Privacy Policy

This privacy policy describes how Open Insurance Pty Ltd, which trades as Huddle Insurance, as well as its related companies Open Insurance Technologies Pty Ltd, Open Technology Services AU Pty Ltd and Open Technology Company Pty Ltd manage your personal information, including if you apply to work for us.

Our commitment to protecting your privacy

We believe that the privacy and security of your personal information is very important. That’s why we strive to protect the personal information we collect, and manage it in accordance with this privacy policy and Australian law, including the Privacy Act 1988 (Cth).

What kinds of information do we collect?

Things you do and information you provide

Depending on how you interact with us, we may collect certain personal information belonging to you, either from you, or from someone else, in accordance with this privacy policy or otherwise as permitted by Australian law. The personal information we may collect includes:

• your name, date of birth, sex;
• Information about your financial position;
• your professional qualifications, past employment history, Australian residency status and proof of identity;
• contact details such as your address, telephone number, email and social media handle;
• information relevant to allow us to decide whether we can offer you insurance cover or another product or service, including:
• underwriting information like your insurance claims history and in the case of vehicle insurance, your driving history; and
• financial institution account details, like your payment card or bank account number;
• information obtained as part of the assessment, processing, defence or recovery action related to an insurance claim, for example personal information contained in an interview or police report;
• details of other insurance policies you hold or have held;
• sensitive information such as health information (for example, where such information is relevant to underwriting an insurance policy or processing a claim) or criminal history (for example where such history is relevant to underwriting an insurance policy or processing a claim);
• your location or activity including the IP address of your electronic device (or similar technology), and whether you’ve accessed one or more third party websites; and
• other information which we are permitted to collect under Australian law.

We may also collect relevant personal information from you when you interact with us, for example when you agree to receive insurance offers or marketing communications from us, when you purchase or amend a product or other service through us, or when you make an insurance claim or utilise another service through us. We also collect information about how you use our products or services, such as the types of content you view or engage with, or the frequency and duration of your activities.

If you do not provide us with the personal information that we need, depending on your interaction with us, we may not be able to offer or continue to allow you to hold a product or service with us, or we may not be able to process or settle a claim made against an insurance policy. It is up to you whether you choose to provide the personal information we reasonably request.

Device information and cookie use

We collect information, which may include personal information about you, from or about the electronic devices on which you install or use to access our products or services such as online customer login, depending on the permissions you’ve granted and otherwise in accordance with Australian law. Our collection of information may also be through cookies, which are little text files that can reside in your computer for a time period. We may also use other technologies to track electronic communications we send you.

We may associate the information we collect from your different electronic devices, to help us provide consistent or improved products and services across your devices. We may also use the information we collect to analyse statistical information, enquire into potential security issues, know when you’ve received something we sent and to generally manage our IT systems. Here are some examples of the electronic device information we may collect:

• information about the electronic device’s operating system, hardware version, settings, file and software names and types, battery and signal strength, and its identifiers;
• its location, including specific geographic location, such as may be available through GPS, Bluetooth or WiFi signals; and
• connection information such as the name of your telephone or internet service provider (ISP), browser type, language, time zone, mobile phone number and IP address.

Depending on your computer or internet browser, you may be able to amend your cookie settings including to better alert you to their presence, if you wish. Please note that we may not be able to offer you all of our products, services or online functions if cookies are restricted or switched off on your device. We may also disclose certain information that we collect from cookies or other information technology with third parties, such as Google Analytics.

Information from third-party partners

We collect your personal information directly from you when we can or where it is appropriate for us to do so. However, there may be occasions where we collect your personal information from someone else, including:

• our authorised representatives, distributors, referrers, agents, business partners, affiliates, insurers or related companies;
• our service providers or professional advisors;
• third parties for the purposes of assessing or managing a claim. For example from a witness to an incident related to the claim or from a law enforcement body like the police;
• people you have authorised us to deal with about your policy or claim;
• the Australian Financial Complaints Authority or another external dispute resolution body like a tribunal or court;
• the Insurance Reference Services, by accessing its database, or similar information sharing database if operating at law;
• a referee when we conduct an employment reference check
• a third party insurance or other service provider that will no longer provide you a product or service, if they give us an opportunity to potentially promote or offer you a replacement product or service; and
• any other person or organisation with your consent, or if we are permitted by Australian law to collect it without your consent.

Our communications with you

We may record and securely store telephone conversations, as well as electronic communications such as emails and online chat sessions, to provide a clear record of your communication with us.

How do we take care of your personal information?

We care about the security of your personal information and we take steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

• confidentiality requirements and privacy training of our employees;
• security measures to control access to our systems and premises;
• only giving access to personal information to a person who is verified to be able to receive that information;
• ensuring third parties who collect or require your personal information meet our privacy obligations; and
• electronic security systems, such as firewalls and data encryption on our website.

We only keep your personal information for as long as we require it for our business purposes or otherwise as permitted under Australian law. When we no longer require your personal information, we’ll ensure that it is securely deleted, destroyed or de-identified.

How do we use your personal information?

We will use your personal information for the purposes we collected it, as well as for relevant purposes which are permitted under Australian law. The purposes for which we may use your personal information include:

• handling your enquiries about a product, service or claim;
• considering your application for a product or service;
• pricing an insurance policy (including deciding what excess to offer and ascertaining if any discounts apply);
• providing, including communicating with you about, a product or service you’ve purchased from or through us;
• handling and processing claims, including permitted legal action;
• recovery activity;
• receiving and appropriately responding to complaints;
• managing our business operations (including our information technology infrastructure, websites, and statistical and maintenance purposes) and research and development;
• where permitted by law, communicating with you about our marketing offers, trade promotions or loyalty programs, or those of our business partners, as well as conducting market research. You can contact us at any time to ask us to unsubscribe you from these communications, or unsubscribe by following the link in the relevant communication;
• auditing, quality assurance and training;
• improving our products and services, including data analytics;
• considering your application to work, consult, contract or intern with us;
• considering whether we can offer you a replacement product for service when a third party insurance or other service provider will no longer provide you that product or service, and they give us an opportunity to potentially promote or offer you a replacement product or service; or
• any other purposes communicated to you at the time we collect your personal information or otherwise as permitted under Australian law.

When can we disclose your personal information to others?

We may disclose your personal information for the purposes for which we have collected it or for related permitted purposes or purposes otherwise permitted or compelled under Australian privacy law.

Here are some of the ways we may disclose your personal information:

• to our claim service providers, like car or home repairers and fulfilment providers;
• if we are required to by a court order, subpoena or other legal process;
• you have consented to us sharing it with a third-party for a particular purpose;
• If an insurance broker or other representative, who is acting on your behalf, has asked us for it;
• where it is necessary for a third party to assist us in providing our products and services, for example, the insurer, reinsurers, insurance intermediaries, insurance reference bureaus, lawyers, accountants, loss adjusters and others involved in the provision of products and services or claims handling processes;
• if we need to communicate with a financier of insured property;
• where it is reasonable for us to make enquiries into a claim made against our product or service. This includes making (or responding to) enquiries into such a claim with a law enforcement body like the police;
• if we can no longer offer you a product or service and we disclose relevant personal information to a third party insurance or other service provider that may be able to promote or offer you a replacement product or service; or
• for any other purposes which are within reasonable expectations or otherwise permitted under Australian law.

Some examples of these third parties that we may share your personal information with are:

• our authorised representatives, distributors, referrers, agents, business partners, affiliates;
• our insurers or underwriters;
• other third party insurance or service providers, but only to the extent explained in this Privacy Policy or otherwise permitted by Australian law;
• Insurance Reference Services (a member-based organisation supporting Australian general insurance company members with understanding policyholder claims history);
• our service providers;
• our professional advisers; or
• a witness of the claimed incident or someone else relevant to our reasonable enquiries into a claim, including a police officer.

Third-parties will only be provided with access to your information as is reasonably necessary or otherwise as permitted under Australian law.

Sharing outside of Australia

If your personal information is collected or supplied to an organisation outside of Australia we will ensure it will be held, used or disclosed only in accordance with Australian privacy law, including the Privacy Act 1988 (Cth). However, this might not always be possible in some emergency situations, for example if we need to provide your personal information to an overseas medical services provider, for the purposes of administering a travel insurance claim. Even if we cannot reasonably ensure the receiving person or entity complies with Australian privacy law, we will only disclose your personal information if doing so is necessary and permitted by the Privacy Act 1988.

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We may disclose personal information outside of Australia, including to countries in the European Union such as Ireland and Poland. We may otherwise store your information in cloud or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is held in this way, disclosures may occur in overseas countries. If this occurs, we will ensure that it will be held, used or disclosed only in accordance with the law.

When we update this privacy policy

From time to time we may need to update this privacy policy. We will show our updated policy on our website. Your continued use of our products and services after we update our privacy policy means that you accept the changed content.

How can I access or correct information about me?

We will always give you access to your personal information unless there is a legal reason why we won’t. You can ask us to access or correct your personal information that we hold by contacting us by:

Email:

Huddle Insurance: privacy@huddle.com.au

Open: privacy@beopen.com

Call:

Huddle Insurance: 1300 777 200

Open: 1300 811 224

We will give you access to your information in the form you want it where it’s reasonable and practical. Normally your access request will be free of charge. In certain circumstances we may charge you a small fee to cover our costs of providing you access. If we need to do so, we’ll always check with you first.

If we can’t give you access, we will tell you in writing and tell you the reason why. If you have a concern, you can contact us or make a complaint by following the information in our letter, or see the section below for how to contact us.

If you have a question or complaint about your privacy

If you have a question or complaint about how your personal information has been collected or managed, please let us know. We will have a look into it for you and respond to you. You can contact us by:

Chat:

Huddle Insurance: @ huddle.com.au

Open: @ beopen.com

Email:

Huddle Insurance: privacy@huddle.com.au

Open: help@beopen.com

Phone:

Huddle Insurance: 1300 777 200

Open: 1300 811 224

If we cannot resolve your privacy complaint, we will provide you with information about how you can refer it for external review to the Office of the Australian Information Commissioner (OIAC), or for certain privacy complaints, to the Australian Financial Complaints Authority (AFCA).

The effective date of this privacy policy is 15 December 2022.