Privacy policy.

Upward Insurance Group (we, us or our) respects your privacy and is committed to handling your personal information responsibly and in accordance with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (APPs) set out in the Act.

Upward Insurance Group, ABN 86 701 489 376, operates as a Corporate Authorised Representative (CAR No. 001322938) of Delaney Kelly Golding Pty Ltd, which holds Australian Financial Services Licence (AFSL) No. 231146. We are authorised under that licence to provide insurance broking and related financial services.

This Privacy Policy explains how we collect, hold, use and disclose your personal information, how you can access and correct the information we hold about you, how you can complain about a breach of your privacy rights, and how we will deal with any such complaint.

This Policy applies to personal information collected by us in the course of providing insurance broking, advice and related services, including through our website, over the phone, by email or in person.

Our commitment to your privacy

We recognise that your personal information belongs to you, and we are committed to collecting, storing and handling it carefully and securely.

We will not use or disclose your personal information for any purpose other than as set out in this Policy, as you would reasonably expect, with your consent, or as otherwise permitted or required by law.

The personal information we collect

To provide our insurance broking services, arrange insurance cover, assess your needs and manage claims, we typically need to collect personal information about you. Depending on the product or service, this may include:

• Identification details, such as your name, date of birth and gender.
• Contact details, such as your residential and mailing address, email address and telephone number.
• Details of the property, assets or risks to be insured.
• Financial information, including bank account details and information about your financial position where relevant to your insurance arrangements.
• Information relevant to a claim, including the circumstances of any loss, injury or damage.
• Sensitive information, such as health information, where relevant to the insurance or claim (we will only collect sensitive information with your consent or as otherwise permitted by law).
• Your insurance and claims history.
• Employment history, residency status and identity verification information, where required.
• Any other personal information reasonably required to arrange your insurance, manage your policy or assist with a claim.

Where we arrange insurance on your behalf, we pass relevant information to insurers, underwriting agencies and premium funders so that they can assess whether to offer you cover, on what terms, and how your premium may be funded. Insurers may in turn share this information with their reinsurers, some of whom may be located outside Australia.

If you make a claim, we will collect information about the claim from you and, where necessary, from other parties (such as witnesses or other parties involved). We will provide this information to your insurer, and to any loss adjusters, investigators, medical practitioners or other service providers engaged to assess or manage the claim.

From time to time, we may use your contact details to send you information about products, services or offers that may be relevant to you. You may opt out of receiving marketing communications at any time by contacting us using the details below.

What happens if you do not provide your information?

We can only properly advise you and arrange or manage your insurance if we have the information we need. If you have a consumer insurance contract, you have a duty to take reasonable care not to make a misrepresentation to the insurer. For other types of insurance contracts, a duty of disclosure may apply — your insurer will explain the specific duty that applies and the consequences of not meeting it.

If you do not provide the personal information we request, we may not be able to provide you with our services, arrange insurance cover, or process a claim on your behalf.

Disclosure of information overseas

In the course of providing our services, we, or the insurers and underwriters we deal with, may disclose your personal information to organisations located outside Australia, including reinsurers, technology and policy administration service providers, and other business partners.

Where practical, we will let you know if your information is likely to be disclosed to a recipient located overseas, and the countries in which such recipients are likely to be located. Please note that overseas recipients may not be subject to privacy laws that offer the same level of protection as the Australian Privacy Principles.

Before disclosing your personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient handles your information in a manner consistent with the Australian Privacy Principles, unless an exception under the Act applies.

How we store and protect your information

We take reasonable steps to keep the personal information we hold accurate, complete and up to date, and to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure.

Your information may be held in electronic systems and databases, as well as in paper records. We use physical security measures (such as locked storage and restricted premises access) and technical security measures (such as firewalls, secure networks, and user access controls) to protect your information.

We retain personal information only for as long as reasonably necessary to fulfil the purpose for which it was collected, or as required to meet our legal, regulatory or reporting obligations.

If there is a data breach

If we become aware of a data breach involving your personal information that is likely to result in serious harm, we will take steps in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth). This includes assessing the breach, notifying the Office of the Australian Information Commissioner (OAIC) where required, and notifying affected individuals about the breach, the information involved, and steps you may wish to take.

Who we may disclose your information to

We do not sell, rent or trade your personal information. We may disclose your personal information to:

• Insurers, underwriting agencies, premium funders and reinsurers, to arrange and manage your insurance.
• Our licensee, Delaney Kelly Golding Pty Ltd, and related entities, for the purposes of providing our services under its Australian Financial Services Licence.
• Service providers who assist us with claims handling, loss adjusting, IT systems, policy administration, mailing and other administrative functions.
• Professional advisers, regulators and government bodies, where required or authorised by law.
• Any other party with your consent, or as otherwise permitted or required under the Privacy Act.

We require third parties who handle personal information on our behalf to take reasonable steps to protect that information in a manner consistent with the Australian Privacy Principles.

Accessing and correcting your information

You may request access to the personal information we hold about you or ask us to correct information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, please contact our Privacy Officer using the details set out below.

We will generally not charge a fee for a request for access or correction. However, where a request requires a significant amount of time or resources to fulfil, we may charge a reasonable fee to cover our costs, and we will let you know of any proposed charge in advance.

In some circumstances, we may be unable to give you access to your information or make a requested correction — for example, where this is permitted or required by law. If this occurs, we will explain our reasons and how you may seek review of our decision.

Website, cookies and anonymous data

Our website may use cookies and similar technologies to improve functionality and understand how visitors use our site. Cookies are small files stored on your device that may collect information such as your browser type, IP address, and pages visited.

This information may be used for statistical and analytical purposes to help us improve our website and services. You can adjust your browser settings to refuse or delete cookies, although this may affect the functionality of parts of our website.

Where you submit information to us through an online form (such as a quote request or contact form), that information will be used to respond to your enquiry and, where relevant, to provide you with our services.

The content on our website is provided for general information purposes only and does not constitute personal advice. You should seek professional advice before relying on any information contained on the site. To the extent permitted by law, we accept no liability for any loss arising from reliance on the content of our website.

How to make a complaint

If you have a concern about how we have handled your personal information or believe we may have breached the Privacy Act or the Australian Privacy Principles, please contact our Privacy Officer with details of your concern.

Privacy Officer — Upward Insurance Group
PO Box 1670
North Sydney NSW 2059
Telephone: (02) 9929 7299
Email: compliance@dkg.com.au

We will acknowledge your complaint promptly and aim to provide a response within 30 days. If we require additional time to investigate, we will contact you to agree on a reasonable timeframe.

If you are not satisfied with our response, you may refer your complaint to:

Office of the Australian Information Commissioner (OAIC)

• Website: www.oaic.gov.au
• Telephone: 1300 363 992

Australian Financial Complaints Authority (AFCA)

AFCA can consider certain privacy-related complaints connected with financial services. Please contact AFCA to confirm whether it is able to assist with your complaint.

• Website: www.afca.org.au
• Email: info@afca.org.au
• Telephone: 1800 931 678
• Mail: GPO Box 3, Melbourne VIC 3001

Your consent

By providing us with your personal information and asking us to assist with your insurance needs, you consent to us collecting, using and disclosing that information in accordance with this Privacy Policy. Where the law requires us to obtain your specific consent for a particular collection, use or disclosure, we will seek that consent separately.

Updates to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The most current version will be available on our website. We encourage you to review this Policy periodically.

Contact us

If you have any questions about this Privacy Policy or how we handle your personal information, please contact us:

Upward Insurance Group
ABN 86 701 489 376 · CAR No. 001322938 of Delaney Kelly Golding Pty Ltd (AFSL No. 231146)
PO Box 1670
North Sydney NSW 2059
Telephone: (02) 9929 7299
Email: info@upwardinsurance.com.au
Website: www.upwardinsurance.com.au