Holden Financial Services Privacy Policy
Holden Financial Services welcomes you to this website. By viewing the pages of our website
you acknowledge that you have read and have accepted this Privacy Policy and our
Website Terms of Use.
1Purpose
To ensure that the privacy of information relating to website users is maintained.
2.1This policy is made in accordance with the Privacy Act 1993 and
will be subject to:
2.1.1the exceptions set out in the Privacy Act 1993; and
2.1.2any other enactment or rule of law that may override the
provisions of the Privacy Act 1993.
2.2Holden Financial Services is an
organisation that recognises it has obligations to maintain privacy in respect
of personal information held about customer(s).
3.1The Privacy Act 1993 establishes twelve information and privacy
principles that cover the collection, use and disclosure of personal
information, as well as the access to and correction of that personal
information by the individuals concerned.
3.2Personal information under the Privacy Act 1993 means
“information about an identifiable individual”.
3.3A breach of the privacy principles may amount to interference to
privacy, which may be investigated by the Privacy Commissioner.
3.4Complaints not settled by the Privacy Commissioner may be
referred to the Proceedings Commissioner and may fall to be determined by the
Complaints Review Tribunal.
3.5The general principles provided for by the Privacy Act 1993
include:
3.5.1Principle 1 – Purpose: Information must be collected for a
lawful purpose connected with the activity and functions of Holden Financial Services.
3.5.2Principle 2 – Source: Personal information must be collected
directly from the individual concerned.
3.5.3Principle 3 – Collection: When personal information is
collected directly from an individual, the person collecting must ensure that
the individual is aware of a number of matters, including the purpose for which
it is collected, the intended recipient, the fact that the individual has a
right to access to, and a right to request correction of, that information.
3.5.4Principle 4 – Manner of Collection: Personal information may
not be collected unlawfully, or in any way that is unfair in the circumstances
or which intrudes unreasonably on personal privacy.
3.5.5Principle 5 – Storage and Security: Holden Financial Services must ensure
that it has reasonable safeguards for securing the protection of the
information.
3.5.6Principle 6 – Access to Personal Information: Any individual
is entitled to confirmation from
Holden Financial Services as to whether it holds personal information, and access to that
information about them if it is readily retrievable.
3.5.7Principle 7 – Correction: An individual is entitled to request
correction of personal information about them held by Holden Financial Services.
3.5.8Principle 8 – Accuracy: Holden Financial Services cannot use personal
information without taking reasonable steps to ensure that the information is
up-to-date, complete, relevant and not misleading.
3.5.9Principle 9 – Time Limit: Personal information may not be kept
longer than necessary for the purpose for which it may lawfully be used
(maximum time limit – six years).
3.5.10Principle 10 – Limits on Use: Personal information obtained
for one purpose may not be used for another purpose.
3.5.11Principle 11 – Limits on Disclosure: Holden Financial Services must not
disclose personal information to any person or agency, unless one of the
following applies:
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there is a reasonable belief that disclosure is one of the purposes for which
information has been obtained;
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disclosure is for the individual concerned;
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disclosure is necessary to enable the sale of the business;
-
disclosure is necessary to prevent a serious or imminent threat to public
health or safety;
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it has been authorised by the Privacy Commission;
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that the information is publicly available;
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that non-compliance is necessary to avoid prejudice to the maintenance of law;
and
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the information will not be used in a form which identifies the individual
concerned.
3.5.12Principle 12 – Unique Identifier: Holden Financial Services may not
assign a unique identifier to an individual unless this is necessary to enable
it to carry out its functions effectively. A “unique identifier” is a tag that
does not use the individual’s name.
4.1Holden Financial Services has developed the following rules to ensure its
obligations under the Privacy Act 1993 are observed and upheld:
4.1.1Principle 1 – Purpose: Any information collected on this
website will be collected for the purpose of furthering the relationship
between Holden Financial Services and the customer, and enabling the customer to access
web-based financial services.
4.1.2Principle 2 – Source: Holden Financial Services will only collect
personal information on this website from you. You will be identified by your
Holden Financial Services customer number and password if you wish to add personal
information.
4.1.3Principle 3 – Collection: Any information about you will be
collected directly from you, unless otherwise authorised, and we advise that:
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Holden Financial Services is the only intended recipient of this information;
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you have a right to access and correct any information; and
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the purpose of collecting this information is as described above.
4.1.4Principle 4 – Manner of Collection: Information gathered on
this website will be limited to that information necessary to serve the purpose
outlined above, and will be collected in a fair manner.
4.1.5Principle 5 – Storage and Security: Holden Financial Services will take
all practicable steps to safeguard and secure any personal information gathered
by way of this website. You consent to Holden Financial Services contracting with a third
party service provider for the storage and security of your personal
information.
4.1.6Principle 6 – Access to Personal Information: You may contact
us at any time to confirm that we hold personal information about you, and are
entitled to request a copy of that personal information, which will be provided
to you within 20 working days.
4.1.7Principle 7 – Correction: As noted above, you may request that
we correct any personal information held about you.
4.1.8Principle 8 – Accuracy: Holden Financial Services will not use any
personal information about you without taking reasonable steps to ensure that
the information is up-to-date, complete, relevant and not misleading. This
means that we will not act on any information provided without:
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being satisfied that it is accurate; and/or
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seeking verification of that information from you or if necessary and with your
consent, from a third party.
4.1.9Principle 9 – Time Limit: Holden Financial Services will keep personal
information about you for as long as you continue to be a customer of Holden
Financial Services. Thereafter, personal information will be destroyed within six years of
the termination of the relationship.
4.1.10Principle 10 – Limits on Use:
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Personal information obtained by this website will not be used except in
association with any past or future financial services, transactions,
interactions or proposals between Holden Financial Services and the customer.
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Unless you have specifically requested otherwise, Holden Financial Services may use
information provided to this website for the purposes of marketing the services
of Holden Financial Services or its subsidiaries to you.
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For the avoidance of doubt, marketing material accompanying any use of your
personal information which is authorised will not be a breach of the Privacy
Act 1993 and this Privacy Policy.
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For the avoidance of doubt, Holden Financial Services may search information collected from
you on this website for statistical analysis or to target special offers to
you.
4.1.11Principle 11 – Limits on Disclosure: We will not disclose to
any person or agency your personal information. In particular, we will not give
information you have provided on this website to a third party unless:
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it is one of the purposes for which the information has been obtained (for
example to undertake a credit check for the purpose of processing an
application for credit);
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it is disclosure to you or a person authorised by you;
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it is necessary to enable a sale of Holden Financial Services' business;
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it is necessary to prevent a serious or imminent threat to public health or
safety;
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it is authorised by the Privacy Commission;
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the personal information is publicly available;
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it is necessary to avoid prejudice to the maintenance of law; and/or
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the information will not be used in a form which identifies you.
4.1.12Principle 12 – Unique Identifier: We will only assign a
unique identifier to you if this is necessary to enable us to carry out our
functions effectively.
5.1You may at any time request that your personal information not
continue to be used by Holden Financial Services, and you may at any time asked to be
removed from a mailing list.
5.2Our web service collects the domain names, not the email
addresses of visitors. Our web server may require you to place a “cookie”
(small data file) on your computer’s hard drive, in order to track statistical
information about navigation to and throughout certain areas of the site.
5.3From time to time, Holden Financial Services may enable third parties to
advertise on its website. If you follow a link to a third party website from
the Holden Financial Services website, the website privacy policy of that third party
applies, and Holden Financial Services accepts no liability for breaches of privacy once
such a link has been followed.
5.4Further information about Holden Financial Services' privacy policy can be
obtained by telephoning 0800 55 30 30.