Privacy Policy

Clover Insurance Pty Ltd (ABN 19 653 550 371, AFSL 538528)

Introduction

Clover Insurance Pty Ltd (ABN 19 653 550 371) (“Clover”, “we”, “us”, or “our”) is an Australian Financial Services Licensee (AFSL No. 538528) regulated by the Australian Security and Investments Commission(“ASIC”).  Clover arranges insurance products and services as an agent to insurers via brokers and intermediaries.  We issue insurance policies and assess claims made on insurance policies we have issued.

Definitions

Personal Information is any ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

Sensitive Information means Personal Information belonging to certain categories as set out in the Privacy Act 1988 (Cth) (“Privacy Act“), such as health information and criminal record information. you and your refers to our customers and prospective customers. It also refers generally to users of our websites as well as a person sharing their information with us, such as a third party or an agent acting on behalf of you.

Protecting your privacy

Clover is committed to protecting the privacy of your Personal Information in accordance with the Privacy Act. This Privacy Policy outlines how we manage your Personal Information and how you can contact us about your Personal Information held by us.

Information we collect

We collect a range of Personal Information to carry out the operations of our business.  This is often so that we can issue an insurance quotation or policy, or process a claim made on an insurance policy we have issued. The Personal Information we collect can include:

• name
• contact details (for example address, telephone number, email address)
• identification details (for example date of birth, driver licence)
• payment details (for example credit card number or bank account details)
• claims history
• occupation
• assets & liabilities
• information relating to the insured risk (for example a property or a vehicle)
• insurance policy terms
• information relating to your interactions, dealings and communications with us or relating to our business, including any contact by telephone, email or online and activity at our websites and physical sites
• interests, preferences and opinions relevant to our business and operations
• information appropriate for us to deal with your claim, inquiry, request, complaint or application
• web and device information (for example IP address, device type, operating system, browser, general location)
• in addition, for staff and job applicants:
  • referee and emergency contact details
  • job applications and related documents
  • candidate and performance assessments
  • employment contracts and terms
  • details of financial and personal interests of staff and family members (for example where relevant to potential conflicts of interest)
  • proof of eligibility to work (for example, Australian citizenship)
  • background checks including criminal record checks
  • educational and training records
  • records relating to salary, employment benefits and leave
  • health information (for example, medical certificates)
  • tax and superannuation details.

We may also collect Sensitive Information such as health information, your criminal record, any medical conditions or your membership with a professional association.

How we collect, use, store and disclose your information

Collect

We collect Personal Information in various way depending on the insurance products and services being provided and administered and our relationship with you. The way we collect information includes:

• directly from you by telephone, mail, email or via our website portal
• from our authorised representatives, distributors, referrers, business partners, affiliates, insurers or related companies
• from our service providers or third parties as described under ‘Disclose’ below (for example for the purposes of assessing a claim)
• from people you have authorised to deal with us or act on your behalf
• from the Australian Financial Complaints Authority or any other external dispute resolution body
• from any other organisation or person where you have consented to them providing your Personal Information to us or consented to us collecting Personal Information from them
• from records of your interactions with us and activity relating to our operations, sites and facilities (for example records from CCTV, site access, telephone recordings and use of IT resources)
• generating new and consolidated information through combining information and creating reports, commentary and analysis.

We may also indirectly collect Personal Information from publicly available third-party sources.  If you are providing us with Personal Information or Sensitive Information belonging to another individual, please ensure that you provide them with this Privacy Policy and obtain their consent. Like many other websites, our website may use ‘cookies’ from time to time. A cookie is a piece of information that allows our system to identify and interact more effectively with your browser. The cookie helps us to maintain the continuity of your browsing session and remember your details and preferences when you return. You can configure your web browser software to reject cookies however some parts of our website may not have full functionality in that case. See www.allaboutcookies.org for instructions on deleting and rejecting cookies for many common browsers. Our website may use Google services such as Google Analytics from time to time. For more about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/. Some personal information is collected pursuant to applicable laws such as the Insurance Contracts Act, Anti-Money Laundering and Counter-Terrorism Financing Act, Personal Property Securities Act, Australian Securities and Investments Commission Act, Autonomous Sanctions Act, Fair Work Act, Superannuation Guarantee (Administration) Act, Income Tax Assessment Acts and other tax laws, Corporations Act, occupational health and safety acts, public health acts and workers compensation acts.

Use

We use, store and disclose your Personal Information for the purposes for which we collected it, as well as for other related or lawful purposes, such as:

• dealing with your enquiries
• considering your application for a product or service
• verifying your identity and Personal Information
• pricing an insurance policy (including deciding what excess to offer and determining if any discounts are available)
• providing a product or service
• processing and investigating claims
• debt collection
• managing complaints
• managing our business operations (including our IT infrastructure and website) and company research and development
• auditing, quality assurance and training
• communicating with customers, the public, stakeholders and the media including through websites, apps and social media
• understanding and responding to the interests, preferences and needs of customers and other stakeholders
• recruiting, training and managing staff
• maintaining and updating our records
• providing, targeting and tailoring marketing communications and advertising on an ongoing basis by telephone, electronic messages (eg. email), online (including websites and mobile apps) and other means, unless you opt out or we are subject to legal restrictions. See the marketing communications for details of how to opt out, or contact us as set out below
• protecting the safety and security or our customers, people, sites and assets
• complying with our legal obligations and protecting and defending our legal rights
• facilitating acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities
• any other purposes we let you know about or as allowed by law

We may not be able to do these things without your Personal Information. For example, we may not be able to communicate with you, provide our services or deal with your enquiry.

Store

We generally hold the Personal Information we collect from you in electronic form in our internal document management systems. We also hold some physical records. Personal Information regarding insurance policies may also be held by the underwriter of your insurance product. We maintain reasonable safeguards to protect the privacy and security of Personal Information. We have reasonable security measures in place to secure Personal Information. These include firewalls, protection against malware and secure logon procedures. We keep Personal Information only for as long as is reasonably necessary for the purposes for which we are permitted to use it and disclose it and to comply with any applicable legal or regulatory reporting or document retention requirements. We will make reasonable efforts to destroy or de-identify your Personal Information after this time in accordance with law and our record management policy and procedures.

Disclose

We share your Personal Information:

• if we are required to by a court order, subpoena or other legal requirements
• if you have consented to us sharing it with a third-party for a particular purpose
• with an insurance broker or agent acting on your behalf
• with relevant and affected parties in connection with a claim or complaint (for example claimants, complainants, respondents, witnesses and their insurers, staff and advisers)
• with our underwriters, reinsurers, insurance intermediaries, insurance reference bureaus, lawyers, accountants, loss adjusters, investigators, agents and service providers (including IT, HR, data, marketing and financial service providers), or with other third parties that assist us in providing our products and services
• with social networks and online platforms and communities where relevant to performing our functions
• clubs, organisations, groups and loyalty programs for which we provide member offers
• for staff and job applicants: with academic institutions, health service providers, professional and trade associations and referees
• with our related entities and joint venture partners
• with external dispute resolution bodies, such as the Australian Financial Complaints Authority
• with government authorities
• for any other purposes which are within reasonable expectations or permitted by law

Some of these parties may be located outside Australia including in India, the United Kingdom, New Zealand, and the United States.

How can I access or update my information?

You can ask us to access or correct your Personal Information that we hold by contacting us at [email protected] or by calling 02 9000 6180. We may need to verify your identity and may ask for your request in writing. Please provide as much detail as you can about the particular information in question, in order to help us locate it. We will give you access to your information in the form you want it where it’s reasonable and practical. Normally your access request will be free of charge. In certain circumstances we may charge you a small fee to cover our costs of providing you access. If we need to do so, we’ll always check with you first. If we decline your request, we will tell you why. Where we decline to make a correction you request, you can ask us to make a note of your requested correction with the information. If you have any other concern, you can contact us or make a complaint by following the instructions below.

How can I contact Clover if I have a question or complaint?

If you have any questions about this Privacy Policy, or a complaint about our handling of your Personal Information, please contact us using the information below: Phone: 02 9000 6180 Email: [email protected] Website:  cloverinsure.com.au/complaints We may need to engage or consult with other parties in order to investigate and deal with any complaints. We will keep records of your complaint and any resolution.

Updates to our Privacy Policy

This Privacy Policy is effective as at 18th July 2022.  From time to time we may need to update this Policy Statement. We will show our updated policy on our website. You should always ensure you have reviewed our current Privacy Policy when you provide us with your Personal Information.