Privacy Policy

Stella, its authorised agents and related companies provide services to us or on our behalf collect your personal information to identify you and to provide our products and services to you or as otherwise permitted by law. Without this information, we may not be able to provide you with our products or services.

However, protecting your privacy and the confidentiality of your personal information is important to us. This policy sets out how we do so.

Definitions

In this Privacy Policy:

‘Cookie’ means a message given to a web browser by a web server and which is stored in a text file.

‘Product Issuer’ refers to QBE Insurance (Australia) Limited (ABN 78 003 191 035). QBE is the issuer of your insurance policy and is responsible for the obligations set out in our Product Disclosure Statement and any Supplementary Product Disclosure Statement.

‘Our’, ‘Us’ and ‘We’ refers to Stella Underwriting (ABN 72 633 811 319) and Insurtech Gateway Australia Pty Ltd (ABN 27 633 140 879) who arranges and administers insurance policies on behalf of the Product Issuer.

‘Personal Information’ refers to any information or 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.

‘Related Entity’ has the same meaning as ‘related bodies corporate’ as defined in section 50 of the Corporations Act 2001 (Cth).

‘Sensitive Information’ is Personal Information and relates to particular issues including information about your

• health
• racial or ethnic origin
• political opinions or memberships of political associations
• philosophical or religious beliefs
• sexual preferences or practices
• memberships of professional or trade associations or trade unions or criminal records
• health information
• genetic information that is not otherwise health information
• biometric information that is to be used for the purpose of automated biometric verification or biometric identification
• biometric templates.

‘You’ refers to our customers and prospective customers and users of our web site.

Our Commitment

We are committed to protecting the privacy of your Personal Information in accordance with the Privacy Act 1988 (Cth).

The Privacy Act details the Australian Privacy Principles that set minimum standards for how government agencies and private sector organisations such as Stella may collect, use, disclose, store, provide access to and correct Personal Information.

We are committed to complying with those Australian Privacy Principles.

Our Privacy Policy

Our privacy policy is detailed below and is current from 10 February 2021. We suggest that you read the policy thoroughly before deciding whether to arrange a financial product with us.

Our privacy policy may change from time to time and any change will be immediately posted on our website, so we recommend that you check it periodically. Alternatively, you can contact us on 1300 633 811 or send an email to privacy@stellainsurance.com.au and request a copy of our most recent policy.

Whenever using our website, you should read the privacy policy in conjunction with our Terms of Use.

Personal Information we collect

The Personal Information we collect depends on the products and services you apply for or which we offer. In most cases the details we collect, and store include:

• your full name
• your contact details including your address, phone and fax numbers and email address
• your date of birth and gender
• your account payment details

We may also collect information that is specific to a particular product which may include details of your home and its contents together with your insurance history.
We do not collect ‘Sensitive Information’.

How we collect your Personal Information

We collect your personal information in various ways including via the telephone, our website, hard copy forms or by email.

Whenever you deal with us, we will collect your personal information directly from you unless it is unreasonable or impracticable for us to do so. In some cases we may collect your personal information from another party which may include our authorised representatives, distributors, referrers, agents or related entities, claims service providers, another party involved in a claim, a family member, anyone you have authorised us to deal with us on your behalf and our legal or other advisers.

For example, if you submit an application for insurance to us in joint names or where information is provided to us by a third party (such as our authorised agent) with your consent or where we need to obtain information from a professional expert for the purpose of assessing a claim or providing you with insurance cover or any other services.

If you intend to provide Personal Information to us about another person, we rely on you to make that person aware that you will provide their information to us and the types of third parties we may provide it to, the relevant purposes we and any third parties may use that information and how they can access it. If you have not done and will not do so, you must tell us before you provide the relevant Personal Information.

A number of interactive tools or facilities may be available on our web site. If you use any of those tools or facilities, we generally do not collect your Personal Information unless a particular tool permits you to suspend or save information and recover those details at a later time. In those circumstances your Personal Information may be retained by us but is not processed or used except when it is used for the purpose of online quoting and our subsequent follow up with you.

From time to time we may request Personal Information from you during a competition or customer survey. Participation in those competitions or surveys is completely voluntary and you have the choice whether to disclose the Personal Information we request.

Why we use your Personal Information

We collect Personal Information to provide or offer to you the various products and services we administer or as otherwise as permitted by law.

Those purposes include:

• providing you with any assistance you request from us
• maintaining and administering our products and services (for example processing requests for quotes, applications for insurance, underwriting and pricing policies, issuing you with a policy, managing claims, processing payments)
• providing you with news, information or advice about our existing and new products and services, including for marketing (see the “Marketing” section below)
• to communicate with you, including but not limited to, by email, mail, SMS or telephone
• to manage and enhance our products and services (such as for research and development)
• to personalise and customise your experience
• the collection of general statistical information using common internet technologies such as cookies
• for our administrative, promotional, planning, product/service development, quality control and research purposes, or those of our contractors, external service providers or business partners
• to provide your updated personal information to us, our contractors, external service providers or business partners
• to administer and manage services relating to payment, including to recover any amounts you may owe to us
• to 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 and/or
• as otherwise required or permitted by any law (including the Privacy Act).

If you do not consent to us collecting and using all or some of the Personal Information we request, we may not be able to provide you with our products or services including processing your application for insurance, claim or any payment due to you. It may also prevent us from maintaining or administering your policy or providing information relating to our products or services or those of a third party.

We may use the Personal Information collected through our competitions to determine a prize winner, award prizes or notify prize winners.

We may use the Personal Information we collect through surveys or questionnaires to assess your satisfaction with our products and services and determine how we may better service your needs.

We, and our Related Companies, may also use your Personal Information for research and statistical analysis.

Marketing

We may collect, hold, use and disclose your personal information to send you marketing communications about our product and services and the products and services of our business partners that you may be interested in. We may do this through mail, phone, SMS, social media, email, app notifications and advertising through our apps, websites or third-party websites.

You can contact us at any time to opt-out from receiving direct marketing communications from us by contacting us directly (see “how to contact us”), by following the unsubscribe instructions in the relevant communication or by updating your personal details on your account profile. We do not provide your personal information to other organisations for the purpose of direct marketing unless expressly authorised by you.

If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.

Your personal information will not be shared or disclosed other than as described in this Privacy Policy.

Cookies and the collection of information through our website

We may use a Cookie to collect anonymous traffic data.

Each time the web browser requests a page from the web server the message which is sent back enables the user’s computer address (IP address) to be identified.

We may use the information provided by a Cookie and an IP addresses to analyse trends, administer the site or for research and marketing purposes to help us better serve our clients.

No information which personally identifies you will be collected through a Cookie. You can also set your browser to notify you before you receive a cookie to enable you to either accept it or you can set your browser to turn off all cookies.

Sharing and Disclosing your Personal Information

We never sell, rent, or trade your Personal Information.

We may share your Personal Information with our Related Entities, the Product Issuer or other parties which provide services to us or on our behalf.

We will not share your Personal Information with any unrelated party except under the following circumstances:

• in accordance with this Privacy Policy
• as provided in any Privacy Notice we give you
• where a product or service you apply for is provided or supplied by or through a third party
• where a third party, such as a mailing house, carries out activities on our behalf
• if disclosure is otherwise required in order to provide you with a particular product or service
• to ensure our ability to continue providing products and services
• if disclosure is required for the purpose of conducting a business analysis to improve our products and services
• if disclosure is required by law or requested by a statutory authority including the Australian Financial Complaints Authority, other dispute resolution providers, government body or regulator or any other law enforcement agency
• where a third party has an interest in the product or service we supply, for example a referral agent, distributor or insurance intermediary
• where it is necessary to enable a third party to assist us in providing our services, for example an underwriter, insurance intermediary, reinsurer, insurance reference bureau, credit provider, external IT service provider, external claims data collector and loss adjuster, lawyer, accountant and any other party or person involved in our claims handling processes
• where you have provided your express or implied consent

Your Personal Information may also be disclosed to some of our service providers who are located overseas, and which may change from time to time. You can contact us for more details of those overseas service providers.

In some cases, we may not be able to take reasonable steps to ensure those overseas service providers do not breach the Australian Privacy Act as they may not be subject to the same protections or obligations required by the Act.

By proceeding to acquire our services and products you acknowledge and agree that you will not seek any redress from us under the Privacy Act (to the extent permitted by law) and that you may not be able to seek any redress overseas.

Related and unrelated third parties to whom your Personal Information is disclosed are required to keep the information confidential and only use it for the same purposes we are permitted to use it.

Quality of your Personal Information

We aim to ensure that your Personal Information is accurate, complete, and up to date.

During the course of your relationship with us you are required to inform us of any changes to your Personal Information. You should also contact us at any time to update your Personal Information or to advise us that the information we have recorded is either not accurate or incomplete.

Security of your Personal Information

We are committed to keeping your Personal Information secure and will use all reasonable measures to protect it from loss, misuse, interference or unauthorised access, modification, or disclosure, including:

• physically securing our external and internal premises
• maintaining computer and network security which requires user identifiers and passwords to gain access to our computer systems
• restricting access to your Personal Information by our employees or any person who performs services on our behalf and are authorised by us to access your Personal Information on a ‘need to know’ basis
• entering into confidentiality agreements with our employees, service providers and third parties
• where we provide training of our staff
• only retaining your Personal Information for as long as it is reasonably required by us to service a policy or continue to provide our products and services to you, unless we are required by law to retain it for longer
• taking reasonable steps to destroy or de-identify any Personal Information that we no longer require, or which was unsolicited, and we have identified that we would not have otherwise collected it from you.

Access to and Correction of your Personal Information

You have the right to access the information we hold about you and request corrections, subject to the exceptions detailed in the Australian Privacy Principles. For example, we may refuse access to your personal information where:

• the information may have an unreasonable or adverse impact on the privacy of another person
• the request is frivolous or vexatious
• the information requested relates to existing or anticipated legal proceedings and would not be subject to being disclosed in those proceedings
• the information may prejudice our negotiations relating to a claim
• If we refuse access or to provide access in the manner requested by you, we will let you know why in writing.

If in our opinion providing you access to your Personal Information may reveal information relating to our commercially sensitive decision-making processes, we will provide you with an explanation for our decision but not access to that personal information.

For access to your historic Personal Information or to respond to a detailed request for your Personal Information (for example information that has been archived) we may require you to submit your request in writing and may charge you a fee equal to our reasonable costs of retrieving and supplying a copy of the requested information to you.

In each case we will ask you to verify who you are before any of your Personal Information is provided.

All requests for Personal Information will be handled within a reasonable period of time.

In most cases you may access your Personal Information at no cost by contacting us on 1300 633 811 or by sending an email to privacy@stellainsurance.com.au

How to contact us

If you have any questions, suggestions or complaints about our privacy practices or this privacy policy, please contact us on 1300 633 811 or send an email to help@stellainsurance.com.au. We will endeavor to respond to you as soon as possible.

Depending on the nature of your enquiry we may ask that you submit your request in writing.

If you are not satisfied with our response to your enquiry or complaint you can contact our Privacy Officer and request that our decision be reviewed by a senior staff member, who will then endeavour to resolve your dispute within 30 days.

If you are still not satisfied with our decision we will tell you about the options you may have to refer your complaint to a recognised external dispute resolution scheme of which we are a member or to the Office of the Australian Information Commissioner (OAIC).

You can obtain information on the privacy issues in Australia by visiting the OAIC website at www.oaic.gov.au or by contacting the OAIC directly by email at enquiries@oaic.gov.au or by calling on 1300 363 992.