Introduction

At Javelin Limited and all its related companies (JAVLN, we, us, our), we take your privacy seriously. We are committed to protecting your privacy and complying with our obligations in respect of personal information under the law of the country in which we provide our service (which we refer to in this policy as the applicable privacy laws). In Australia, these include the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In New Zealand, these include the Privacy Act 2022 including the information privacy principles set out in section 22 of that Act.

We’ve created our privacy policy to ensure that we communicate to you how we collect, use, hold and disclose your personal information. We encourage you to read this policy carefully. It will help you make informed decisions about sharing your personal information with us.
By using our services, providing information to a user of our services or otherwise interacting with us, you consent to us collecting, holding, using and disclosing your personal information as outlined in this policy. If you do not agree with the terms and conditions of this Privacy Policy, please do not access or use our services.

Scope

This policy applies across all websites that we own and operate and all services we provide, including our online and mobile products, and any other apps, services or facilities we may offer (for example, events or training). For the purpose of this policy, these are called our ‘services’.

When we say ‘personal information’ we mean identifiable information or an opinion about you, like your name, email, address, telephone number, bank account details, payment information, support queries, community comments and so on. If you can’t be identified from any information (for example, when information has been aggregated and anonymised) then this policy doesn’t apply to that information.

Types of personal information we collect

The personal information that we collect and hold about you depends on your interaction with us. We collect and hold various types of personal information in connection with your, or your brokers’, use of our services, including:

– your identity and contact details such as your name, gender, address, phone number and email address;
– financial and transaction data including billing, bank account and credit card details and information about payments made via our secure online payment portal;
– information about your purchase history;
– usage data, including information about your use of our services;
– details of enquiries or complaints you may make;
– clickstream data;
– employee numbers;
– technical data including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and
versions, operating system and platform, and other technology on the devices you use to access the services; and
– information necessary or incidental to the provision of our services.

Sensitive information If you are an end consumer, JAVLN will from time to time collect sensitive information, including health information and government identifiers, from your insurance broker or agent when your broker or agent uses our services to manage your insurance policies or claims. Your broker and JAVLN will ensure this information is stored securely within the JAVLN platform. JAVLN will only collect sensitive information, such as health information, with your consent and will ensure that it is only used for the purpose for which it was provided.

How we collect your personal information

JAVLN may collect personal information directly from you when you:

– register to use our services;
– use our services;
– contact JAVLN (including our support team);
– visit our website;
– respond to a job application;
– participate in community forums;
– join us on social media; or
– take part in training or events.

You can always choose not to provide your personal information to JAVLN, but it may mean that we are unable to provide you with our services.

Information collected about your use of services and online

Information will also be collected about your visits to our website and use of our services, and may be collected from various sources such as Google Analytics.

When you access our website, the JAVLN platform or use our services, clickstream data and other related information about visits to our website and use of our services may be collected. In addition to this, usage and performance data through our website using various platform specific tracking technologies available to the website will be collected.

JAVLN may collect personal information from third parties

Where applicable, JAVLN will collect information about you from third parties (including your employer and our third party affiliates or partner companies and from marketing or advertising companies) who may provide us with such information as a part of their relationship with us. We may combine this information with other information that we hold. Third party service providers may be allowed to use technologies including mobile monitoring and tracking technologies in relation to our services. These third party service providers may collect information sent by your browser or mobile device.

We use this information to supplement the personal information we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal information you provide.

If we don’t collect your personal information from third parties, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.

Information you provide about someone else

If you provide JAVLN with personal information about someone else, you must ensure that you are authorised to disclose that information to JAVLN and that, without JAVLN taking any further steps required by applicable data protection or privacy laws, JAVLN may collect, store, use and disclose such information for the purposes described in this policy.

This means that you must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, JAVLN’s identity, and how to contact JAVLN.

Where requested to do so by JAVLN, you must also assist JAVLN with any requests by the individual to access or update the personal information you have collected from them and provided to JAVLN.

JAVLN collects, holds, and uses your personal information for limited purposes

JAVLN collects your personal information so that we can provide you with our services. In doing so, JAVLN may use the personal information we have collected from you for purposes related to our services including to:

– perform a contract with you or an organisation you work for;
– verify your identity;
– administer our services;
– enable access to the JAVLN platform;
– notify you of new or changed services, or otherwise communicate with you about the services;
– carry out marketing or training relating to our services;
– assist with the resolution of technical support issues or other issues relating to our services;
– conduct statistical research;
– make improvements to our products and services;
– develop and commercialise new products and services;
– communicate with you;
– comply with laws and regulations in applicable jurisdictions;
– analyse, aggregate and report: We may use the personal information we collect about you and other users of our websites and services (whether obtained directly or
from third parties) to produce aggregated and anonymised analytics, data sets and reports, which we may share publicly or with third parties; and
– measure the number of visitors to different parts of our website and, for example, to measure the effectiveness of advertising. Information may also be collected via
monitoring or recording calls for training and quality control purposes.

By using our website or our services, you consent to your personal information being collected, held and used in this way and for any other use you authorise. JAVLN will only use your personal information for the purposes described in this policy; or with your express permission, or as required or permitted by applicable law.

Disclosure – How we share your information

We do not sell, license, or rent your personal information to others.

There will be times when we need to share your personal information with third parties. We will only disclose your personal information to:

– other companies in the JAVLN group;
– third party service providers and partners who assist and enable us to use the personal information to facilitate the provision of our services or to offer products and services to you, or in connection with a purpose for which the information was collected. For example, to support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you;
– regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
– an actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; or
to any other party where we have your consent.

Where JAVLN uses your personal information for statistical research, to improve our products and services and/or for the development and commercialisation of new products and services, your information will not be disclosed in a form that identifies you.

International disclosures

Some uses of your personal information may involve the transfer of that information overseas. When we share information, it may be transferred to, and processed in, countries other than the country you live in, to be held and used by us and business partners or where our data hosting provider’s servers are located. These countries may have laws different to your country’s laws. Rest assured, where we disclose personal information to a third party in another country, we put safeguards in place to ensure your personal information remains protected and that overseas recipients comply with the applicable privacy laws.

Security

Security is a priority for us when it comes to your personal information. We’re committed to protecting your personal information and have appropriate technical and organisational measures in place to make sure that happens.

Your personal information is stored on secure servers and all information transferred between you and our services is encrypted. We take all reasonable precautions to protect your personal information from unauthorised or accidental access, disclosure, alteration, loss or destruction and actions which prevent us from accessing your personal information on a temporary or permanent basis (each event being a Privacy Breach).

If your personal information is subject to a Privacy Breach, we will comply with any applicable obligations to notify you and/or the relevant regulator under the applicable privacy laws.

Retention

The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements).

We’ll retain your personal information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our information retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.

What about links to other websites?

Our website may contain links to other websites that are not under our control. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the privacy policy on all third party websites to ensure you are comfortable with third party cookies. We have no responsibility for linked websites, and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

Email, text and telephone communications

By subscribing to emails and/or text communications, or otherwise providing your email address and/or mobile number, you consent to receiving emails, texts and/or other electronic messages (as the case may be) which promote and market our products and services, or the products and services of others, from time to time.

You can unsubscribe from such communications at any time by following the “Unsubscribe” process within the communication.

Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.

You may request access to or correct your personal information

It is your responsibility to ensure that the personal information you provide to us is accurate, complete and up-to-date.

You may request access to the information we hold about you, or request that we update or correct any personal information we hold about you, by setting out your request in writing and sending it to us at privacy@javln.com.

We will review your request as soon as reasonably practicable. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

JAVLN uses cookies

In providing our services and/or operating our website, JAVLN utilises “cookies”. A cookie is a small text file that is stored on your computer for record-keeping purposes. A cookie does not identify you personally or contain any other information about you but it does identify your computer.

We may use a combination of “persistent cookies” (cookies that remain on your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when you close your browser) on the website.

Any such cookie is typically stored on your computer’s hard drive and permits our website or services to recognise you when you return. Our use of cookies helps us to provide you with a better experience during your use of our website or services by allowing us to understand what areas of our website or services are of interest to you.

You can set your browser to notify you when you receive a cookie so that you will have an opportunity to either accept or reject it in each instance. However, you should note that refusing cookies may have a negative impact on the functionality and usability of the website.

If you receive email communications, email open and click tracking may be used including cookies, a single pixel image for tracking and link redirects for tracking clicks, for us to get a better understanding of which email communications are of most interest to you so we can provide you with a better experience by sending relevant and interesting email communications.

We may use “web beacons” (electronic images also known as pixel tags or clear gifs) to recognise a cookie on your computer when you view or act upon a web page, an advertisement that we have placed on a third party web page, or an email or other electronic communication that we have sent.

We may also use Local Shared Objects (“LSO”), sometimes referred to as “Flash” cookies. Use of Local Shared Objects can help deter, detect and prevent fraud and can support our services.

Specific information may be collected such as your operating system version, unique device identifiers, and mobile network information including phone numbers to associate your device with you.

JAVLN has a privacy complaints process

If you wish to complain about how we have handled your personal information, please contact us with full details of your complaint and any supporting documentation by email at privacy@javln.com.

If you are dissatisfied with the way we have handled your complaint, you may complain to the applicable regulator in your country.

In New Zealand this is the Office of the Privacy Commissioner. Complaints can be made here.

In Australia this is the Office of the Information Commissioner. Complaints can be made here.

This policy may be updated from time to time

JAVLN reserves the right to change this policy at any time, and any amended policy is effective upon posting to our website. Your continued use of our services and/or website will be deemed acceptance of any amended policy. We recommend you regularly review the policy when you visit the website. If you do not agree with any aspect of the updated policy, you must immediately cease using our services and/or website.

 

Last updated: January 2023