Last updated 23 December 2021
1. 1BILL GROUP’S COMMITMENT TO PRIVACY
The 1bill Group is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (AU Privacy Act) and in accordance with any applicable local privacy and data protection laws, including:
- the Australian Privacy Act 1988 (Cth) (AU Privacy Act), which include the Australian Privacy Principles; and
- the New Zealand’s Privacy Act 2020 (NZ) (NZ Privacy Act), which include the Information Privacy Principles.
We understand the importance of being open and transparent with you in the way in which we collect, store, store, use and share your personal information. We take protecting your privacy very seriously.
We strongly encourage you read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this document, or about the 1bill Group’s handling of your personal information, please contact our Privacy Officer using the relevant contact details set out in section 17.
2. ABOUT 1BILL GROUP
The 1bill Group provides a wide range of products and services to individuals, including:
- connections services and deal with providers of connection services on your behalf;
- comparison services which compare different utilities plans and may allow you to purchase a utility plan from one of our trusted utilities providers; and
- services to manage and pay bills.
The 1bill Group includes:
- 1Bill Holdings Pty Ltd (ABN 59 642 697 425), which is the parent company of the group;
- 1 Bill Pty Ltd (ABN 69 613 846 058), which owns and operates the 1bill business;
- Residential Connections Pty Ltd (ABN 63 612 925 434), which owns and operates the Resi Connect and Compare & Connect Australia businesses;
- YourPorter Pty. Ltd. (ABN 42 166 347 235) as trustee for the YourPorter Unit Trust (ABN 36 252 576 050), which owns and operates the YourPorter business;
- Compare & Connect NZ Limited (company number 8128197), which owns and operates the Compare & Connect New Zealand business; and
- Fast Connect Limited (company number 1857388), which owns and operates the Fast Connect business,
together with their Australian and New Zealand subsidiaries and affiliates (1bill Group and each a 1bill Group member).
- what is considered personal information;
- what personal information we collect and store;
- how we collect, store, use or share personal information;
- the purposes for which we collect personal information;
- what happens if we are not able to collect personal information;
- how to seek access to and correct your personal information;
- whether we share personal information outside Australia;
- how to make a complaint about the handling of your personal information; and
- how to contact us.
- through our websites (including forms on our websites), including https://www.compareandconnect.com.au/ and https://www.yourporter.com.au/ (Websites);
- through our official social media channel pages which we control (such as our LinkedIn, Twitter and Facebook pages);
- during conversations between you and our representatives;
- to real estate agents (such as through hardcopy forms (e.g. tenancy application forms) and online on their websites); and
- through email and other messages that we send to you.
Other terms and conditions may apply to you such as:
- the privacy terms and conditions contained in our 1bill Group Terms and Conditions (as applicable to you); and
- the collection notices and privacy statements which may be provided to you at the time your personal information is collected.
4. WHAT IS PERSONAL INFORMATION?
In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
5. WHAT PERSONAL INFORMATION DO WE COLLECT AND STORE AND HOW DO WE COLLECT THIS INFORMATION?
The types of personal information that we collect and store about you, and how we collect that information, will depend on the circumstances in which the information is being collected, including whether we collect the information from you as a customer or prospective customer, partner or provider, contractor, supplier job applicant or in some other capacity.
We generally collect personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person.
Below we have described the types of information we generally collect, and the main ways we collect that information.
We may collect the following types of personal information:
- full name;
- mailing or street address;
- previous mailing or previous street addresses;
- email address;
- telephone number;
- age or birth date;
- profession, occupation or job title, and other workplace information (such as your work history, your education and qualifications, your working eligibility rights and details about your referees);
- payment information and records (such as your credit card information);
- a photograph of you or a picture of your image or likeness;
- copies of or details regarding your bills with your current utilities providers;
- your energy or internet usage details
- your electricity meter number, national meter identifier or meter installation reference number;
- details and information, you have provided in relation to conducting a comparison or productions and services with us;
- details of the products and services you have purchased from us or one of our partners or providers, or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
- online and digital services information (including behavioural information), such as your IP address and details about your device, which we may collect through your use of our online services (such as our Websites or social media channels), via our use of online behavioural technologies, such as cookies;
- any additional information relating to you that you provide to us directly through our Websites and social media channels or indirectly through use of our Website or online presence through our representatives or otherwise;
- information you provide to us through our service centre, customer surveys (which are used to measure consumer satisfaction and alignment, and to improve our system, processes and benefits) or visits by our representatives from time to time; and/or
- any information that is required by law.
To provide some of our services, we may need to collect and store proof of identity documents and government-related identifiers, such as drivers licence, passport and/or Medicare details, as well as sensitive information about you (such as medical or certain lifestyle information contained on your bills). This may be necessary, for example, if you wish to switch service providers, or store bills or compare quotes relating to health or certain types of insurance. We will only collect your ID documents and sensitive information with your consent.
If you decide to switch service providers (such as utilities providers) over the phone, we may record your telephone call conversation with us for training and quality assurance purposes.
We collect your personal information directly from you unless it is unreasonable or impractical to do so.
In summary, we may collect your personal information:
- through your access and use of our Websites (including connection and comparison services and forms on our Websites), apps or sending SMS/MMS to us;
- during conversations between you and our representatives (e.g. through our call centre);
- when you complete an application or purchase order (via phone or electronically);
- when you communicate with us during competitions, special events and promotions; and
- when you apply for a position with us.
We may also collect personal information from third parties including:
- other individuals who have provided us with your information;
- third party companies such as credit reporting agencies, law enforcement agencies and other government entities;
- data suppliers (e.g. White Pages and Yellow Pages);
- mailing lists;
- recruitment agencies; and
- our contractors and business partners.
In addition, we may also collect personal information from real estate agents in the following circumstances:
- if they manage a property that you lease or rent or which we otherwise deal with;
- if they are involved in the sale of a property that you purchase or sell;
- where we may need to collect that information under law for the purposes of connecting your water supply;
- when you submit an application or enquiry about our services via the website of a real estate agency referral partner;
- when you submit a rental application to a real estate agent who is managing that property and consent to the disclosure of your personal information to us;
- when you have purchased a property and submit an application to us through the real estate agent who is managing the sale of that property; and
- where you previously provided your information to a real estate agent (including by subscribing to a property alert or while attending an Open For Inspection conducted by that real estate agent) and you have consented to being contacted by the business partners of that real estate agent (which includes us).
We may also receive personal information from another member of the 1bill Group.
6. WHAT HAPPENS IF WE CAN’T COLLECT YOUR PERSONAL INFORMATION
We will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry).
Generally it is not practicable for us to deal with individuals anonymously or pseudonymously on an ongoing basis.
- we may not be able to provide you with the products or services you requested, either to the same standard, or at all;
- we may not be able to provide you with information about products and services that you may want, including information about discounts sales or special promotions; or
we may be unable to tailor the content of our Websites to your preferences and your experience of our websites may not be as enjoyable or useful.
If you have any concerns about personal information we have requested, please let us know.
7. WHY DO WE COLLECT, STORE AND USE PERSONAL INFORMATION?
We collect personal information reasonably necessary to carry out our business, to assess and manage our customer’s needs, and to provide the services.
The purposes for which we usually collect, store and use your personal information depends on the nature of your interaction with us, but may include:
- to provide products and services to you;
- to gather or seek to gather your National Meter Identifier (NMI) or Metering Installation Registration Number (MIRN) (including any associated data) either directly or through third party partners and providers, for the purposes of connecting your electricity or gas to the supply address;
- to provide you with news, information or advice about our existing and new products and services;
- to communicate with you, including but not limited to, by email, mail, SMS or telephone (including in connection with the process of connecting your utilities);
- to assess your eligibility for the products and services that you’re interested in, including any special offers;
- to manage and enhance our products and services;
- to create of service delivery accounts;
- to personalise and customise your experience;
- to provide you with access to protected areas of our Websites;
- to conduct promotions on behalf of selected third parties;
- to verify your identity and manage any enquiries or complaints you have after you’ve used our services;
- to ensure we comply with the requirements from our partners or providers;
- to conduct business processing functions for operation of our Websites or our business (including financial management, reporting and accounting functions);
- for our administrative, marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers, including:
- to improve our understanding of your interests in relation to our services and offers, and to improve our data analytics capability to provide our customers with better services and comparisons);
- to analyse your interactions and use of our online services to understand the effectiveness of our marketing initiatives; and
- develop insights from our interactions with our customers to enhance our Services and the way we deliver them so that we can keep on meeting the needs of our customers;
- to maintain and improve our customer service by monitoring our service for quality control, quality and training purposes;
- to consider job applicants for current and future employment (including for contractors);
- to manage our relationship with our partners and providers, suppliers and other business partners;
- to provide your updated personal information to us, our contractors or external service providers;
- to respond to any enquiries and investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity;
- meet our regulatory and legal obligations (for example, including under the AU Privacy Act and the NZ Privacy Act or under specific contractual obligations where we are required to give access to personal information we store to be audited); and/or
- as otherwise required or permitted by any law (including the AU Privacy Act and NZ Privacy Act).
Naturally we will also use (and potentially share) personal information for a range of administrative, management and operational purposes in ways that you would expect. This includes:
- administering billing and payments and debt recovery;
- planning, managing, monitoring and evaluating our services;
- quality improvement activities;
- statistical analysis and reporting;
- training staff, contractors and other workers;
- risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
- responding to enquiries and complaints regarding our services;
- obtaining advice from consultants and other professional advisers; and
- responding to subpoenas and other legal orders and obligations.
We may also use personal information to create deidentified data (which is no longer personal information). We share this deidentified data we create or otherwise collect with people we do business with such as our advertising and other business partners.
8. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH AND WHY?
We may share your information with third parties:
- for the reasons for which we collect, store and use that information (see section 7);
- for other purposes explained at the time we collect your personal information;
- as specifically authorised by you; or
- where we are otherwise allowed or required to do so under law (including under the AU Privacy Act and NZ Privacy Act).
Some of the third parties we may share your personal information with include the following:
Our partners and providers
We may share your personal information with our partners and providers (which may include service providers or retailers, such as energy providers):
· where you have agreed to receive services from that partner or provider (such as in relation to connecting utilities, or receive insurance or financial services – in the case of insurance and other regulated products and services, you will be contacted directly by the partner or provider and not us); or
· where we may need to share that information under law for the purposes of connecting your water supply.
Our sponsors or promoters
We may share your personal information with our sponsors or promoters of any competition we conduct or promote via our services.
Other members of the 1bill Group
We may share your personal information across the 1bill Group, between 1bill Group members (as appropriate).
· we may share your personal information to another 1bill Group member where that member provides backend IT support and other corporate services to the 1bill Group;
· where it is necessary, for example you have entered into a promotion or competition operated by one 1bill Group member, however, another 1bill Group member is responsible for delivering all or some of the prize; and
· for direct marketing purposes, for example we may share your personal information with another member of the 1bill Group so that the other member of the 1bill Group can serve targeted advertising which may be of interest to you.
Our service providers and advisors
We may share your personal information with a variety of our service providers to assist us with providing, promoting, and managing our products and services. These may include our:
· IT service providers and third party storage providers;
· marketing and communications agencies;
· data analysis organisations; and
· professional advisors and consultants (such as legal, insurance and financial advisors).
We may share your personal information with third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us).
Government and law enforcement agencies
We may share your personal information with regulatory bodies, government agencies and law enforcement bodies to comply with our legislative or regulatory obligations (such as to assist with police investigations).
9. DO WE DISCLOSE YOUR PERSONAL INFORMATION OUTSIDE OF AUSTRALIA?
We generally collect personal information about you in Australia or New Zealand, depending on where you are based. However we may share personal information to our related bodies corporate, partnerships, joint venture entities and external service providers located overseas for some of the purposes listed above in section 8. We only ever share your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with the requirements of the AU Privacy Act and the NZ Privacy Act.
We may share your personal information to entities located outside of the jurisdiction in which we collected your personal information, including the following:
- our related bodies corporate, partnerships and joint venture entities located in Australia and New Zealand;
- our data hosting and Cloud-based IT service providers;
- other external service providers located in the Philippines and U.S.; and
- other third parties operating in jurisdictions including China, India, Indonesia, New Zealand, Hong Kong and the United States where you have authorised us to do so.
There are other circumstances where we may share your personal information to an overseas recipient. For example, where you have provided your consent or we are otherwise permitted to do so under the AU Privacy Act, the NZ Privacy Act or other relevant laws.
10. DIRECT MARKETING MATERIALS
We may use or disclose your personal information for the purpose of sending you direct marketing communications and information about products and services that we consider may be of interest to you (or as otherwise permitted under the AU Privacy Act and NZ Privacy Act), which include products and services offered by a member of the 1bill Group, or by third party providers (which we think may be of interest to you).
These communications may be sent in various forms, including mail, SMS, telephone or email, or via social media channels (including through targeted advertisements on certain websites and social media channels), in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth), the Unsolicited Electronic Messages Act 2007 (NZ) and the Do Not Call Register Act 2006 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
How can you opt-out of receiving direct marketing?
You can let us know at any time if you do not want the personal information we store about you to be used or shared for direct marketing purposes, or you do not wish to be contacted in any of the above ways, by contacting our Privacy Officer using the contact details set out in section 17 or by using the opt-out facilities provided (e.g. an unsubscribe link). In some circumstances we may need to contact you to obtain additional information, to verify your identity or to clarify your request.
We will then ensure that your name is removed from our mailing list.
We do not provide your personal information to other organisations for the purposes of direct marketing unless expressly authorised by you.
Even if you do opt out of receiving marketing communications from you, we may still send you information relevant to the supply of any services arranged by us (and in relation to our ongoing relationship with you).
11. HOW DO WE INTERACT WITH YOU VIA THE INTERNET?
WEBSITE USE AND COOKIES
We may also log IP addresses (the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track user movements, and gather broad demographic information.
We may also collect anonymous data (which is not personal information) relating to your activity on our websites (including IP addresses) via cookies, or we may collect information from you in response to a survey. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services. To the extent this information does not constitute personal information because it does not identify you or anyone else, the Australian Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.
THIRD PARTY LINKS AND WEBSITES
12. HOW DO WE STORE INFORMATION?
We store information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas).
Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
We take all reasonable steps to protect the personal information that we store from misuse, interference and loss, and from unauthorised access, modification and disclosure.
1bill maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems, and encryption of credit card transactions.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
13. HOW LONG WILL WE KEEP YOUR PERSONAL INFOMRATION?
- legal and regulatory requirements and guidance;
- limitation periods that apply in respect of taking legal action;
- our ability to defend ourselves against legal claims and complaints;
- good practice; and
- the operational requirements of our business.
We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.
14. HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You may request access to any personal information we store about you at any time by contacting the Privacy Officer using the contact details set out in section 17.
Where we store information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information.
If you make an access request, we will ask you to verify your identity. We may decline your request to access your personal information in certain circumstances in accordance with the AU Privacy Act or NZ Privacy Act (as applicable). For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
We will take reasonable steps to ensure that the personal information we collect, use or share is accurate, complete and up-to-date. If you believe that personal information we store about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment against the requirements under the AU Privacy Act or NZ Privacy Act (as applicable). If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
We request that you keep your information as current as possible so that we may continue to improve our service to you.
15. HOW YOU CAN COMPLAIN ABOUT A BREACH OF PRIVACY
You may make a complaint about privacy to the Privacy Officer using the contact details set out in section 17.
We have a formal procedure for investigating and dealing with privacy complaints.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking.
We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are based in Australia and you are not satisfied with our response to your complaint, or you consider that we may have breached the AU Privacy Act (including the Australian Privacy Principles), a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
If you are based in New Zealand and you consider that 1bill may have breached the NZ Privacy Act (including the Information Privacy Principles), a complaint may be made to the Office of the Privacy Commissioner. The Office of the Privacy Commissioner can be contacted by telephone on 0800 803 909 or by using the contact details on the website www.privacy.org.nz.
If you are outside of Australia or New Zealand, you may wish to take your complaint up with the local data protection authority in your jurisdiction.
17. HOW CAN YOU CONTACT US?
Please contact our Privacy Officer at:
Privacy Officer – 1bill Group
Phone: 1300 859 258
Fax: (03) 8677 9097
Postal Address: Level 3, 342 Flinders Street, Melbourne VIC 3000.