This Privacy Notice addresses how Chubb Fire & Security Pty Ltd, Chubb New Zealand, their parent companies, their subsidiaries and affiliates in Australia and New Zealand (together, “Chubb”) may collect, use and process the personal information of individuals, and how individuals can access and correct their personal information or complain about a breach of their privacy.
Chubb interacts with individuals in a variety of ways: end users of our products, employees of our business customers and suppliers, and others in our communities. To enable these interactions, Chubb may need to collect and process personal information. As this Privacy Notice is intended to cover a variety of situations, some of the practices described in this Privacy Notice may not apply to you.
Please review this Privacy Notice periodically for changes and updates.
Specific information about how Chubb collects, uses and discloses credit-related personal information is contained in the section titled ‘Collection, Use and Disclosure of Credit-Related Personal Information’.
This Privacy Notice does not apply to Chubb employees’ personal information, although it may apply to job applicants’ personal information. A separate Employee Privacy Notice is provided to employees.
This Privacy Notice contains the following sections:
- Collection of Personal Information
- Use of Personal Information
- Disclosure of Personal Information
- Cookies and Web Beacons
- Collection, Use and Disclosure of Credit-Related Personal Information
- Storage and Security of Personal Information (Including Credit-Related Personal Information)
- Retention of Personal Information (Including Credit-Related Personal Information)
- What choices do you have about how Chubb uses your personal information?
- Access to and Correction of Personal Information (Including Credit-Related Personal Information)
- Privacy Complaints
- Notification of Changes to this Privacy Notice
- How to Contact Us
Collection of Personal Information
The types of personal information we collect
The personal information Chubb collects will depend on our relationship with you and may include one or more of the following categories:
- Name, including given, family, middle, any suffix (such as Junior or Senior), and salutation (such as Mr. or Ms.)
- Basic identification information, such as date of birth, gender, and/or relationship to end user (for next of kin or emergency contact)
- Emergency contact information
- Work contact information, including telephone numbers, fax number, email address, pager number, mailing address, and work location
- Home address, personal email address and home telephone number, including personal mobile
- Work experience, education and job history, skill categories including language skills, licenses, certifications, authorisation to perform a certain job, or memberships to and participation in trade associations or professional organisations
- Information about an individual’s job, including job title, department, job function, and cost centre
- Information about an individual’s employer, including company name(s), company location(s), company address(es), and country of registration or incorporation
- Name of supervisor and/or assistant
- Training, development, and/or performance review information
- Chubb computer, network, and communications information and logs covering the use of company phones, computers, electronic communications (such as email and electronic calendars), and other information and communication technology
- Username/login identification, passwords, access codes, answers to security questions, and other information required to access and use Chubb applications, networks, systems, products and services
- Information that you store, send, submit, or receive through Chubb’s networks, products and systems, including but not limited to, GPS location, system or device status, activity logs
- Work assignments and work product that may include a connection to you, such as but not limited to documents and files with you identified as the author and tasks assigned to you
- Environmental, health, and safety information
- Agreements, programs, events and activities in which you participate
- Payment and invoice-related information, including government identification numbers and bank account information
- Language and communication preference(s)
- Information collected through a voluntary survey or promotion or through use of a product, such as a security system
- Travel and expense information related to work assignments, including visa information, expense details, and supporting bills
- Information that may be collected as part of an assignment, such as time and attendance data, badge information, photographs, audio, video, biometric information (e.g., fingerprint, iris scan, or voice recognition), or geolocation data used for a particular role or assignment, but such collection will be known, transparent, and consistent with applicable law
- Country of birth, citizenships held (past and present), and permanent residency status, as required by applicable law
- Required screenings, such as a medical examination, drug screening, and/or background check information as required by applicable law
- Information that may be required for international trade compliance regulations to permit your access to certain technologies or other information related to a particular assignment or visit as required by applicable law
- Government-issued identification numbers (in whole or in part), such as a tax identification number, Chubb assigned identification number, social security/insurance number, government-issued driver’s license number, visa, passport, or other document number
- Qualifications to serve as a supplier, service provider or subcontractor, such as conflicts of interest information
- Visitor information, including time, date, and location of visits, information regarding a vehicle for parking purposes, and information necessary to maintain visitor logs and denied party screening
- Listing of nominal gifts that may have been provided or received
- Location information for certain sites that provide location-based services, such as maps, access to printers based on location, or availability of nearby conference rooms, but such collection will be known and transparent
- Warranty-related information, such as the product purchased, and information related to the servicing of a product
- Information provided to facilitate a service, troubleshoot an issue or request assistance, such as product use or problem information
- Information required to process a claim or provide requested benefits or services, which may include health information, government identification numbers, or other information
- Any information that a person chooses to include in a document that is part of a legal proceeding involving Chubb
How we collect personal information
Chubb collects personal information from you when interact with us (including through our websites), such as when you purchase or enquire about one of our products or services, register your product, participate in one of our surveys or apply for a position with us. If you use one of our monitoring services, we will also collect personal information that is automatically transmitted to us from any device that is connected to our monitoring centres.
We may also collect your personal information from third parties such as:
- our customers, suppliers, service providers, consultants, contractors and subcontractors;
- national broadband network retail service providers or telecommunication service providers;
- our related companies;
- individuals or entities who act as your referee, your agent, your attorney or are otherwise expressly or impliedly authorised by you to interact with Chubb about you or on your behalf;
- government entities such as government departments, government agencies and regulators; and
- public sources (including social media).
For certain products and services, you may provide Chubb with information about family members and others connected to you. Before providing that information to Chubb, you must ensure that you have the legal authority to do so.
Use of Personal Information
Chubb will use your personal information in support of a contract with you or to fulfil a legal obligation, and otherwise only for legitimate business interests such as those described below:
- Conducting regular business operations, including designing and developing products, using and managing an Enterprise Resource Planning (ERP) system, sending invoices and collecting payment, providing payment, and providing goods and services to customers, which may include sharing limited personal information with customers, suppliers, service providers, consultants or other business partners
- Providing requested products and services, which may include use of geolocation for certain applications in a known and transparent manner
- Verify your identity
- Assessing your application for employment
- Conducting charitable or community fundraising activities
- Staffing planning, including as that may impact budget and financial planning and reporting
- Responding to situations involving a risk of health or safety, including an emergency
- Managing communications and notices
- Planning and providing health and safety programs and services, including drug screening and health and safety programs
- Reporting and statistical analyses, including global enterprise headcount, demographics, and reporting required by applicable law
- Managing physical security, including access controls and security, facility access and safety, business interruption and disaster preparedness
- Managing, maintaining, and securing information technology (“IT”) systems, such as computer networks, email, internet access, Enterprise Resource Planning (“ERP”) systems, and workflows, including:
- Access controls and security for computer and other systems
- Internet, intranet, email, social media, and other electronic system access
- Virus, intrusion, and insider threat scanning and analysis
- Creation and analysis of logs for security and helpdesk purposes
- Providing helpdesk support and system maintenance activities
- Backing up and recovering data and providing disaster recovery services
- Overseeing location tracking, duration, and other telematics of certain Chubb assets and applications for management of services provided, security, safety, and efficiency
- Ensuring compliance with import, export, and other international trade controls, including managing registrations and authorisations, determining access to controlled technologies and/or commodities, and screening for sanctioned or restricted countries or parties
- Responding to questions or concerns submitted to our Ethics & Compliance program
- Performing audits and compliance reviews to ensure compliance with applicable policy, regulation, and law
- Conducting and managing internal and external investigations, including health and safety, environmental, legal, ethics and compliance, privacy and data security and international trade compliance reviews and any resulting disclosures to government agencies
- Evaluating and reporting conflicts of interest
- Addressing environmental, health, and safety issues, including injury and damage claims
- Prosecuting and defending claims in litigation, arbitration, administrative, or regulatory proceedings, including but not limited to pre-dispute activity, evidence collection, discovery, litigation holds and e-discovery efforts
- Responding to subpoenas, notices of non-party productions, requests for information, freedom of information requests and other similar legal disclosure processes
- Responding to law enforcement and other government inquiries, including but not limited to, assisting law enforcement investigations, lawful surveillance operations and in the execution of lawful warrants
- Protecting intellectual property rights, including but not limited to patent filings
- Business planning, including planning for or executing restructures, mergers, acquisitions and divestitures
- Facilitating investor management activities
- Documenting participation in professional organisations and provision or receipt of business gifts and hospitality
- Administering of marketing, contract, joint ventures, and other business efforts, including without limitation invoice and payment processing, project management, and customer surveys and promotions
- Creating and publishing website or application content most relevant to you
- Designing, selling, producing, and improving products
- Providing customer service and support
- Training and certification of customer, supplier, and vendor personnel
- Conducting subcontractor, supplier and vendor due diligence, including risk assessments
- Developing and managing budget and financial planning and reporting
- Providing benefits and services as requested by either an employee or by a beneficiary or dependent
- Ensuring compliance with applicable laws, regulations, and company policies concerning business gifts and sponsored travel to third parties
- As required or expressly authorised by applicable law or regulation
Disclosure of Personal Information
Chubb may disclose your personal information to third parties to enable us to accomplish the purposes listed above, including:
- our customers, suppliers, service providers, consultants, contractors and subcontractors;
- our related companies;
- emergency services (i.e. police, fire brigade or ambulance);
- individuals or entities who act as your emergency contacts, your next of kin, your referee, your agent, your attorney or are otherwise expressly or impliedly authorised by you to interact with Chubb about you or on your behalf;
- government entities such as government departments, government agencies and regulators;
- law enforcement agencies in non-emergency situations, such as to assist with investigations into criminal activity; and
- a court as part of court proceedings.
Disclosure to recipients outside of Australia and New Zealand
Chubb is part of a global company with locations in many different countries. We may to disclose personal information to overseas recipients, including related bodies corporate and service providers in India, China, Singapore, Israel, France, the Netherlands, the United Kingdom and the United States of America.
We will transfer your personal information consistent with applicable legal requirements and only to the extent necessary for the purposes described above.
Where we disclose personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient complies with the applicable Privacy Principles.
Cookies and other tracking technologies
In addition, Chubb monitors user traffic patterns throughout its Websites according to a user’s domain name, browser type, date and time of access, and pages viewed. Our Web servers collect the domain names but not the email addresses of visitors. This information is collected in order to measure the number of visitors to our Website and to determine which areas of the Website users find useful based upon the amount of traffic to particular areas. Chubb uses this information to enhance users’ experience of the Website and to better prepare future content based on the interests of users.
This Website may also use web beacons. A web beacon is usually a pixel on a website that can be used to track whether a user has visited a particular website to deliver targeted advertising. Web beacons are used in combination with cookies, which means that, if you turn off your browser’s cookies, the web beacons will not be able to track your activity. The web beacon will still count as a website visit, but your unique information will not be recorded. Information collected by web beacons may include IP address information (see below). Web beacon information is also used for:
- Advertising and email auditing, and reporting;
- Site traffic reporting; and
- Unique visitor counts.
An Internet Protocol (IP) address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
Chubb may collect and keep track of IP addresses to, among other things:
- Maintain Website safety and security;
- Restrict access to our Websites to certain users;
- Troubleshoot technical issues; and
- Better understand how Chubb Websites are used.
Chubb (or third parties on behalf of Chubb) may collect information in the form of log files that are recording Website activities and statistics about web users’ habits.
Log files are used for internal purposes only. By using log files, Chubb can constantly improve and customise its Websites and applications.
The entries help us gather, among other things:
- Internal marketing and demographic studies;
- A user’s browser type and operating system;
- Information about a user’s session (such as the URL, the date and time our Website was visited and which pages and for how long were viewed on our Website); and
- Other similar navigational or click-stream data.
Social Network Information
Social network information is any information that you permit a third party social network to share with third party application developers such as Chubb. Social network information includes any information that is part of your profile on a third party social network. Such social network may include, but is not limited to, Twitter, LinkedIn, Facebook, google+.
To find out how your information from a social network may be obtained by us (or other third party application developers), please go on the settings page of the relevant social network. Furthermore, you acknowledge that we may use your personal information to match information with a social network for advertising purposes.
Chubb cannot make assurances about the security of information that you share with third parties, including information you share with social media sites.
Collection, Use and Disclosure of Credit-Related Personal Information
We may provide credit in connection with the supply of our goods and services. For this purpose, we collect credit-related personal information about individuals that apply for credit with us or who provide guarantees in respect of credit provided by us. We also collect credit-related personal information about directors of companies that apply for credit with us or provide guarantees in respect of credit provided by us.
We explain below the types of credit-related personal information we collect and how we use and disclose this information.
The types of credit-related personal information we collect
The kinds of credit-related personal information Chubb may collect about you include:
- your name, personal and work contact details (including post code), date of birth and driver’s licence or licence number;
- information about assets you own and any security held against those assets;
- information about court proceedings to which you are or were a party, and any court orders made against you, that affect your ability to make payments to us;
- any other information on your credit check report, such as credit providers you have commercial or consumer credit with and your payment history with these providers (including any defaults on payments);
- information about your history of payments, including any defaults on payments, for the goods and services we provide to you;
- information about your interactions with our collection agencies;
- any information about you provided by your trade referees;
- where applicable, information about any relevant insolvency event; and
- confirmation that you are not listed as a denied party by the United States government.
How we collect credit-related personal information
Chubb collects credit-related personal information about you when you fill out a credit application form. We may also collect this information from other sources, such as:
- credit reporting bodies;
- any trade referees you provide;
- publicly available sources;
- our contact for the company for which you are a director (when the company applies for credit or notifies us of a change in directorship);
- our collection agencies and external solicitors;
- if relevant, a company’s administrators and liquidators; and
- government bodies, such as the Australian Securities and Investments Commission, and the United States Government.
If you are a guarantor, we may also collect your name and contact information from the credit applicant.
Use of credit-related personal information
If you apply for and/or receive credit from Chubb, Chubb uses your credit-related personal information to assess your application for credit, manage your credit account and manage the collection of overdue payments (if necessary).
If you are a guarantor, Chubb uses your personal information to assess whether to accept you as a guarantor and invoke the guarantee (if necessary).
Disclosure of credit-related personal information
We may disclose your credit-related personal information to credit reporting bodies, our collection agencies and our external solicitors.
We may to disclose credit-related personal information to overseas recipients, including service providers in India.
Where we disclose credit-related personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient complies with the applicable Privacy Principles.
Other information about our handling of your credit-related personal information
The following sections of this Privacy Notice apply to all personal information, including credit-related personal information.
Storage and Security of Personal Information (Including Credit-Related Personal Information)
Chubb stores your personal information in a combination of:
- hard copy files with restricted physical access; and
- electronic files stored on local servers or secure cloud platforms owned by Chubb, its related entities or their contracted service providers.
Chubb takes reasonable security precautions to protect the personally identifiable information that we collect from misuse, interference and loss and from unauthorised access, use, modification and disclosure.
Our service providers are contractually restricted from using or disclosing any personal information we disclose to them except as necessary to perform services on our behalf or to comply with legal requirements.
Retention of Personal Information (Including Credit-Related Personal Information)
Chubb retains personal information for the length of time required to fulfil the purpose for which it was originally collected, and for any additional period as required by applicable law or regulation, court, administrative or arbitration proceedings, or audit requirements.
What choices do you have about how Chubb uses your Personal Information?
Where possible, Chubb will provide you with the opportunity to decide whether or not to provide your personal information. There may be circumstances in which you will not be provided with a choice, such as IT security practices like virus and malware scanning for individuals with access to Chubb networks. Depending on the nature of the personal information and the reason that Chubb may require it, Chubb may be unable to fulfil your request without collecting and processing your personal information.
You will always have a choice about whether Chubb uses your personal information for marketing purposes. If you have provided us with your personal information and would now like to request that it is no longer used for marketing purposes, please contact the businesses from which you are receiving the marketing communications. The communications themselves and the business website will provide you with the contact details.
Access to and Correction of Personal Information (Including Credit-Related Personal Information)
You can request to access and/or correct your personal information by contacting us on the contact details at the end of this Privacy Notice. You may also request to access credit eligibility information about an individual held by us if you are assisting the individual deal with us and are authorised in writing by the individual to make the request.
We may request that you provide evidence to satisfy us as to your identity and, if you are not the individual about whom the personal information relates, your entitlement to access the information.
We may require you to pay our reasonable costs of supplying you with access to your personal information (such as retrieval costs). However, we will not charge you for making an access or correction request or to correct your personal information.
We will deal with your request for access and/or correction as soon as reasonably practicable. If the request relates to credit-related personal information, we will generally provide access or correct the information within 30 days, unless:
- in respect of access requests, unusual circumstances apply; or
- in respect of correction requests, we agree another period with you in writing.
In certain circumstances we will not be able to provide you with access to or correct your personal information. In these circumstances we will provide you with a written notice explaining the reasons for our refusal and stating actions you may take you if you are not satisfied with our response.
If you wish to make a complaint about how we have handled your personal information, please contact us on the contact details set out at the end of this Privacy Notice. We may ask you to put your complaint in writing.
We will investigate and respond to your complaint as soon as is practicable after we receive it.
If your complaint relates to credit-related personal information, within 7 days we will acknowledge your complaint in writing and explain how we will deal with it. Depending on the nature of your complaint and the information to which it relates, we may need to consult with and/or notify particular credit reporting bodies or other credit providers. We will advise you of our decision in relation to your complaint in writing within 30 days of your complaint or such longer period as you agree in writing.
You may also contact:
- if you are in Australia, the Commonwealth Privacy Commissioner. If your complaint relates to our handling of your medical information in NSW or VIC you may also complain to the NSW Privacy Commissioner or the Victorian Health Services Commissioner; or
- if you are in New Zealand, the Privacy Commissioner or an Ombudsman.
Notification of Changes to this Privacy Notice
This Privacy Notice may be updated periodically to reflect changes in our practices and policies. We will post a notice on our websites to notify you of any significant changes to our Privacy Notice and indicate at the top of the Notice when it was most recently updated.
How to Contact Us
If you have any questions about this Privacy Notice or would like to request to access or correct your personal information or make a privacy complaint, please contact us using the following details:
By post in Australia:
Chubb Fire & Security Pty Ltd
Locked Bag 2007
North Ryde BC NSW 1670
By post in New Zealand:
Data Protection Officer
Chubb New Zealand
Private Bag 92207, Victoria St
West Auckland 1142