Privacy Notice
Posted: February 7, 2020
Australia and New Zealand
This Privacy Notice (“Notice”) applies to this website (the “Site”). This Notice does not apply to any
website or service that does not display this Notice. This Notice does not apply to information
collected or received apart from this Site and does not apply to data that does not allow us or third
parties to identify or contact you.
Assurant’s collection and use of your information may be subject to laws and additional notices
which may limit Assurant’s use of your information or provide you rights not described in this Notice.
APEC Participation
The Assurant privacy practices, described in this Policy, comply with the APEC Cross Border Privacy Rules
System. The APEC CBPR system provides a framework for organizations to ensure protection of Personal
Information transferred among participating APEC economies. More information about the APEC
framework can be found here.
Introduction
Founded in 1927, Virginia Surety Company, Inc (An Assurant group company) (ABN 63 080 339 957)
and its affiliate companies, are among the largest underwriters of insured service plans and warranty
products in the world.
The Warranty Group Australasia Pty Ltd (TWG) (ABN 37 005 004 446) acts as Administrator to Virginia
Surety Company, Inc. Both Virginia Surety Company, Inc and The Warranty Group Australasia Pty
Ltd are part of Assurant, Inc. (NYSE AIZ), a global provider of risk management solutions.
This Privacy Policy describes how Virginia Surety Company, Inc. in Australia (including its related
companies which handle personal information collected in Australia) and New Zealand (CN
920655) (including its related companies which handle personal information collected in New
Zealand), referred to as “We”, “Us”, “Our” throughout this policy, collects, holds, uses and
discloses personal information in compliance with the Privacy Act 1988 (Cth) (Australia) and Privacy
Act 1993 (New Zealand). This Policy also serves as notification to individuals of the matters required
to be notified by the Australian Privacy Principles (APPs). An individual who provides personal
information to Us, either directly or through a business partner, distributor or referrer, agent or
service provider who sells or is involved with selling Our insurance and extended warranty products
(“Products”), is given access to this Policy. By providing personal information to Us and having
access to this Policy an individual consents to Us collecting, holding, using and disclosing personal
information in accordance with this Policy.
The personal information We collect
Personal information We collect includes: gender; first, middle and last names; phone and fax
numbers; home and postal addresses; e-mail addresses; date of birth; employment history;
information about individuals from financial institutions; credit card details; bank account details
and Australian Business Numbers. We may also collect sensitive information, a category of personal
information, including medical and health information.
How We collect and store personal information
We collect the personal information of individuals directly from those individuals when selling
Products to those individuals, as well as from Our business partners, distributors or referrers, agents,
or service providers who sell or who are involved with selling the Products. We collect personal
information from other parties such as financial institutions and medical and health professionals in
connection with claims made by individuals. We also collect personal information directly from an
individual when the individual makes an inquiry or claim about a Product.
Personal information received by Us is held electronically on Our information technology systems,
which are password and access-level protected and may only be accessed by Our authorised
employees and contractors who require access in connection with the purposes described in this
Policy. Some personal information is held in hard copy such as files created when a claim or
complaint is made, which are accessible to Our claims and complaint-handling employees, their
managers and the organisation which is contracted by Us to store and secure that information. Other
hard copy personal information may be held for internal purposes and administration of Our
business.
Data Analytics.
Virginia Surety Company and its partners use cookies or similar technologies to analyze trends,
administer the website, track users’ movements around the website, and to gather demographic
information about our user base as a whole. You can control the use of cookies at the individual
browser level, but if you choose to disable cookies, it may limit your use of certain features or
functions on our website or service.
If information or consent is not provided
Without all of the required personal information being provided or consent being given, We may not
be able to provide the Products, and may not be able to administer claims or handle inquiries in
connection with those Products.
Purposes
Personal information will be collected, held, used and disclosed for the purposes of:
For users in New Zealand. The information collected is held by the Administrator and used by the
Administrator, the Insurer and their contractors and agents to administer Your Policy. If You do not
provide this information, We may decline Your application to take out a warranty or insurance
policy. You have the right to access, and request correction of this information, subject to the
provisions of the Privacy Act 1993.
We will hold personal information for as long as necessary in order to meet the purposes described
in this Policy and as required by law. For example, personal information in connection with Products
will be held for the life of the Product which includes the period when claims may be notified or
made after the Product expires.
We will not disclose an individual’s personal information for any other purpose unless the individual
has provided Us with consent. There may be other purposes where We may disclose an individual’s
personal information other than those mentioned above. We will only do this if it would be
reasonably expected of Us to do so in the circumstances.
Disclosure of personal information (including overseas recipients)
We may disclose personal information to Our business partners who provide services for us and third
party service network providers including, repairers, assessors and loss adjusters to perform
activities in connection with the purposes described in this Policy. As Virginia Surety Company, Inc.
is a member of a global group of companies, then each member of the group may share and access
personal information in connection with the purposes described in this Policy. An individual may not
be informed of each occasion personal information is shared or accessed by a member of Our group
companies. Some of the organisations to which We will disclose personal information are located
outside Australia. They are located in the U.K, U.S.A, South Africa, China, Singapore, Japan, India,
South Korea, the Philippines and New Zealand. By purchasing a Product and consenting to Us
managing personal information in accordance with this Policy, We will take reasonable steps to
ensure that overseas recipients do not breach the APPs in relation to the information.
Regulators. We may share information with regulators, including as necessary to comply with
regulatory oversight of our businesses.
Business Transfer. We may share information we have collected from you in connection with the
sale or merger of our business or the transfer of assets, you will be notified via email and/or a
prominent notice on our website, of any change in ownership, uses of your personal information,
and choices you may have regarding your personal information.
Protection of Ourselves and Others. We may use and share the information we gather to protect our
own and others’ rights and property, including protection of our affiliates, customers and members
of the public. We may use and share the information we gather to comply with applicable law, legal
process (such as in a response to a subpoena or court order), legal advice and for preventing fraud,
theft, and injury to you, us or others.
How Does Assurant Address Information Security?
The security of your personal information is important to us. We follow generally accepted
standards to protect the personal information submitted to us, both during transmission and once
it is received. If you have any questions about the security of your personal information, you can
contact us at dataprotectionofficer.apac@assurant.com.
Access to personal information
An individual may see and have a copy of their personal information that We hold. If an individual
is able to establish that their personal information is not accurate, complete and up-to-date, then
on request We will take reasonable steps to correct it. If We are unable to agree whether personal
information is accurate, complete or up-to-date, then an individual may ask Us to place with the
information a statement claiming that particular information is not accurate, complete or up-todate.
An individual who seeks to exercise their rights of access, deletion, and correction must
contact Us in writing with attention to Our Privacy Officer. If we decline an individual’s access
request or do not amend the personal information, We will provide Our reasons together with details
about how the individual can access Our complaints process. We will respond to your request within
a reasonable timeframe.
How Does Assurant Provide Updates to this Notice?
We may update this Privacy Policy to reflect changes to our information practices. If we make any
material changes we will notify you by email (sent to the e-mail address specified in your account)
or by means of a notice on this website prior to the change becoming effective. We encourage you
to periodically review this page for the latest information on our privacy practices.
Complaints
An individual may make a complaint in writing about how their personal information has been dealt
with by explaining the nature of the complaint and providing sufficient information to enable Us to
provide this to Our Privacy Officer.
Alternatively, an individual can contact Our Privacy Officer directly:
If We have not responded to the complaint within 30 days or if the individual is not satisfied with
our response, then the individual can refer the matter to the Office of the Australian Information
Commissioner (OAIC).
An individual may make a complaint with the OAIC:
For New Zealand:
If You have any questions about the information collected about You, please contact the
Administrator at customerfeedback@thewarrantygroup.com.
If you would like to make a complaint about the way your information has been handled, please
contact our Privacy Officer directly:
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily,
please contact our U.S.-based third party dispute resolution provider (free of charge) at
https://feedback-form.truste.com/watchdog/request.
“Administrator” means The Warranty Group Australasia Pty Ltd (CN 2367681)
“Insurer” means Virginia Surety Company, Inc in New Zealand (CN 920655)
Acknowledgement and Consent
By purchasing a Product, the individual consents to the collection, handling, use and disclosure of
personal information by Us in accordance with this Policy