In this Privacy Policy, ‘Trowbridge’ means Maydark Pty Limited ABN 32 262 737 962

Trowbridge respects the privacy of your personal information. This Privacy Policy sets out how Trowbridge collects, stores, uses and discloses your personal information (including sensitive information) in accordance with the terms below, and applicable Privacy Laws (defined as laws including the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

What personal information Trowbridge collects

“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 (e.g. name and contact details), or data about an individual who can be identified from that data, or from that data and other information to which Trowbridge has or are likely to have access. As its name suggests, “sensitive information” is a more sensitive subset of personal information, which includes bank account/payment, criminal history, health information, religion, racial/ ethnic origin or sexual orientation. If you are an individual who is either based in or a resident of Australia, subject to applicable Privacy Laws, Trowbridge will not process sensitive information about you unless Trowbridge has received your express consent to the processing of this information.

Trowbridge collects certain types of information about you if you provide Trowbridge with your personal information.

The information Trowbridge collects and holds 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.

You may be able to deal with Trowbridge without identifying yourself (i.e. anonymously or by using a pseudonym) in certain circumstances. If you wish to do so, please contact Trowbridge to find out if this is practicable in your circumstances.

How Trowbridge collects your personal information

Trowbridge may collect personal information in a number of ways, including:

• directly from you via our website, telephone, in writing or email; and/or
• indirectly from third parties or publicly from available sources.

Purposes for collecting, holding and using your personal information

Trowbridge collects and holds your personal information for purposes including:

• the Trowbridge Independent Review of Strata Insurance Practices
• any other purpose notified to you at the time your personal information is collected.

Disclosure of your personal information

Other than (a) when required or permitted by law, (b) as specified in this Privacy Policy or (c) where you have provided your express or implied consent, Trowbridge will not disclose your personal information. The purpose for which Trowbridge will disclose your personal information (in the circumstances described) is in the publication of submissions, and in the public report, Independent Review of Strata Insurance Practices.

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

Transfer of personal information overseas

Trowbridge will not transfer your personal information overseas.

Your obligations when you provide personal information of others

You must not provide Trowbridge with personal information (including any sensitive information) of any other individual (including any of your employees or customers) unless you have the express or implied consent of that individual to do so. If you do provide Trowbridge with such information about another individual, before doing so you:

• must tell that individual that you will be providing their information to Trowbridge; and
• warrant that you have that individual’s consent to provide their information to Trowbridge.

If you have not done this, you must tell Trowbridge before you provide any third party information.

Your obligations when Trowbridge provides you with personal information

If Trowbridge gives you, or provides you access to, the personal information of any individual, you must only use it:

• for the purposes agreed to; and
• in compliance with applicable Privacy Laws and this Privacy Policy.

You must also ensure that your agents, advisers, employees and contractors meet the above requirements.

Accuracy, access and correction of your personal information

Trowbridge takes reasonable steps to ensure that your personal information is accurate, complete and up-to-date whenever Trowbridge collects, uses or discloses it. However, Trowbridge also relies on you to advise Trowbridge of any changes to your personal information. All personal information identified as being incorrect is updated in Trowbridge’s database and, where applicable and appropriate, website.

Please contact Trowbridge 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 Trowbridge holds about you is not accurate, complete or up-to-date.

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

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

Security of your personal information

Trowbridge takes reasonable steps to protect any personal information that it holds from misuse, interference and loss, and from unauthorised access, alteration and disclosure.

For example, Trowbridge maintains physical security over its paper and electronic data stores and premises, such as locks and security systems. It also maintains computer and network security. For example, Trowbridge uses passwords to control access to computer systems.

However, data protection measures are never completely secure and, despite the measures Trowbridge has put in place, Trowbridge cannot guarantee the security of your personal information. You must take care to ensure you protect your personal information (for example, by protecting any usernames and passwords). You should notify Trowbridge as soon as possible if you become aware of any security breaches. Trowbridge will where required by applicable Privacy Law, as soon as reasonably possible, notify you of material security breach concerning your personal information.

Links to third party sites

Our website may contain links to other third party websites. Trowbridge does not endorse or otherwise accept responsibility for the content or privacy practices of those websites or any products or services offered on them. Trowbridge recommends that you check the privacy policies of these third party websites to find out how these third parties may collect and deal with your personal information.

Administration of personal information

You may refuse or withdraw your consent for the collection, use and/or disclosure of your personal information in Trowbridge’s possession by giving Trowbridge reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so.

If the purpose for which your personal information is collected is no longer served by the retention of such data, or when the retention is no longer necessary for any other legal or business purpose, Trowbridge will ensure that the hard copy of your personal information will be completely destroyed and electronic personal information as much as possible.

Updates of Privacy Policy

Trowbridge reserves the right to amend our Privacy Policy from time to time to ensure Trowbridge properly manages and processes your personal data. Any amended Privacy Policy will be posted on the Trowbridge website.

How to make a complaint

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

Trowbridge will refer your complaint to its Privacy Officer who will investigate the issue and determine the steps that Trowbridge will undertake to resolve your complaint. Trowbridge will contact you if  any additional information is required from you and will notify you in writing of the outcome of the investigation. Trowbridge will try to resolve any complaint within 14 working days in Sydney. If this is not possible, you will be contacted within that time to let you know how long it should take Trowbridge to resolve your complaint.

If you are not satisfied with the determination, you can contact Trowbridge to discuss your concerns or complain to the relevant local data protection supervisory authority (i.e., your place of habitual residence, place of work or place of alleged infringement). This is the Australian Privacy Commissioner (at www.oaic.gov.au).

How to contact Trowbridge

If you wish to gain access to your personal information, want Trowbridge to correct or update it, have a complaint about a breach of your privacy or any other query relating to the Privacy Policy, please contact the Privacy Officer during business hours in Sydney on:

The Privacy Officer

Email: john@trowbridge.com.au

Post: PO Box 1076 Neutral Bay 2089