Phoenix Health Rewards is brought to you by Phoenix Health Fund Ltd (Phoenix Health) in conjunction with our partner Member Benefits Australia Pty Ltd (MBA (“we”, “us” and “our”) ), the creator of Phoenix Health Rewards.
To meet your expectations about privacy and confidentiality MBA has operational processes and procedures to comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).
If you have any questions not addressed in this policy, please feel free to contact us using the methods at the end of this policy under the heading "How can I contact MBA?".
Our websites contain links to third party websites. We are not responsible for the privacy policies of those other websites. We recommend you review the privacy policies of each site you visit.
2. What personal information do we collect?
MBA collects personal information that you provide directly to MBA as well as information from publicly available sources and third parties. We may ask for a range of personal information to assist us in providing the relevant services. The information we may request includes (but is not limited to) name, address, contact details, Phoenix Health membership number, or any other personal information you provide us which is relevant to your query..
3. Sensitive Information
We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to, race, political or religious beliefs, sexual preferences, criminal convictions and, health information.
The Australian Privacy Principles set out restrictions about the way sensitive information can be used. Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided.
4. Why do we collect personal information?
MBA only collects personal information that is necessary to carry out our primary business activities, including providing you with information and general marketing activity about our products and services, including our motor vehicle advisory and referral services.
5. How do we collect your personal information?
We may collect personal information from you when you use our services, request a motor vehicle advisory and referral service, visit our websites, or otherwise interact with us.
We will endeavour to only collect your personal information directly from you. However, there are circumstances where we will be required to collect your information from third parties. We may collect personal information about you from other parties including third parties who have agreed with us to provide rewards or benefits to members of the program.
6. How do we use your personal information?
MBA may collect, use and disclose your personal information to:
• Efficiently administer and manage the products and services we provide to you;
• Provide you with information about other products and/or services that may be of benefit to you;
- Respond to your queries,
- Facilitate your participation in the benefits program;
- Operate our business;
- Where we believe the law requires or permits us to do so; or
- With your consent.
7. Who do we disclose personal information to?
The types of organisations we may disclose your information to are:
- Our agents, contractors or third-party service providers that provide financial or other services in connection with the provision of our primary business activities;
- Our agents, contractors or third-party service providers that provide financial, legal or other services in connection with the operation of our business;
- Vehicle dealers if we arrange a new vehicle on your behalf;
- Our program partners who provide goods and services for the program.
8. Is MBA likely to disclose personal information to overseas recipients?
We disclose personal information outside Australia and we take reasonable steps to ensure that any overseas recipient handles your personal information in accordance with the Privacy Act. We may disclose your personal information to entities located in the following countries: USA & Japan.
9. Securing Your Data
We take reasonable steps to protect all information which we hold (including your personal information) from misuse, loss, unauthorised access modification or disclosure. However, the security of communications over the Internet cannot be guaranteed, and therefore MBA cannot provide absolute assurance that information will be secure at all times.
MBA has implemented security measures to protect the personal information we hold from unauthorised access.
10. Website Information Collection & Usage Practices
You can access our home page and browse our website without disclosing your personal information. When you access the site or services, we may collect the following information:
- Personal Information: We collect Personal Information when you knowingly provide it, including when you provide feedback or request information.
- Non-Personally Identifiable Information: MBA automatically receives and records certain traffic data on its server logs including your IP address, browser type, browser language, the page you requested, the date and time of this request, your communications and interactions with other site registrants and the page you visited immediately prior to visiting this site. You understand that MBA uses this data to help diagnose problems, analyse trends and develop marketing material communications.
- Cookies: We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Cookies are small text files stored in your browser. You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is being sent. Most browsers accept cookies by default. If you set your browser to not accept cookies, it will not prevent you from accessing the Sites, however it may prevent you from utilising all features of the Sites.
- Remarketing: Our remarketing service is provided by Google and other companies that show our ads on websites across the Internet. When you visit another website that works with Google, or other providers of remarketing advertising, you may see ads for our products you previously viewed although they may have nothing to do with the website you are viewing the ads on.
11. Direct Marketing
From time to time we may use the personal information we collect from you to identify particular MBA products and services which we believe may be of interest to you. Our communication to you may be sent in various forms such as, SMS and email. You consent to us sending you marketing communications. If you indicate a preference for a method of communication, we will endeavour to use that method wherever practical to do so. If you do not wish to receive information about our products and services, you may notify us using the contact details provided below or by using any opt-out facilities provided in the marketing communications.
12. Requests for Access
If we collect your personal information, you have the right to request access to your personal information.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request an amendment of it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it and provide upon request, MBA's reasons for denial of access or a refusal to correct personal information.
13. How can I contact MBA?
Please address all correspondence to:
The Privacy Officer
Member Benefits Australia Pty Ltd
PO Box 269
Chadstone Centre VIC 3148
T 1300 119 493
F 03 8672 6448
14. Privacy Complaint Form
If you believe we have not complied with our obligations concerning your personal information we invite you to contact us and lodge a complaint. Complaints can be lodged via email, which can be sent to firstname.lastname@example.org. You can find information about how the process MBA will use to manage your complaint by going to our Complaints Policy.
If your complaint is not resolved to your satisfaction you can contact the Office of the Privacy Commissioner on 1300 363 992.
This policy represents our policy at February 2022