1. What is this Privacy Policy?

(a) In this privacy policy, we, us and our means Virgil Assist Pty Ltd (ACN 621 938 850) of Level 5, 11 York Street, Sydney, NSW, Australia, 2000.

(b) This privacy policy explains how we handle personal information we collect from you when you access or use this website, including any content and products or services provided by us to you via this website (the Services).

(c) By accessing or using the Services you consent to our collection and handling of your personal information in accordance with this privacy policy.

(d) We may revise this privacy policy from time to time. We will display a notice on this website indicating when any such revisions have been made, for a period of 30 days after the date of revision.  This privacy policy was last revised on 3 December 2018

2. What is personal information

Throughout this privacy policy, we refer to “personal information”, which means information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not, (for example, this would include a person’s name, address and telephone number).

3. What personal information do we collect?

(a) When you use our Services as an unregistered user and without entering identifying information into our website, we may collect non-identifiable information about you as a visitor to our website, including your IP address, browser type, version and language, operating system, pages viewed while browsing the site, page access times and referring website address.

(b) When you register to use our Services, or enter your personal details into our website (for example, for the purpose of us purchasing third party products available through our website), the information referred to in paragraph (a), and any other information you have entered into our website, may be identified with you, and so become personal information.

(c) We may also collect personal information from you when you us by any method, such as telephone or email.

4. Anonymity

You do not have to provide us with any personal information if you choose not to. You may use our website without registering and without entering identifying information into our website, in which case we will not be able to personally identify you.  However if you wish to remain anonymous you may not register (and you will be unable to obtain the benefits of registration), and you will not be able to use any features of the website which rely on your identity, such as purchasing third party products for sale on our website.

5. Cookies

(a) If you use our Website, some of the personal information referred to in section 3 may be collected through the use of cookies.  Most browsers are set by default to accept cookies.  However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies. 

(b) Please note that rejecting cookies may mean that some or all of the functions on our website will not be available to you.

6. How is your personal information used?

(a) The personal information that we collect is generally used to provide the Services to you, and, if you use access and use of our Services, to track your usage, to evaluate performance of our Services, and to keep track of your account settings.  Personal information collected by us may also be used for the following purposes:

(i) to provide our Services to you;

(ii) to market our products and services to you;

(iii) to provide updates on changes to insurance products that relate to cards you have selected and saved to your profile;

(iv) to respond to your communications with us;

(v) to improve the quality of our Services;

(vi) other purposes which are notified to you at the time the information is collected, or which you consent to; or

(vii) as otherwise required or permitted by law.

(b) You may opt out of receiving marketing communications from us at any time by notifying us accordingly, or using any unsubscribe facility we provide for that purpose.

7. Disclosure of your personal information

(a) We do not sell, rent or trade personal information to or with any other third parties.

(b) We may disclose your personal information to a third party where:

(i) that third party is a group company of ours, in which case that group company will only use and disclose your personal information in accordance with this privacy policy as if a reference in this privacy policy to us included a reference to that group company;

(ii) that third party is a contractor engaged to provide goods or services to us (including goods or services that assist us in providing our Services);

(iii) you have applied for a third party product for sale on this website, in which case we will disclose your relevant personal information to the provider of that third party product.  Please note that we are not responsible for the privacy practices of third party product providers, and you should review their privacy policy before providing us with information that will be disclosed to them;

(iv) you have been notified of the disclosure at the time the information is collected, or you consent to the disclosure; or

(v) as otherwise required or permitted by law.

(3) At this time, the third parties to whom we disclose your personal information are generally located within Australia, however this may change in the future and if it does we will update this privacy policy accordingly.

8. Aggregated data

We may use and disclose to others de-identified and/or aggregated data (including data related to third party products available through our website) for statistical, analytical, market research, quality assurance, service and product improvement and other purposes, provided that no details concerning you (such as your identity) can be reasonably derived from the data.

9. Access and correction of your personal information

(a) We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under the Australian Privacy Principles (APPs).

(b) If you require access to your personal information, please email us at website@virgilassist.com. Before we provide you with access to your personal information we will require some proof of identity.  For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.

(c) If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).

(d) We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.  If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

10. How we hold and secure your personal information

The security of your personal information is important to us.  We take reasonable steps to prevent the personal information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure.  This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.

11. Links to other websites

Our website may contain links to other websites.  When you access a website other than our website, we are not responsible for the privacy practices of that site.  We recommend that you review the privacy policies and terms of use of each website you visit.

12. How to contact us

(a) If you have any queries or complaints with regard our collection, use or management of your personal information, please contact:

A: Virgil Assist Pty Ltd
Level 5, 11 York Street, Sydney, NSW, Australia, 2000

E: website@virgilassist.com

T: +61 435 72555

(b) If you wish to make a complaint about an alleged breach of the Privacy Act, we ask that you send us your complaint in writing to the email address listed above.  We endeavour to respond to complaints within a reasonable period (usually 30 days).  If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at enquiries@oaic.gov.au