Our privacy policy statement.

"Personal information" includes information or an opinion, whether true or not and whether recorded in a material form or not, about an identified living individual or an individual who is reasonably identifiable, such as name and contact details. It also includes data about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access.

"Sensitive information" is a more sensitive subset of personal information. It includes bank account or payment information, criminal history, health information, religion, racial or ethnic origin and sexual orientation.

If you are an individual based in or a resident of Australia, the European Union or the United Kingdom, subject to applicable Privacy Laws, we will not process sensitive information about you unless we have received your express consent to the processing of this information.

We collect certain types of information about you if you visit our website, authorise your broker or our agent to provide us with your personal information in relation to insurance, give your personal information to our share registrar in relation to your shareholding, or otherwise provide us with your personal information.

The information we collect and hold generally includes your name and contact information, including telephone numbers and email addresses, information relating to the operation of your business, other reference information, and information about other parties that you may conduct, or are interested in conducting, business with.

If you have requested that we act in a broking capacity for insurance-related services, we may also collect and hold other information required to provide such services to you, including details of your previous insurances and sensitive information such as bank account details and criminal records.

You may be able to deal with us without identifying yourself, anonymously or by using a pseudonym, in certain circumstances, such as when making a general inquiry relating to the services we offer. If you wish to do so, please contact us to find out if this is practicable in your circumstances.

If you do not provide us with the information that we need, we or any of our third party service providers may not be able to provide you with the appropriate services.

We may collect personal information in a number of ways.

• Directly from you via our website, telephone, in writing or email.
• Indirectly from third parties, if necessary. For example, your employer, CBN insurance broker members or underwriting agencies may provide us with information about you for the purpose of obtaining our services.
• From referees, insurers, premium funders and other third party service providers, or publicly available sources.
• Automatically when you visit our website, including information collected through cookies or similar technology.

You authorise us to contact such third parties for the purposes of providing you with the services that you have requested.

We also automatically collect certain information when you visit our website, some of which may be capable of personally identifying you. Please see the cookies section below for more details.

We collect and hold your personal information for the purposes of providing our services to you and related purposes. Such purposes include the following.

• Providing CBN insurance broker members, customers, potential customers and others with our services.
• Providing CBN insurance broker members with benefits, including passing customer enquiries to appropriate brokers or providing brokers with professional indemnity insurance.
• Facilitating adequate management of benefits on behalf of CBN insurance broker members.
• Helping develop and identify services that may interest CBN insurance broker members, their customers, potential customers or others.
• Conducting market or customer research.
• Developing, establishing and administering alliances and other arrangements with other organisations in relation to the promotion, administration and use of our services.
• Telling you about other service offerings which we believe may be relevant, if you have requested to receive this.
• Statutory or regulatory reporting.
• Internal or external audit within our group.
• Any other purpose notified to you at the time your personal information is collected.

Legal basis for using your personal information

If you are an individual who is either based in or a resident of the European Union or the United Kingdom, we will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this.

• We need to use your personal information to perform a contract or take steps to enter into a contract with you.
• We need to use your personal information for our legitimate interest as a commercial organisation, such as responding to enquiries submitted via our website.
• We need to use your personal information to comply with a relevant legal or regulatory obligation that we have.
• We have your consent to using your personal information for a particular activity.

We will disclose your personal information to the following parties.

• Our related companies, CBN insurance broker members or third parties who help manage our business and provide our services.
• Third party service providers such as payment system operators, IT suppliers, lawyers, accountants, other advisers and financial institutions.
• Insurers, reinsurers, other insurance intermediaries, insurance reference bureaus and industry bodies.
• Any other entities notified to you at the time of collection.
• A buyer of our assets or shares when we are a seller.
• Courts, law enforcement, regulators and other government agencies where required to comply with applicable laws, regulations, rules or lawful requests.

Other than when required or permitted by law, as specified in this Privacy Policy, or where you have provided your express or implied consent, we will not disclose your personal information.

Nothing in this Privacy Policy prevents us from using and disclosing to others de-personalised aggregated data.

We may disclose your personal information to third party service providers, insurers and related companies where they may process your personal information either on our behalf or otherwise for one or more of the purposes stated in this Privacy Policy.

Some of the third party service providers to whom we disclose personal information are located in countries outside your country of residence, for example, Australia or, in relation to New Zealand, outside New Zealand. These may include:

Unless exempted by applicable Privacy Laws, we will either seek your express or implied consent prior to the transfer of your personal information overseas, or take reasonable steps to ensure the overseas recipient does not breach the Privacy Laws applicable in relation to your personal information.

Transfer of your personal information will only be made for one or more of the purposes specified in this Privacy Policy. Where we take reasonable steps, we will ensure transfers are in accordance with applicable law and carefully managed to protect your privacy rights.

You have a right to contact us for more information about the safeguards we have put in place, including a copy of relevant contractual commitments, to ensure the adequate protection of your personal information when transferred as described above.

When you provide personal information of others

You must not provide us with personal information, including sensitive information, of any other individual, including any of your employees or customers if you are an insurance broker, unless you have the express or implied consent of that individual to do so.

• You must tell that individual that you will be providing their information to us.
• You warrant that you have that individual's consent to provide their information to us.
• If you have not done this, you must tell us before you provide any third party information.

When we provide you with personal information

If we give you, or provide you access to, the personal information of any individual, you must only use it as follows.

• Use it only for the purposes we have agreed to.
• Use it in compliance with applicable Privacy Laws and this Privacy Policy.
• Ensure that your agents, advisers, employees and contractors meet the same requirements.

We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date whenever we collect, use or disclose it. However, we also rely on you to advise us of any changes to your personal information.

All personal information identified as being incorrect is updated in our database and, where applicable and appropriate, on our website. Please contact us using the contact details below as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date.

You can make a request to access your personal information by contacting us using the contact details below. If you make an access request, we will provide access to the personal information we hold about you unless otherwise required or permitted by law. We will notify you of the basis for any denial of access.

We may charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may also charge the reasonable cost of third parties who assist us in complying with the access request.

Additional rights for EU and UK individuals

If you are an individual based in or a resident of the European Union or the United Kingdom, additional rights may be available to you.

If you wish to access any of the rights mentioned above, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information, for example by protecting usernames and passwords. You should notify us as soon as possible if you become aware of any security breaches.

Where required by applicable Privacy Law, we will notify you as soon as reasonably possible of a material security breach concerning your personal information.

Our website may contain links to other third party websites. We do not endorse or otherwise accept responsibility for the content or privacy practices of those websites or any products or services offered on them. We recommend you check the privacy policies of those websites.

In all cases in which cookies are used, the cookie will not collect personal information except with your consent. You can disable cookies in your browser, however our website may not function properly if you do so.

If you follow a link from our website to another website, the owner of that website will have their own privacy and cookie policies. You can adjust your browser settings to determine whether sites can set cookies on your device. To find out more about cookies, including how to see, manage and delete them, visit aboutcookies.org or allaboutcookies.org. You may opt out of being tracked by Google Analytics across all websites by following the guidance outlined on Google's website.

Our processing of your personal data for direct marketing purposes is based on our legitimate interests, but where opt-in consent is required by law, we may seek your consent where applicable. If you no longer wish to receive such information, or you do not want us to disclose your personal information to any other organisation, including CBN insurance broker members or related companies, you can opt out by following the opt-out links in electronic communications, deactivating push notifications or alerts to your mobile phone, or contacting us using the contact details below.

If you withdraw consent for us to use your personal information for your insurance matters, this will affect our ability to provide the products and services that you asked for or have with us. If the purpose for which your personal information is collected is no longer served by retaining such data, or retention is no longer necessary for any other legal or business purpose, we will ensure hard copy personal information is destroyed and electronic personal information is deleted as much as possible.

Updates of Privacy Policy

We reserve the right to amend our Privacy Policy from time to time to ensure we properly manage and process your personal data. Any amended Privacy Policy will be posted on our website.

If you wish to make a complaint about a breach of this Privacy Policy or any breach of applicable privacy laws, you can contact us using the contact details below. You will need to provide sufficient details regarding your complaint together with any supporting evidence and information.

We will refer your complaint to our Privacy Officer who will investigate the issue and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information and will notify you in writing of the outcome of the investigation.

We will try to resolve any complaint within 14 working days in Melbourne. If this is not possible, you will be contacted within that time to let you know how long it should take us to resolve your complaint.

If you are not satisfied with our determination, you can contact us to discuss your concerns or complain to the relevant local data protection supervisory authority, such as the supervisory authority for your place of habitual residence, place of work or place of alleged infringement.

In Australia, this is the Australian Privacy Commissioner at oaic.gov.au.

If you wish to gain access to your personal information, want us to correct or update it, have a complaint about a breach of your privacy or have any other query relating to this Privacy Policy, please contact our Privacy Officer during business hours in Melbourne.

Further information on privacy

Updated: June 2023