Privacy
Policy V1 / June 2021 1
HVG
Graphics Privacy Statement, Privacy Policy, Credit Reporting Policy and
Statement of Notifiable Matters
Privacy
Statement and Privacy Policy
This
Privacy Statement, Privacy Policy, Credit Reporting Policy and Statement of
Notifiable Matters sets out the Privacy and Credit Information Policy of HVG
Graphics Pty Ltd (ACN 649 379 635) (ABN 75 649 379 635) of 29 Henderson Street,
Turrella, NSW 2205 (referred to hereafter as “HVG Graphics”).
Privacy
Laws
HVG
Graphics is bound by the Privacy Act 1998, the Privacy (Enhancing
Privacy Protections) Act 2012, the Credit Reporting Privacy Code and the
Australian Privacy Principles (“the APPs”) as amended from time to time.
Privacy
Statement
HVG
Graphics is committed to your privacy. Our policy on the handling of personal
information is to comply with the Australian Privacy Principles (“the APPs”)
for the fair handling of Personal Information (any information from which your
identity is apparent) and Credit Information (your repayment and default
history, amount and type of credit provided, and any default information) as
set out in the Privacy Act 1988 and the Privacy (Enhancing Privacy
Protections) Act 2012 as amended. In accordance with those principles and
the HVG Graphics Privacy Policy and Privacy Statement, a copy of which is
located on our website at www.hvggraphics.com.au persons will be given access to their personal
information on request. We use the types of Personal Information collected for
several purposes which include considering and assessing applications for
employment, enabling us to supply you with our products and/or services and for
assessing Applications for Commercial Credit and Guarantee documents, managing
accounts including overdue accounts and, if necessary, insuring our risk in
collecting debts. This information may be disclosed to our related or
associated entities, parties related to your employment (e.g. referees and
others as set out in our Privacy Policy), contractors, other Credit Providers
whether or not your account is overdue and, if necessary, our Risk Insurers,
debt collectors, lawyers and other service providers, and Credit Reporting
Bodies including Equifax (www.equifax.com.au), Illion (www.illion.com.au) and others. If all or
part of the information requested is not provided we may not be able to
consider any application made by you or to supply you with our goods and/or
services and we may not be able to process your Application for a Commercial
Credit Account. If you have any questions or concerns about our Privacy Policy,
the type of information we may hold about you, or for corrections or complaints
about a breach of your privacy, please direct your requests to the Privacy
Officer at our Head Office address at 29 Henderson Street, Turrella, NSW 2205
or e-mail [email protected]
Collection of your personal information
HVG Graphics is committed to the protection of your personal information.
Personal information is any information or an opinion about an identified
individual or an individual who is reasonably identifiable. Generally, the kind
of information HVG Graphics will collect about an individual include an
individual’s name, signature, residential address, telephone number, date of
birth, bank account details or credit card information, and commentary or
opinion about a person, for example credit commentary, eligibility or
information received from Veda or Dun and Bradstreet.
The specific types of personal and business information that we
collect from you will depend on the services you require from us and how you
interact with us. When you apply to do business with us we will ask you many
details to do with you and your business. That information then assists us in
making business decisions about our intended business relationship and the
terms of that relationship. If the personal information requested is not
supplied HVG Graphics may not be able to consider any application made by you,
or to supply you with our goods and/or services and we may not be able to
process your Application for a Commercial Credit Account.
At the time of collecting personal information about an individual,
or as soon as practicable after that time, HVG Graphics takes reasonable steps
to ensure the individual is aware of:-
a) The identity and contact details of HVG Graphics and HVG
Graphics’ Privacy Officer;
b) The purposes for which the information is being collected;
c) Any organisations to which HVG Graphics may possibly disclose
the information to;
d) The fact that an individual has a right to gain access to the
personal information collected;
e) The main consequences (if any) for the individual if all or part
of the information is not provided.
We will not collect any personal information from you revealing
racial or ethnic origin, political opinions, religious or philosophical
beliefs, trade union membership, or details of health, disability or sexual
activity or orientation. Exceptions to this include:
a) Where you have given express consent to HVG Graphics to do so;
b) Where is it necessary for HVG Graphics to carry out one of its
primary functions;
c) Where there are reasonable grounds to believe that disclosure is
necessary to prevent a threat to life or health;
d) The use is authorised by law or reasonably necessary to enforce
the law; or when the information is necessary for the establishment, exercise
of defence of a legal claim.
When you use HVG Graphics’ website at www.hvggraphics.com.au, our Internet Service
Provider (ISP) may make a record of your visit and log your server address,
your domain name, the date, time and duration of your visit, the pages and
documents you accessed, the previous site you had accessed (i.e. the referring
URL) and the type of browser you are using. This information is collected for
statistical purposes only, and HVG Graphics will not make any attempt to identify
users according to their browsing activity.
In
the unlikely event of an investigation, a law enforcement agency or other
government agency may exercise its legal authority to inspect our business
records or ISP’s logs. It is also possible that your ISP is logging your
activity while you visit our site. This is obviously beyond the control of HVG
Graphics.
While
you are visiting our site, we may use cookies to facilitate a more personalised
web browsing experience. Except where you volunteer personal or business
information, we will not procure information about you via any alternative
means while you visit our website.
How
we use and disclose personal information
The
personal information that you provide to us before during or after our business
relationship, or before or after or during interaction on this site, and in
other interactions between us, is used for a number of primary purposes,
including the following:-
a)
Enabling us to supply you with our products and services;
b)
Managing, servicing and reviewing Accounts, including overdue accounts;
c)
Managing Customer Payment information, including credit card information and
bank account details;
d)
Considering and assessing applications for employment;
e)
Providing you with better service for the supply of products and services; and
f)
Insuring and assessing our risk in collecting debts.
HVG
Graphics will not sell, rent or trade your personal information.
Any
personal or business information which you do supply will only be used
internally at HVG Graphics and will not be divulged to a third party unless
that third party is associated or integral to the purpose for which you gave us
the information or where required by law. We will only use and disclose
information about you for the purpose for which you gave us that information.
We may use and disclose information about you for a purpose other than the
purpose for which you gave us the information where:
a)
That other purpose is related to the purpose for which you gave us the
information;
b)
You have given us your consent for the personal information to be used or
disclosed for the additional purpose;
c)
Where there are reasonable grounds to believe that use or disclosure is
necessary to prevent a threat to life or health;
d)
Where we suspect that unlawful activity is or has been engaged in and we use or
disclose the personal information to investigate the suspected unlawful
activity; or
e)
The use or disclosure is authorised by law or reasonably necessary to enforce
the law.
During
the ordinary course of business, HVG Graphics may disclose your information as
required by law or to parties related to your employment (e.g. referees or
WorkCover Insurers), our contractors, other credit providers (whether or not
your account is overdue) and, if necessary, our Risk Insurers, debt collectors,
solicitors, other professional advisors and Credit Reporting Bodies including
Equifax (www.equifax.com.au), Illion (www.illion.com.au) and others. HVG
Graphics may also disclose your personal information to organisations involved
in a transfer or sale of all or part of our business or its assets or one
involved in managing our corporate risk and funding requirements.
HVG
Graphics’ Credit Department has well-documented detailed procedures, which are
compliant with the APPs, in managing personal data relating to the
administration of customer accounts. Compliance to these procedures is
monitored on an ongoing basis.
Direct
Marketing
HVG
Graphics may also use your personal information, including e-mail addresses,
for the purpose of direct marketing. We may only use your personal information
or data for the purpose of direct marketing in relation to promotional
activities where it is impracticable for us to obtain your prior express
consent. However, when we do this, we will provide an express opportunity when
we first contact you to decline receiving any further marketing communications from
us, via an opt-out mechanism. Please contact us if you do not want to receive
any direct marketing information or if you do not want your information
disclosed for direct marketing purposes.
Overseas
Disclosure
In
the normal course of its business, HVG Graphics may disclose personal
information to overseas recipients such as HVG Graphics’ related or associated
companies, or to third parties. This disclosure may occur if HVG Graphics’
service providers are located overseas, if any transactions, information,
products or services have an overseas connection, where the individual
consents, where the disclosure is for the benefit of the individual or is for
the performance of a contract with HVG Graphics. HVG Graphics will take
reasonable steps to protect an individual’s privacy if this disclosure occurs.
You agree and consent to the possible use and disclosure of this information to
overseas recipients from time to time in accordance with this Privacy Policy
and Privacy Statement.
Security
of your personal information
HVG
Graphics will take all reasonable steps to ensure that all personal information
we collect, use or disclose is stored both physically and electronically in a
secure environment accessed only by authorised persons. HVG Graphics will take
reasonable steps to protect any personal information that it holds from misuse,
loss, unauthorised access, modification or disclosure, and to destroy or
permanently de-identify personal information if it is no longer needed for any
purpose. HVG Graphics requires any third party, service provider, or other
entity to which HVG Graphics discloses information to comply with this Privacy
Statement and Privacy Policy and to comply with the APPs.
HVG
Graphics maintains sophisticated IT systems to keep its customer, vendor and
employee data on master files. HVG Graphics has security measures designed to
protect against the loss, misuse and/or alteration of the information under its
control, including restricted access, firewalls and encryption.
While
HVG Graphics employs anti-virus software and encryption technology when
interfacing with its customers, suppliers, contractors and other parties, you
should be aware that there is a residual risk in transmitting any data
electronically. This risk is inherent in any Internet dealings.
How
to access, correct or update your information
HVG
Graphics will take all reasonable steps to ensure that all information we
collect, use or disclose is accurate, complete and up-to-date, and will review
information on its databases at regular internals to ensure all information
kept is up to date.
You
have a right to seek access to your personal information and to make correction
to that information. Please contact the Privacy Officer if your details change
or if you believe the information we have about you is not accurate or
complete. We will provide you with reasonable opportunity to access your
personal information and have it corrected or updated. A fee may apply to such
access and you will be required to provide the appropriate identification.
Exceptions
to your access rights may include:
a)
Where providing access will pose a serious threat to the life or health or any
individual or pose an unreasonable impact on the privacy of an individual;
b)
Your request for access is frivolous or vexatious;
c)
Where the information relates to existing legal proceedings between HVG
Graphics and you and the information would not be discoverable in the process
of those legal proceedings; or
d)
Where providing access would be unlawful, may prejudice an investigation of
possible unlawful activity, may prejudice enforcement of laws, or denying
access is specifically authorised by law.
Where
HVG Graphics refuses a request for correction or access, you will be provided
with written reasons for the refusal and details of complain mechanisms.
Complaints
HVG
Graphics takes your complaints seriously. If you believe that HVG Graphics has
not dealt with your personal information in a manner that complies with the Privacy
Act 1998, the Privacy (Enhancing Privacy Protections) Act 2012, the
Credit Reporting Privacy Code and the Australian Privacy Principles (“the
APPs”) as amended from time to time, please contact the Privacy Officer, 29
Henderson Street, Turrella, NSW 2205 or e-mail [email protected] or via any of our
contact details listed at www.hvggraphics.com.au. You will be required to put your complaint in
writing. HVG Graphics will use its best endeavours to provide a response in
writing within a timely manner, and to correct any personal information and
notify any other entity required with updated information.
HVG
Graphics has detailed procedures for dealing with Privacy breaches. If you are
dissatisfied with the outcome of your complaint, or if HVG Graphics refuses to
provide access to, or correction of, your personal information, you may
complain to the Office of the Australian Information Commissioner at http://www.oaic.gov.au.
Transparency
This
Privacy Statement and Policy is available on HVG Graphics’ website at www.hvggraphics.com.au.A copy of
this Privacy Statement and Policy will be made available to anyone who requests
it. This Privacy Statement and Privacy Policy may be reviewed and amended from
time to time, and any updated version will be made available on and will apply
from the date the updated version is published on HVG Graphics’ website or upon
request.
How
to contact us
You
can contact HVG Graphics and our Privacy Officer at our head office premises at
29 Henderson Street, Turrella, NSW 2205 or e-mail [email protected]or via any
of our contact details listed at www.hvggraphics.com.au.
Credit
Reporting Policy
This
Credit Reporting Policy sets out how HVG Graphics will manage your Credit
Information (your repayment and default history, amount and type of credit
provided, and any default information) and your Credit Eligibility Information
(Information provided by other Credit Providers and Credit Reporting Bodies).
Our handling of your Credit Information complies with our obligations under thePrivacy Act 1988 (“the Act”) and the Credit Reporting Privacy
Code (“CR Code”).
This
Credit Reporting Policy is to be read together with our Privacy Policy and our
Statement of Notifiable Matters.
Collection
of your Credit Information and Credit Eligibility Information
HVG
Graphics may collect, use, hold and disclose Credit Information about you. You
consent to such collection, holding, use and disclosure of your Credit
Information in accordance with the terms of this policy.
If
you apply for commercial credit or provide a guarantee for commercial credit,
the kinds of Credit Information and Credit Eligibility Information that we may
collect and hold includes information used to identify you, your
creditworthiness and any other related information necessary or incidental to
the products and services which HVG Graphics provides or proposes to provide to
you. This may include:
•
identification information; or
•
consumer credit liability information; or
•
repayment history information; or
•
a statement that an information request has been made in relation to you by a
credit provider;
•
payment or default information; or
•
new arrangement information; or
•
court proceedings information; or
•
personal insolvency information; or
•
publicly available information in relation to your creditworthiness.
Sometimes,
we may gather Credit Information and Credit Eligibility Information about you
from a third party, for example, from Credit Reporting Bodies (“CRB’s”) (for
example, Veda and Dun & Bradstreet) or intermediaries and spouses or from
publicly available information.
The
Credit Information that you provide assists us in making business decisions
about our intended business relationship and the terms of that relationship. We
may not be able to transact business with you if you do not provide all of the
information requested and we may not be able to process any Application for
Commercial Trading Account.
How
we Use and Disclose your Credit Information and your Credit Eligibility
Information?
We
will collect, hold, use and disclose Credit Information and Credit Eligibility
Information for a number of primary purposes, including the following:-
•
assessing Applications for Commercial Credit Accounts and Guarantee documents
and whether to accept you or anyone else as a guarantor in relation to credit;
•
to assist you in avoiding any default on your credit obligations;
•
assessing your credit worthiness;
•
notifying a CRB or other credit providers of any defaults by you;
•
comply with any legal or regulatory requirements; and
•
to advise you of services and products from time to time.
We
will also collect, hold, use and disclose Credit Information and Credit
Eligibility Information about you to comply with Australian legislation,
including the Corporations Act 2001, Proceeds of Crime Act 1987 andAnti-Money Laundering and Counter Terrorism Financing Act 2006 and any
amendments to these Acts.
Disclosure
of Credit Information and Credit Eligibility Information
We
may disclose your Credit Information and Credit Eligibility Information to any
of the following third parties:
•
any regulatory, governmental organisation or industry or legal body which
governs the conduct of any part of our business in any jurisdiction or as
required by law or regulation;
•
our related bodies corporate;
•
a third party who is supplying a service to us;
•
any other third party provided that we obtain your prior written consent;
•
your representatives (including your legal adviser, mortgage broker, financial
adviser, executor, administrator, guardian, trustee, or attorney);
•
where permitted by law, debt collection agencies or other lenders; or
•
as otherwise permitted by law.
Overseas
Disclosure
HVG
Graphics may disclose Credit Information and Credit Eligibility Information to
overseas recipients such as our related or associated companies, or to third
parties. This may also occur if our service providers are located overseas. We
will take reasonable steps to protect your privacy if this disclosure occurs.
Storage
and Security of your Credit Information and Credit Eligibility Information
We
will take all reasonable steps to ensure that all Credit Information and Credit
Eligibility Information that we collect, use or disclosed, is stored both
physically and electronically in a secure environment accessed only by
authorised persons. We will take reasonable steps to protect any such
information that we hold from misuse, loss, unauthorised access, modification
or disclosure and to destroy or permanently de-identify personal information if
it is no longer needed for any purposes.
We
maintain sophisticated IT systems to keep such information and data on master
files. We have security measures including restricted access, firewalls and
encryption.
While
HVG Graphics employs antivirus software and encryption technology when
interfacing with its customers, suppliers, contractors and other parties, you
should be aware that there is a residual risk in transmitting any data
electronically. This risk is inherent in any internet dealings.
Credit
Reporting Bodies and your Credit Information
CRBs
are permitted under the Act and the CR Code to use and disclose your Credit
Information. If you apply for commercial credit or offer to act as a guarantor,
we may disclose your Credit Information to, or collect Credit Information about
you from a CRB. This information is used for the purpose of determining your
Eligibility for credit, and we may process the information to assess your
creditworthiness and suitability for credit.
HVG
Graphics deals with the following Corporate Reporting Bodies:
•
Equifax
Level
15, 100 Arthur Street, North Sydney NSW 2060, www.equifax.com.au, 13 83 32; and
•
Illion
Level
7, 479 St Kilda Road, Melbourne VIC 3004, www.illion.com.au, 13 23 33.
Further
information about how these bodies manage credit related personal information
can be found in their privacy policies available on their websites or by
contacting them directly.
How
to Access, Correct or Update your Credit Information and Credit Eligibility
Information
HVG
Graphics will take all reasonable and necessary steps to ensure all information
collected, used or disclosed is accurate, complete and up to date. You have a
right to seek access to your Credit Information and Credit Eligibility
Information and to make correction to that information. Your request must be
reasonable and practicable. Please contact our Privacy Officer on [email protected]should your
details change or if you believe the information we have about you is not
accurate or complete or to make an access or correction request. We will
endeavour to respond to your request within a reasonable time. If you are not satisfied
with our response to your access or correction request, please see our
Complaints Section below, for information on making a complaint.
Complaints
HVG
Graphics takes your complaint seriously. If you believe that we have not dealt
with your Credit Information and Credit Eligibility Information, in a manner
that complies with the Act or the CR Code, please contact the Privacy Officer,
29 Henderson Street, Turrella NSW 2205 or by emailing [email protected].
You
will be required to put your complaint in writing and we will use our best
endeavours to provide a response in writing within a timely manner and to
correct any personal information and notify any other entity required with
updated information.
HVG
Graphics has detailed procedures for dealing with privacy. If you are
dissatisfied with the outcome of your complaint or should we refuse to provide
access to or correction of your information, you may complain to the Office of
the Australian Information Commissioner at www.oaic.gov.au.
Contact
Details
If
you have any questions about this policy, please contact the Privacy Officer by
emailing [email protected] or by mail to the Privacy Officer, 29 Henderson Street,
Turrella NSW 2205.
Changes
to our Credit Reporting Policy
We
may, at our discretion, change our approach to the handling of Credit
Information and will, in such instances, update the Credit Reporting Policy to
reflect these changes. The most up-to-date copy of the Credit Reporting Policy
will be available at www.hvggraphics.com.au and any such updated version shall apply from
the date the updated version is published on our website.
Statement
of Notifiable Matters
This
Statement has been prepared by HVG Graphics to provide you with information on
the Credit Reporting Bodies (CRB’s) that HVG Graphics deals with and to notify
you about the rights you have in relation to your Credit Information.
Credit
Information
Credit
Information and Credit Eligibility information is personal information that may
have a bearing on commercial credit that has been provided to you or that you
have applied for or is about you as a guarantor of commercial credit. Credit
Information about you may include:
1.
identification information; or
2.
consumer credit liability information; or
3.
repayment history information; or
4.
a statement that an information request has been made in relation to you by a
credit provider; or
5.
default information; or
6.
payment information; or
7.
new arrangement information; or
8.
court proceedings information; or
9.
personal insolvency information; or
10.
publicly available information in relation to your creditworthiness.
Credit
Information applies to both consumer credit and commercial credit.
CRB’s
and your Credit Information
CRB’s
are permitted under the Privacy Act 1988 and the Credit Reporting Privacy Code
to use and disclose your Credit Information. If you apply for commercial credit
or offer to act as a guarantor, we may disclose your Credit Information to, or
collect Credit Information about you from, a CRB. This information is used for
the purpose of determining your eligibility for credit, and we may process the
information to assess your creditworthiness and suitability for credit.
CRB’s
that HVG Graphics may disclose Credit Information to
HVG
Graphics will deal with the following CRB’s:
•
Equifax
Level
15, 100 Arthur Street, North Sydney NSW 2060, www.equifax.com.au , 13 83 32; and
•
Illion
Level
7, 479 St Kilda Road, Melbourne VIC 3004, www.illion.com.au , 13 23 33.
Further
information about how these CRB’s manage credit related personal information
can be found in their privacy policies which can be obtained from their
websites or by contacting them directly.
HVG
Graphics’ Credit Reporting Policy and how you may access your Credit
Information
HVG
Graphics’ Credit Reporting Policy contains further information on:
•
how you can access the Credit Information that HVG Graphics holds about you;
•
how you can correct the Credit Information that HVG Graphics holds about you;
•
how you can complain about a breach of regulatory obligations by HVG Graphics;
•
the locations outside of Australia that HVG Graphics may disclose your Credit
Information to.
Your
rights in relation to your Credit Information
CRB’s
offer a service to credit providers wishing to send direct marketing material
about credit services to individuals. This is called "credit
pre-screening". You have the right to request the CRB’s do not use your
Credit Information for this purpose. To opt out of credit pre-screening,
contact the CRB, using the contact details provided above.
You can also ask a CRB not to use or disclose your credit
reporting information for a period if you believe on reasonable grounds that
you have been or are likely to be a victim of fraud.