Privacy Policy

This Privacy Policy sets out the approach which Frostbland Pty Limited (Frostbland) will take in relation to the treatment of Personal Information. It includes information on how Frostbland collects, uses, discloses and allows access to individuals’ Personal Information.

This policy has been drafted having regard to the National Privacy Principles (the NPP’s) and Frostbland’s obligations as set out in the Privacy Act 1988 as amended by the Privacy Amendment (Private Sector) Act 2000.

Privacy & Confidentiality

As responsible corporate citizens we appreciate the importance of confidentiality.This part of the obligation remains unchanged by this privacy policy.

The privacy policy deals with your additional right to privacy and is independent of our contractual and ethical obligations.

Privacy Policy

For the attention of individuals whose personal information may be collected by Frostbland.

Purpose of the Policy

Frostbland is covered by the Privacy Act and wishes to implement obligations under the Privacy Act and takes all reasonable steps in order to comply with the Act and protect the privacy of the personal information that we hold. This policy sets out how we do so.

The Policy applies to:

The personal information that Frostbland collects.

Frostbland collects the following personal information:

• Your name
• Address
• Contact Details

Why we collect it?
Frostbland collects, uses and discloses the information in accordance with the Collection Statement.

Access to your personal information
Frostbland provides access to the personal information that we hold about you. Access will be provided in accordance with our Access Policy. If you require access to your personal information please contact Customer Service.

Complaints
If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed please contact Customer Service. Complaints will be handled under Frostbland’s Privacy Complaints Policy.

Storage
We will take all reasonable steps to protect the security of the personal information that we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.

Contract
We do not contract out data storage or processing functions.

Why we collect the personal information
We collect the information in order to comply with our legal obligations, to allow us to offer our products and services, to set up trading accounts, to create commercial relationships, to keep consumers informed of product developments and promotions, to process payments and to protect ourselves from possible non payment.

What happens if you choose not to provide the information?
You are not obliged to give us your personal information. However, if you choose not to provide Frostbland with required information we may not be able to provide you with the full range of our products and services.

Collection Statement

Type of personal information collected

• Your name
• Address
• Contact Details

Use and disclosure

Personal information is collected for the purpose of:

• offering you our product
• offering you our services
• setting up trading accounts
• creating commercial relationships
• keeping consumers informed of product developments and promotions
• processing payments
• protecting ourselves from possible non payment
• billing and account management
• business planning

Legal reasons why we collect the personal information
We collect the information in order to comply with our legal obligations (eg credit reporting obligations).

What happens if you choose not to provide the information
You are not obliged to give us your personal information. However, if you choose not to provide Frostbland with required information we may not be able to provide you with the full range of our products and services.

Access
You can gain access to the personal information that Frostbland holds about you. If you wish to do so please refer to our Access Policy or contact Customer Service.

Sources of information
Frostbland will collect the information directly from Frostbland’s customers.

Overseas
Frostbland does not send information overseas.

Access Policy

This policy is directed to those individuals whose personal information is held by Frostbland.

Purpose
The purpose of this Policy is to set out how Frostbland will provide access to your personal information. The Policy is part of our Privacy Policy and our desire to provide for, maintain and give effect to your right to privacy.

Overriding principles
At all times the conduct under this Policy will be governed by the following principles:

• All requests for access will be treated seriously
• All requests will be dealt with promptly
• All requests will be dealt with in a confidential manner
• Your request to access your personal information will not effect your existing obligations or effect the commercial arrangements between you and Frostbland.

Form of Access
Frostbland will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that Frostbland holds about you.

You can make your request in writing by contacting Customer Service.

To obtain access you will have to provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

When will Access be denied?
Access will be denied if:

• the request does not relate to the personal information of the person making the request;
• providing access would pose a serious and imminent threat to life or health of a person;
• providing access would create an unreasonable impact on the privacy of others;
• the request is frivolous and vexatious;
• the request relates to existing or anticipated legal proceedings;
• providing access would prejudice negotiations with the individual making the request;
• access would be unlawful;
• denial of access is authorised or required by law;
• access would prejudice law enforcement activities;
• access discloses a ‘commercially sensitive’ decision making process or information; or
• any other reason that is provided for in the National Privacy Principles (NPPs) set-out under the Privacy Act.

Where possible, Frostbland will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate ‘intermediary’.

Where there is a dispute about the rights or forms of access these will be dealt with in accordance with the Frostbland’s Grievance Policy.

Time
We will take all reasonable steps to provide access within 30 days of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will provide information within 14 days.

Costs and charges
Frostbland can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.

Privacy Complaints

How we handle privacy complaints for individual customers
Frostbland sees the importance of privacy to the organisation, its customers and other stakeholders. As such Frostbland is committed to protecting the privacy of the personal information that we hold. This is part of our organisations:

Legal obligations under the Privacy Act 1988

1. Ethical and business obligations
2. Service to you
3. Frostbland places high priority on effectively dealing with any complaints about privacy that you may have.

Overriding principles

At all times the conduct under this policy will be governed by the following principles:

1. All complaints will be treated seriously
2. All complaints will be dealt with promptly
3. All complaints will be dealt with in a confidential manner
4. The privacy complaint will not effect your existing obligations or the commercial arrangements that exist between this organisation and you.

Who may complain under this policy?
If you have provided us with personal information you have a right to make a complaint, have it investigated and dealt with under this policy.

What is a privacy complaint?
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:

1. How personal information is collected
2. How personal information is stored
3. How this information is used or disclosed
4. How access is provided.

What do I do if I have a complaint about privacy practices?
Frostbland resolves grievances at the local level if possible. If you have a complaint about privacy please contact Customer Service.

All complaints will be logged on a complaints register.

You may complain orally or in writing. Usually your contact with the organisation will be the proper person to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter will then be referred to the next level of management.

Grievance Policy

The goal of this policy is to achieve an effective resolution of your complaint within 30 days or as soon as practicable.

Once the complaint has been made, the point of contact can then resolve the matter in a number of ways:

1. Request further information and investigation: Your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential.

   The complaint may be investigated. The organisation will try to do so within 72 hours or as soon as practicable. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.

2. Discuss options: We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.
3. Refer to CEO: If your complaint is not resolved at the local level, it will be referred to the CEO. The CEO would be provided with the history and may discuss the complaint with the employees, or other parties that are involved.
4. Resolution: You will be informed of the outcome and the reasons for the decision. If this does not resolve the complaint, the matter will be referred to a mutually agreed intermediary.

If after the above steps have been followed you are still dissatisfied with the outcome you may refer the complaint to the Federal Office of the Privacy Commissioner.

Records
The organisation will keep a record of your complaint and the outcome.

Anonymous complaints
Frostbland is unable to deal with anonymous complaints as we are unable to investigate properly and follow-up such complaints.

However, in the event that an anonymous complaint is received Frostbland  will note the issues raised and try and resolve it appropriately. For example, Frostbland may wish to conduct further training or provide assistance in a given area.

Information
For any further information about this policy please contact Customer Service.