Telstra Trade-In

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Assurant Services Australia Ltd - Privacy Notice Telstra Device Futures-Consumer and Business Trade-in program-for the Assurant Mobile App.

What Information We Collect

How We Use & Disclose Collected Information

Your Choices

Important Information

 

This Privacy Notice (“Notice”) describes how Assurant Services Australia Pty Ltd ABN 18 613 632 367 (a company incorporated in Australia) referred to as “Assurant”, “We”, “Us”, “Our” throughout this Notice, collects, holds, uses and discloses personal information in compliance with and pursuant to the Privacy Act 1988 (Cth) as amended (the “Act”), the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (the “Act”) and the Australian Privacy Principles. Assurant Services Australia Pty Ltd is an affiliate of Assurant, Inc (NYSE AIZ), a global provider of risk management solutions.

Assurant respects your concerns about privacy. Assurant is a processor and operates this mobile app on behalf of Telstra Limited (“Telstra”), who is the controller of your personal information in the context of providing a consumer device trade-in program (the “Service”). The Service allows users of this mobile app (consumer and business Telstra customers) to enter into a trade-in transaction with Us for the sale to Us of certain eligible devices ("Trade-In Transaction"). In order to provide this Service, Assurant collects and processes your personal information as set forth in this Notice and pursuant to applicable privacy legislation.

We manage your personal information in an open and transparent manner and employ safeguards designed to protect your information, including to:

  1. comply with the Australian Privacy Principles (APPs”).
  2. ensure that we manage your personal information transparently.
  3. collect only the personal information reasonably necessary to provide the Service to you.
  4. tell you how We use your personal information.
  5. let you know if we disclose your personal information to anyone else (including anyone overseas) and if so, under what circumstances this may happen.
  6. employ safeguards designed to protect your personal information.
  7. respond to any request received from you regarding marketing communications.
  8. make sure your personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by Us; and
  9. ensure that, where, appropriate, you may access and correct your personal information that is held by us in the context of the Service.

This Notice describes how We collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use the Service, and how We comply with the Act and the APPs.

You must read this Notice before providing Us with any personal information or using the Service. By providing Us with your personal information and using the Service, you are confirming your agreement to this Notice.

This Privacy Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided associated with each.

If you have any concern about providing information to Us or your information being used in any manner permitted by this Notice and the Terms of Service, you should not  download the mobile app.

1. What information We collect

We collect your personal information in the following ways:

1.1 When you use our Service

When you use the Service; so that We can administer the Service, We ask users to provide Us with their: (i) first name and surname and (ii) contact details, including email address, and phone number. We also collect information about your mobile device (e.g., mobile device type).

2. We process your personal information for the following purposes:

We collect and process your personal information to provide the Service to you and to contact you in relation to the provision of the Service, including.

  1. providing the Service to you.
  2. verifying your identity.
  3. managing your account.
  4. preventing fraud and other criminal activities.
  5. to assist us to operate Our business and to improve Our services and performance, including staff training, risk management, recordkeeping, developing and enhancing the Service.
  6. recognizing you on the Service, improving your experience, increasing security of Our networks and systems, and measuring use and effectiveness of Our Service.
  7. communicating with you and customizing Our support responses.
  8. conducting market research and customer surveys
  9. investigating complaints received from you and others about the Service, or Our products and services and tracking potential issues and trends to better serve you.
  10. making decisions about, and implementing, reorganizations or sales of all or part of Our business.
  11. where you give Us consent.
  12. to enforce Our Terms of Service, protect your safety or the safety of others, investigate fraud, or respond to a government request; and
  13. to comply with our legal obligations.

In addition, please note the following processing purposes:

 

  1. We place cookies and use similar technologies in accordance with Our User Analytics Notice and the information provided to you when those technologies are used.
  2. We obtain geo-location information from your wireless operator, certain third-party service providers, or directly from the device on which the Service is installed.
  3. We send you information about Our products and services, special offers and similar (where your consent is required).
  4. On other occasions where We ask you for consent, We will use the data for the purpose which We explain at that time.
  5. In response to requests by government or law enforcement authorities conducting an investigation.
  6. Responding to complaints where We are under a legal or regulatory obligation to adhere to a complaint’s handling procedure.

2.1 Withdrawing consent

Wherever We rely on your consent, you can always withdraw your consent at any time with effect for the future by contacting customer support by consumer.tradein@assurant.com . You may change your mobile app analytics settings at any time.

2.2 Automated decision making

We do not use automatic decision making or profiling.

3. How We share your personal information

3.1 Sharing information with affiliates

Our affiliates (meaning entities controlled by, controlling or under common control with Assurant, Inc.) may have access to your personal information for the purposes stated in this Notice. For example, your support enquiry may be handled by technical support staff located within or outside Australia (such as in India, Singapore, the United Kingdom, the Philippines, or the United States). Your personal information may be shared with Our affiliates, such as the Assurant group company through which you obtained the Service, for customer relationship management purposes (for example – when you make a complaint).

3.2 We employ third parties to help Us with the Service.

We employ third party companies and individuals to facilitate the Service (for example, customer support, analysis, audit, application, database hosting). These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your personal information is limited to those individuals which are authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorize such third parties to disclose or use it for other purposes.

 

Please see Our List of Service Providers to learn more about the service providers We use and the services that they provide to Us.

3.3 Sharing personal information with other recipients

We may disclose your personal information to public authorities if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.

We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to lawyers and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.

3.4 Data processing outside of your country

Your personal information may be transferred to, and processed by, personnel at our affiliates located in the United States and the United Kingdom (“Overseas Recipients”) in order to support the program and fulfil services pursuant to this Notice. Prior to disclosing your personal information to an Overseas Recipient, We have an obligation under APP 8(1) to ensure that the Overseas Recipient meets at least one of the requirements of APP 8(1) as relates to the privacy laws and obligations that apply to that Overseas Recipient in relation to your personal information, as well as an obligation under APP 8(1) that the requirements of APP 6 Use or disclosure of personal information are met. We take reasonable steps to comply with Our Overseas Disclosure Obligations. By using the Service, you authorise the disclosure of your personal information in the manner and to the third parties and locations described in this Notice.

4. Your Choices and Rights

4.1 Your choices and rights

You have the following rights with regard to the data processed by Us:

  1. the right of access to your personal data stored by us in accordance with APP 12; and
  2. the right to rectify incorrect or complete correct personal data stored by us in accordance with APP 13.

4.2 Additional information

You can exercise any of your rights by contacting Us through the customer support centre at: consumer.tradein@assurant.com .

You can also send Us your request by writing to Us at the address provided in the “Contact Us” section of this Notice. In order to safeguard your personal information from unauthorised access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

In certain situations, and subject to applicable laws, including data protection laws, We may not be able or obliged to comply with all or part of your request. For example, We may not comply with an access request if doing so would reveal personal data about another person or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping. 

 If you have unresolved concerns, you have the right to complain to an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) to have your concerns heard and assessed.

5. Data Retention

We retain personal information you provide while your service contract is active or as needed to provide the Service, and up to 15 years in accordance with applicable law. We may retain your personal information if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Notice and Our Terms of Service. We may retain personal information, for a limited period of time, if requested by law enforcement.

6. Important Information

6.1 Minimum age

We do not knowingly collect personal information from anyone under the age of 18 or such equivalent minimum age for consenting to data processing in the relevant jurisdiction. You must be at least 18 years of age (or ensure a person of 18 years of age or older is present for the duration of a service), or the equivalent minimum age in the relevant jurisdiction, to use the Service.

6.2 Changes to this Privacy Notice

We may update this Notice from time to time. If We make any material changes to this Notice, We will notify you via the relevant website, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. As We may make changes to this Notice, We suggest that you review it each time you access and use the Service. Please review changes carefully. If any changes are made to this Notice, We will revise the Effective Date that is indicated on the Notice.

6.3 Security Procedures

We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.

6.4 Contact Us

If you have questions or comments about this Notice, please contact Us online or by postal mail. 
 
We welcome your questions or comments regarding this Notice. An individual may make a complaint in writing about how their personal information has been dealt with by explaining the nature of the complaint and providing sufficient information to enable Us to provide this to Our Privacy Officer.

 

Alternatively, an individual can contact Our Privacy Officer directly:

 

by phone, 1300 654 611

 

by email, compliance.AU@thewarrantygroup.com ; or

 

by post, PO Box 246 Balwyn VIC 3103.

You also have the right to file a complaint directly with the Office of the Australian Information Commissioner under applicable local data protection law. You may make a complaint with the OAIC.

7. User Analytics Notice

Analyse Mobile App Performance

We collect personal information, on an individual and collective basis, based on your consent, to track and analyze preferences and trends, improve the quality of the mobile app, evaluate possible new features, functionality and services, and improve Our mobile app. We collect information when you use Our mobile app, and use third party analytics tools to evaluate user traffic. For example, We collect information when you view a mobile app screen. Additionally, We collect log in information about devices used to access the mobile app, including user ID, device information (e.g., device manufacturer, OS), and how you use the mobile app (e.g., when you tap the Backup button).

What types of cookies (or analytics) are used with the Mobile App?

We use first party cookies (or analytics) with the Mobile App. The analytics used in our Mobile App can be categorized in the following ways:

Purpose

**These analytics tools collect information about how a user interacts with a mobile app. For instance, which screens visitors go to most often, and if they get error messages. The information collected is used to improve mobile app performance. **

 

Analytics Service Provider

Mixpanel

Purpose

Mixpanel enables Us to perform event-based analytics within the mobile app so effectiveness may be measured. Users may manage their opt in preferences within the mobile app under “Settings” at any time.

This User Analytics Notice should be read in conjunction with this Privacy Notice. If you have any questions or concerns about these Notices or their implementation you may send Us an email at:  consumer.tradein@assurant.com .

Effective Date: 2nd April, 2024

List of Service Providers

This List of Service Providers identifies the third party service providers (who are not considered to be part of the Assurant group companies) We use in connection with the Mobile App and :

Service Provider (Name)

Amazon Web Services

Location (Country)

Australia

Service Provider’s Processing Purposes

Mobile app hosting

 

Service Provider (Name)

Salesforce

Location (Country)

Australia

Service Provider’s Processing Purposes

In-app chat service provider

 

Service Provider (Name)

MixPanel

Location (Country)

United States

Service Provider’s Processing Purposes

Mobile analytics to improve user experience

 

Service Provider (Name)

SendGrid

Location (Country)

United States

Service Provider’s Processing Purposes

Email for mobile app users

 

Service Provider (Name)

LogMeIn

Location (Country)

United States

Service Provider’s Processing Purposes

Remote support via remote device control and screen sharing

 

Service Provider (Name)

Rollbar

Location (Country)

United States

Service Provider’s Processing Purposes

Mobile app crash monitoring.

 

Service Provider (Name)

Intercom

Location (Country)

United States

Service Provider’s Processing Purposes

Sending User Messages

 

Service Provider (Name)

Firebase

Location (Country)

United States

Service Provider’s Processing Purposes

Supports measurement of mobile app performance (for example – when the app crashes)

 

Service Provider (Name)

Fing

Location (Country)

United Kingdom

Service Provider’s Processing Purposes

Scans the users’ Wi-Fi network to attempt to detect & identify connected devices which can be automatically added to the user’s device inventory

 

Service Provider (Name)

Ookla

Location (Country)

United States

Service Provider’s Processing Purposes

Network speed test

 

Service Provider (Name)

IP-API

Location (Country)

Romania

Service Provider’s Processing Purposes

ISP lookup services

 

Service Provider (Name)

Datadog

Location (Country)

United States

Service Provider’s Processing Purposes

Infrastructure performance monitoring

 

Service Provider (Name)

Nice

Location (Country)

Australia

Service Provider’s Processing Purposes

Customer contact management

 

Effective Date: 2nd April, 2024