Privacy Policy

Flip Insurance Pty Ltd (ABN 71 648 680 960) (Flip or We) is wholly owned by HCF Life Insurance Company Pty Ltd (HCF Life) which is in turn wholly owned by The Hospitals Contribution Fund of Australia Limited (HCF). Flip is bound by the Privacy Act 1988 (Cth) (Privacy Act) and holds personal information it collects in accordance with the Australian Privacy Principles contained in the Privacy Act and other relevant State legislation dealing with privacy and health records. We also comply with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth), as amended from time to time.

What Sort Of Personal Information Do We Usually Collect?

Personal information is broadly, any information about or relating to you where you are identified by us, or can be identified. Sensitive information is a special subset of personal information which includes your health information. For the purposes of this Privacy Policy, any references to “personal information” includes “sensitive information”.

The personal information that we (or third parties on our behalf) may collect about you includes:

1. Information relevant to life cover and other related products and services such as your:
   - name, address, email address, mobile number, state of residence and Australian residency status
   - gender
   - credit card, bank account details or other payment details
   - sensitive information, for example your health records and health services provided to you.‍
2. In respect of providers to Flip, information such as your:
   - name, practice and/or business name, practice, postal and email addresses, telephone and/or mobile number
   - government related identifiers such as your Australian Company Number and/or Australian Business Number and Medicare provider number

How Do We Collect Your Personal Information?

We may collect the personal information from you (or persons authorised by you):

• by email, mobile applications, including digital watches and fitness tracking devices, our website or other internet services and applications (e.g. Facebook, Twitter, Google and Apple)
• by phone for verification and training purposes
• from forms, claims and other correspondence
• while you are using services provided by Flip.

Sometimes we may need to collect your personal information from third parties such as research companies that collect feedback from policyholders on behalf of us.

We (or a third party on our behalf) will also collect your personal information from third parties, including where you authorise them to facilitate:

• creating a new account with Flip and for subsequent sign in and authentication purposes (e.g. when you use your account with a third party like Apple or Google to sign in to the Flip website); and
• making payment to Flip using a third party payment platform (such as Apple or Google Pay through Stripe).

What Happens If You Do Not Give Us This Information Or Do Not Wish Us To Use Or Disclose It For A Purpose?

It is your right not to give us any information and not to identify yourself to us (interact anonymously or using a pseudonym) or to tell us that you do not wish us to use or disclose your personal information for a particular purpose or in a particular way. However, if you choose not to give us the personal information we request, or do not identify yourself to us or ask us not to use or disclose your information for a particular purpose, we may not be able to:

1. Consider your application for insurance.
2. Administer your cover.
3. Enter into a contract to provide you with our product or service or provide you with relevant services.
4. Manage or pay any claims you make under your cover.
5. Provide you with relevant insurance services.
6. Enable specific personalised features for your cover.

How Do We Use Your Personal Information?

We use your personal information we collect, under our contract with you, to provide products and services to you (some of which may be provided by third party providers on our behalf) including insurance services, managing our relationship with you and to administer, process and audit claims.

If you sign up to our newsletter, we will use the personal information that you provide to send you information about Flip.

We may also run competitions and other promotions from time to time. If you choose to participate, we will use the personal information that you provide on the competition entry form (or other relevant source) to administer the competition and (with your consent) provide you with information about Flip.

We may also use your personal information for related purposes which you would reasonably expect for our legitimate interest in complying with applicable laws, assessing your insurance, health and related lifestyle needs, developing products and services that may better serve those needs, assessing your possible interest in any such products or services and telling you about these, improving our service delivery, asking for your feedback and opinions about services, benefits or product offerings, resolving any legal and/or commercial complaints or issues and performing other functions and activities relating to the Flip business.

Requests To Stop Direct Marketing From Us

We may communicate with you by telephone, electronically or mail, about our current and new products and services, including participation in any programs we develop.

You may ask us at anytime to stop sending you direct marketing information or being contacted by or on our behalf, in a particular way or at all. You can do this by logging into the Flip Website (www.getflip.com.au) and changing your marketing settings or by emailing us at help@getflip.com.au.

Do We Disclose Information To Third Parties?

We may share or disclose (or require you to share or disclose) your personal information, in accordance with the purposes described above under the heading How do we use your personal information?, to third parties or individuals, some of which may be located overseas in certain circumstances, including:

1. Organisations that deliver services on our behalf or to us such as HCF, HCF Life and other third parties that we contract to assess or process claims, administer programs or services that we develop for the benefit of policyholders, research companies contracted by us (to ask your opinions on improving Flip’s service, benefits or product offerings), third party vendors who placed targeted online ads for us on their sites, competition partners (with your consent) and mailing houses.
2. Other service providers, for example, our advisors for the purposes of obtaining legal advice or our technology and payment providers.
3. Fraud prevention agencies, government bodies and regulators including law enforcement bodies such as the Police, professional associations and industry bodies.
4. Where disclosure is otherwise authorised or required by or under applicable laws or any other legal or regulatory process.

Flip uses Stripe as its payment provider. By providing your payment details, you authorise and consent to Stripe collecting and using this information on behalf of Flip in accordance with Stripe's Terms and Privacy Policy.
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Any third parties to whom we disclose or permit access to your personal information, in the course of providing services on our behalf, will be subject to strict contractual restrictions to ensure that they protect personal information and keep it confidential, consistent with relevant privacy and data protection laws.

Overseas Disclosures

Some organisations to which we disclose personal information are located in the USA, New Zealand, European Economic Area and Japan. We will not disclose your personal information to an overseas recipient without taking such steps as are reasonable in the circumstances to ensure that the overseas recipient will not breach the Australian Privacy Principles set out in the Privacy Act.

How Is Information From Our Websites And Our Mobile Applications Collected And Used?

We collect information when you (or persons authorised by you):

• complete an online form
• give us your email address
• access and use any of our services through our website and/or mobile app

We collect data from our website or mobile application to help us understand which are the most popular items and when the peak usage times are, along with other information that helps us improve the content and make the navigation easier. Some of this information may be used to develop new services or enhance existing services provided to Flip policyholders.

When you visit our website, it will send a cookie to your computer or other device. This is a small piece of information stored on your hard drive which tells us that your computer has accessed our website. The cookie by itself will not be able to identify you. If you do not want to use cookies, you can set your browser to reject them.

Data from mobile applications and other devices may include information that you supply to the application as well as location information provided by the device location services, where you have given permission for the application to access these location services.

Flip uses remarketing and web based analytics to advertise online. Third-party vendors show Flip advertisements on websites across the Internet. This includes the use of Google Analytics (see Google Privacy Policy for more details) and Facebook Pixels (see Meta Privacy Policy for more details). Flip and third-party vendors use first-party cookies and third-party cookies together to inform, optimise, and serve ads based on someone’s past visits to the Flip website.

Storage And Security Of Your Personal Information

We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and unauthorised access, modification or disclosure and to destroy or de-identify personal information we no longer need, wherever possible.

We will keep your personal information for as long as we maintain our relationship with you or otherwise as required for our business operations or by applicable laws, including to enforce our rights, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes.

Your Privacy Rights

How To Access And Correct Your Personal Information

We take reasonable steps to ensure that the information we hold about you is accurate, up-to-date, complete and relevant when we use it or disclose it. You should contact us if you think your personal information is wrong.

If you have a question about this Privacy Policy or want to access or otherwise correct your personal information you can email privacy@getflip.com.au your questions and details that need changing.

A request for access needs to include a full description of the personal information requested. If making a request via email, you will be asked for two forms of identification, one of which must have a photograph on it. If you request information over the phone, we will ask you identity-related questions so we can verify you.

Your request for access to your personal information will be documented, as will details of the request and the identity of the Flip employee who gave it to you. We will generally give access unless an exemption applies to certain information as permitted by the Australian Privacy Principles under the Privacy Act.

If you believe that the information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you can request its correction. If we are satisfied that the information needs to be corrected, we will take reasonable steps to ensure that information is corrected and notify you of the correction. However, there may be circumstances in which we may have to refuse a request for correction. In such a case you can request that we associate a statement, with that personal information, that you made a request for correction.

You will not be charged for accessing or correcting your information.

We might have to charge for the reasonable cost of processing your access request.

How We Will Respond To Your Request

We will acknowledge receipt of your request within 2 business days of receiving your request. We will do our best to deal with your request within 5 business days. If we cannot help with your request, you will receive a written explanation as to why and details of what you can do to take the matter further if you are not satisfied with our response.

Do You Have A Concern Or Query In Relation To Privacy?

If you have any concerns or queries about privacy, you can email privacy@getflip.com.au

We will do our best to resolve your complaint as quickly as possible. However, if you are not satisfied with the result of your complaint to us, you can refer your complaint to the:

• online privacy complaint form oaic.gov.au
• call 1300 363 992
• mail GPO Box 5218, Sydney NSW 2001

Need Further Information?

For more information about privacy in general, you can visit the Office of the Australian Information Commissioner’s website at oaic.gov.au

Updating Our Privacy Policy

We may review, amend or revise our Privacy Policy and the way we handle personal information from time to time. We will post the updated Privacy Policy on our website at www.getflip.com.au and its terms will take effect from the date of posting.

Last updated: March 2023