statement at any time. All changes will be notified by publishing an updated version of the Privacy Policy Statement on the Capricorn website at http://www.capricorn.com.au . Any changes to Capricorn’s Privacy Statement shall be deemed to take place on the date the changes are published on Capricorn’s website.
By providing any member of Capricorn Group with personal information you consent to any and all members of the Capricorn Group using the information for the purposes set out or as permitted in this Statement or as otherwise authorised.
For the purposes of this Statement and unless the contrary intention appears, the singular includes the plural and the opposite gender includes the other gender, an obligation, representation or warranty in favour of 2 or more persons is for their benefit jointly and severally and an obligation, representation or warranty on the part of 2 or more persons binds them jointly and severally, any thing or amount includes any part of it, if a word or phrase is defined, its other grammatical forms have a corresponding meaning and any reference to a person or party includes that person’s or party’s servants, employees, personal representatives, successors and assigns.
THE PERSONAL INFORMATION THAT CAPRICORN COLLECTS & HOLDS
When you are dealing with Capricorn as a CSL member, Capricorn generally stores the following personal information about you in order to manage the business relationship:
- your name, private residential address, age, tax file number and telephone number;
- number of shares held in CSL and bank account details;
- reports from a credit reference agency concerning your credit worthiness or credit history;
- the names of your nominated trade referees and details of your trading history with them,
and possibly also similar information from CSL Preferred Suppliers whom
you have not nominated as trade referees;
- financial information such as assets and liabilities statements;
- the history of your purchases from CSL Preferred Suppliers since you became a CSL
member; and
- notes of dealings with you as a CSL member or CSL Preferred Supplier.
When you are dealing with the Capricorn Group as a customer of Capricorn Travel, Capricorn Travel generally stores the following personal information that relates to travel bookings and associated purchases such as insurance, visa's and foreign exchange:
- your full name as indicated in your passport, passport number, date and place of issue, date of birth, private residential and billing address, age, health issues relevant to your travel
requirements, credit card/debit card number and expiry date and telephone numbers.
In addition, although not mandatory, Capricorn Travel also stores information concerning your travel preferences, frequent flyer details and any other information that would enable travel products and services to be delivered to you.
When you are dealing with the Capricorn Group as a customer of CSFS, CSFS generally stores personal information which comprises:
- name, address, date of birth, gender, marital status, occupation, account details,
contact details (including telephone, facsimile and e-mail) and financial information.
When you are dealing with Capricorn as a prospective employee, Capricorn generally stores the following personal information about you in order to process and evaluate your application:
- name, private residential address and age;
- gender and general health information;
- police security clearance; and
- employment history.
Unsuccessful application forms may be kept on file up to six months to allow those candidates future opportunities.
Under the Privacy Act Capricorn is exempt from the application of the NPP’s relating to employee records of an individual if the act or practice directly relates to a current or former employment between Capricorn and the individual.
Depending upon the service you are utilising, Capricorn may also hold other specific information about you. If you want more detailed information on this matter, then please contact the Capricorn Privacy Officer.
Capricorn may collect personal information by any lawful means whatsoever including directly from you or third parties.
THE MAIN PURPOSES FOR WHICH CAPRICORN HOLDS THE INFORMATION
Capricorn holds personal information for the following purposes:
- to enable and facilitate the delivery and provision of services, benefits and entitlements
to customers, CSL members and CSL Preferred Suppliers;
- to send correspondence in relation to CSL member related services, benefits and events
(including but not limited to convention, annual dinners, other Capricorn organised events
and trade shows) to CSL members;
- to enable/process the delivery of travel products and services (when dealing with
Capricorn Travel);
- to enable/process the delivery of financial products and services (when dealing with CSFS);
- internal accounting and account administration;
- to meet or satisfy the purpose for which the information was provided;
- to protect CSL members, CSL Preferred Suppliers and Capricorn from fraud;
- to help Capricorn identify any products or services that might be beneficial to customers
or CSL members, whether they are offered by Capricorn direct or from CSL
preferred suppliers to CSL Members;
- to comply with obligations imposed on Capricorn by law;
- for Capricorn’s protection, as part of Capricorn’s Risk Management Strategy or as otherwise
reasonably necessary to enforce Capricorn’s legal rights and powers;
- to administer CSL member relationships; and
- to monitor and evaluate Capricorn services and benefits.
USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
The Capricorn business model focuses on people and organisations working together for the mutual benefit of all parties involved. In order to keep Capricorn customers and CSL members informed about updates or changes to the services Capricorn offers, or products and services available from CSL Preferred Suppliers to CSL members, Capricorn may employ a variety of direct marketing techniques.
Capricorn considers that direct marketing to customers and CSL members forms an integral part of delivering services to CSL members, CSL Preferred Suppliers and Capricorn customers, and that these functions or services are directly related to Capricorn’s primary purpose for originally collecting the personal information. Without such a service, the communication between CSL’s members and the CSL Preferred Suppliers would be substantially reduced, and would be unlikely to deliver the benefits and returns that have been experienced to date.
Capricorn does not handle all of the mail-outs to CSL members, CSL Preferred Suppliers and Capricorn customers and you consent to Capricorn providing your personal information to third parties on the terms set out or as permitted in this Statement. The administration and distribution of some updates is out-sourced to an appropriate accredited service provider, who typically provides mailing house services to the private and public sectors. The out-sourcing of this service involves the disclosure of your name and nominated mailing address to the mailing house. Capricorn has taken all reasonable steps to ensure that any service provider deals with your personal information in accordance with the same standards that Capricorn applies.
You also permit Capricorn to disclose your personal information if by your disclosure (including by your agent, servant or delegate) to a mass media organisation or other person, your personal information has ceased to be confidential.
At no time is a CSL member’s personal information or Capricorn customer’s information provided direct to CSL Preferred Suppliers for direct marketing activities. In the instances where a CSL Preferred Supplier wishes to utilise a mail out service to CSL members, the CSL Preferred Supplier is required to send their promotional material to CSL’s approved service provider, where the promotional material is integrated with the other CSL mail going to the CSL member. CSL Preferred Suppliers may also download mailing list labels via the Capricorn website. These mailing lists labels do not contain any of your personal information.
Capricorn may transfer your personal information within the Capricorn Group to each and every entity comprising the Capricorn Group and use your personal information for any purpose for which Capricorn holds your personal information or any purpose necessarily related thereto.
ACCESSING YOUR PERSONAL INFORMATION
Upon request, Capricorn will provide you with details of the information Capricorn has on file about you (unless there is an exception which applies under the National Privacy Principles) including for the purposes of allowing you to correct or update that information. Capricorn’s Privacy Officer will process all such requests within a reasonable time of the date of receipt. Capricorn is permitted to recover a reasonable charge from you for this service.
Capricorn takes reasonable steps to make sure that the personal information Capricorn collects, uses or discloses is accurate, complete and up-to-date.
You have, subject to any exceptions permitted by law, the right to access the personal information Capricorn stores about you. If you find that the information Capricorn holds about you is inaccurate or out of date then Capricorn will at your request in writing correct it. If you wish to access your information that Capricorn holds then Capricorn asks you to contact Capricorn. It will be necessary to verify your identity before considering your request, which Capricorn will process in a reasonable time. While Capricorn will accommodate these requests, Capricorn reserves the right to withhold this information on any lawful basis or under certain circumstances, such as if:
- providing access would pose serious or imminent threat to the life or health of any person;
- providing access would have an unreasonable impact upon the privacy of other individuals;
- the request for access is frivolous or vexatious; or
- providing access would be unlawful, would prejudice any legal investigations, or would
compromise the integrity of the operations of Capricorn.
If Capricorn refuses to provide you with access to the information Capricorn holds about you, Capricorn will provide you with reasons for the refusal and inform you of the basis for the refusal.
Capricorn may transfer personal information to any person or organisation in a foreign country on the terms set out in this Statement or as otherwise authorised including but not limited to:
- Capricorn personnel in a foreign country when the information is required for
operational purposes;
- where you consent to the disclosure; or
- if obtaining your consent is not practical and Capricorn considers that the disclosure is for
your benefit and that you would have consented to the disclosure.
CAPRICORN WEBSITE & EMAILS
When you visit the Capricorn website (www.capricorn.coop), Capricorn may use an Internet browser feature called a cookie. A cookie is a small data file that is placed on the computer of a website user (usually in the browser software folder) the first time a user visits the website. Capricorn stores cookies on the computers of all registered CSL members and CSL Preferred Suppliers who visit the Capricorn website. The cookies do not contain any personal information and are only used to facilitate access to the secure areas of the Capricorn website. If you do not wish to receive cookies you can set your internet browser to refuse cookies, however, this may mean that you are not able to take full advantage of the services the Capricorn website offers.
You have the option to ‘unsubscribe’ and no longer receive electronic marketing/mailing lists on products, services, events etc offered or facilitated by Capricorn. ‘Unsubscribe’ would not apply to credit/debt warning situations and where such a step is taken, this would disadvantage your normal trading with Capricorn.
HOW YOU CAN CONTACT CAPRICORN
If you think your privacy has been interfered with due to a breach of Capricorn obligations in relation to your privacy, then you can complain directly to Capricorn’s Privacy Officer. If you are not satisfied with Capricorn’s response, Capricorn will provide general information concerning your options before further proceeding with your complaint.
At your request Capricorn will provide you with additional information about the way Capricorn manages the personal information Capricorn holds. If you wish to know more about the way Capricorn manages personal information, please contact the Privacy Officer in the following ways:-
· you can write to the Privacy Officer at Locked Bag 436, Victoria Park WA 6979;
· you can call the Privacy officer; (Australia) 1800 005 311, New Zealand 0800 401 444
or Republic of South Africa 0800 993 129.
For further information about privacy issues in Australia and protecting your privacy, you may visit the Federal Privacy Commissioner’s website at http://www.privacy.gov.au.
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