Privacy Policy

UPDATED JULY 2023

About this Policy

Ocwen Energy Pty Ltd (ABN 44 605 178 578) trading as Lowes Petroleum Service (Lowes) (‘we’, ‘us’, ‘our’) understand that your privacy is important to you and we want you to know that your privacy is equally important to us. As we value your trust, we always aim to be transparent about what we do with your information and the ways in which we ensure it remains protected.

As we are an entity which is subject to the Privacy Act 1988 (“the Privacy Act”), we comply with the 13 Australian Privacy Principles (“APPs”) when dealing with your personal information. The APPs are derived from the Privacy Act.

The APPs regulate how we may collect, hold, secure, use and disclose personal and in some instances, sensitive information about you. The APPs also regulate how you may access and correct personal information we hold about you.

This policy explains how we handle your personal information.

Policy Statement

Policy Purpose

The purpose of our Privacy Policy is to clearly and openly set out how we collect, hold, secure, use and disclose your personal information (including sensitive information).

Our Privacy Policy also sets out how you can access or correct your personal information or what you can do if you are unhappy with our management of your personal information.

Changes to this Privacy Policy

Sometimes we update our Privacy Policy.

We reserve the right to review and update this Privacy Policy from time to time. You can always find the most up-to-date version on our website.

By continuing to use our website, or otherwise deal with us after such changes have been made, you acknowledge and agree that you have read, understood and accepted this Privacy Policy as it applies from time to time.

Scope

This Privacy Policy applies to all personal information and sensitive information collected held, used or disclosed by us.

Principles

Information we can Collect and Hold About You

1. We use only lawful and fair ways to collect personal information about We take all reasonable steps to let you know when we collect personal information, which includes informing you through this Privacy Policy.
2. We collect and hold personal information from a number of sources to conduct our business, for administrative purposes, or for legal compliance.
3. We only collect personal information from you if it relates to your business with Quite often, this is collected during our administration or transaction processes but it may also be collected from email, letters or other forms of communication.

Information we collect from you

The types of personal information we may collect from you will depend on the circumstances in which the information is collected.

We collect information from you when you contact us, use our products or services, visit our website or deal with us in some other way.

Generally, the types of information that we collect includes:

• Identity information—your name, contact details (including home or business address, telephone number and email address), company details (if applicable), date of birth, drivers licence number and any other information you may provide to us during the credit application process.
• When you visit our website—time and date of your visit, your location, IP address, browser / network information, any information or documentation that you download (includes third-party sites).
• Other personal information—such as details about your dealings with us.

Information we collect from others

Sometimes we may collect information about you from others we deal with. This may be about a supply, sales contract or to provide a product or service. We may also collect publicly available information about you such as that on social media sites or public registers. We only do this if it is not possible or reasonable to collect it directly from you.

Sensitive information

Some of the personal information about you we may collect and hold is sensitive information such as your religion, health or ethnicity. The Privacy Act 1988 protects sensitive information. We only collect sensitive information if it is necessary and with your consent (unless otherwise stated by law).

What Is Not Personal Information

Information where we have removed any reference to an individual will not be personal information, provided that the identity of the individual can no longer be ascertained.

Personal Information Covered by This Privacy Policy

This Privacy Policy applies to all personal information that we now hold or may collect in the future. This includes information that you provide when you use any of our apps, visit our website or third-party platforms on which we have a presence, order products or services, enter a competition or promotion or otherwise submit information to us (such as by filling in a form or responding to a survey). Where applicable, we and any related group companies will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act and any other applicable exemptions in the Privacy Act or other legislation.

How we Collect and Hold your Personal Information

1. We are careful about how we use your personal information. We may use it to deliver products and services, to better understand you and your needs, or to let you know about products and services you might be interested in. We may also collect, hold or exchange your information for other reasons where the law allows or requires us to do so.
2. We hold personal information in electronic form, using cloud-based encrypted databases. We may also hold information about you on our website to improve our services for you. Our website uses cookies to deliver a better user experience and may also contain links to other websites.
3. We do not have any control over the privacy controls of third-party websites – these are not subject to our Privacy Policy or Procedures.

Why we Collect, Hold, Use and Disclose your Information (Primary Purposes)

We do not collect personal information unless the information is reasonably necessary for one or more of our business functions and operations.

1. Mainly, the information we collect is to:
   • Conduct our business and improve the way we conduct our business with you (e.g. assess and process a credit application, establish and administer your credit account, handle complaints);
   • Maintain contact with you (customers, suppliers, business partners or other stakeholders) to provide information and respond to any requests you make;
   • Inform you of products or services that we think you may be interested in or may improve your experience with the company;
   • Recruit staff and provide a range of services to them; and
   • Other purposes directly related to the above.

Secondary Purpose Use or Disclosure

We may collect your personal information for secondary purposes that relate to the primary purposes above. Secondary purposes may include considering methods to ensure a more efficient running `of our business e.g. using technology to understand how we are doing or how we can sell, transfer business or merge with another business or generally improve our business as a whole.

1. We do not use or disclose personal information other than for the primary purpose (why it was collected), unless:
   • You have consented for a secondary use or disclosure; or
   • You would reasonably expect us to use or disclose the information for the secondary purpose, and the secondary purpose is:
     • For sensitive information, it is directly related to the primary purpose; or
     • For information that is not sensitive information, it is related to the primary purpose;
   • It is required under Australian law;
   • A general situation exists or a permitted health situation exists in relation to the use or disclosure of the information by us; or
   • We reasonably believe it is necessary for law enforcement.

Our IT Manager does not approve any disclosure of personal information for secondary purposes unless you have given consent for it to be provided.

Security

The security of personal information is important to us and we take reasonable steps to ensure that the personal information we hold is secure. Notwithstanding this, except to the extent that liability cannot be excluded due to the operation of statue, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of personal information.

Nothing in this privacy policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law.

1. We hold your personal information in both paper-based and electronic files and take all reasonable measures to protect your personal information against misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure.
2. We protect your personal information using both physical security systems and information and communications technology (ICT) systems.
3. We use encryption technology to protect your personal information and transactions with us.
4. We take reasonable steps to destroy or de-identify personal information we no longer need. This also includes when by law, we are no longer required to keep records about you.

Being Anonymous or Using a Pseudonym (Nickname)

We understand anonymity is an important part of privacy. When dealing with us, you have the option of remaining anonymous (i.e. not use your real name and/or contact details) or using a pseudonym (i.e. use a name like a nickname that isn’t your real name, or your email address or a user name you use online).

You will be unable to remain anonymous or use a pseudonym or nickname if we are required by law to only deal with you if you have identified yourself or if it is impracticable for us to deal with you without you having identified yourself.

When you just use a nickname

If you only use a pseudonym or a nickname when you deal with us:

1. We can only give you general information about our products and
2. You can purchase cash-only products and
   
   When you are anonymous or use a pseudonym or nickname
   For most of our business activities, it’s not practical for us to deal with you when you do not identify yourself or if you use a pseudonym or a nickname.
3. We cannot provide you (as a customer, supplier, or potential employee) with any information about your business dealings with us.
4. We cannot deal with a complaint you may
5. We cannot deliver a service or product to you at an
6. You may not be able to attend any of our networking events, enter in promotions or participate in any online forums we provide.
   
   When you use both your real name and a pseudonym
   You can also deal with us using a combination of a pseudonym and your real name, with contact details. If you choose to deal with us in this way:
7. We may collect your personal information and your pseudonym
8. If you only use your pseudonym to identify yourself, we will deal with you as described in ‘When you are anonymous or use a pseudonym or a nickname’
9. We may ask you for proof of identity.

Unsolicited personal information

1. Unsolicited personal information is information that we may receive about you that has not been requested or information that has been received where no active steps have been taken to collect that information.
2. We assess all unsolicited personal information we If it is information we could have lawfully collected about you, , we treat it according to the Australian Privacy Principles (APPs).
3. If we deem that we could not have collected the personal information, we will take steps to destroy or de-identify all unsolicited personal information as soon as practicable, if it is lawful and reasonable to do so.
4. If personal information was collected in an unsolicited manner, we take reasonable steps (which may include referring you to this Privacy Policy) to inform you of such collection and how we will use, secure or disclose your information.

Marketing

1. We only use personal information for direct marketing purposes with your consent or if it is authorised by law to do so.
2. We may use your information to tell you about our products and services (including those of third parties) we think you may be interested in (we may do this, even if you are on the ‘Do Not Call’ Register).
3. We may record your contact details when you:
   

   Call, mail, email or SMS us; Register and login to our website; Purchase a product or service, if you are a customer or supplier; Fill out an application form (including a credit application form); Participate in a transaction; Provide your contact details via web, mobile or email; or Ask us for information or request something from us.

4. We will always ask for your consent before your details are provided to other companies for marketing purposes.
5. You may opt out of receiving marketing information at any You can do this by asking us to not send you marketing materials. You can contact our Marketing Manager or ‘unsubscribe’ from emails or other marketing messages.
6. Our service providers may provide us with your information from their websites, social media sites, mobile and other technology-based sources.
7. Sometimes, we may combine your personal information with other information we have about you (including sensitive information). When we do, we do not pass on any of this information.
8. We may get information about you from consumer or commercial credit reports (e.g. information that assists us to assess your credit profile or your ability to meet financial commitments to us). We only record your personal information in our database when we are dealing with We remove it from our database when we no longer need to keep a record of it (except if it is required by law to keep it e.g. for tax or superannuation purposes).

Disclosure of Personal Information to Overseas Recipients

1. We only disclose personal information to overseas recipients such as service providers for data storage purposes, or if proof of identity is required g. for a cloud data centre, a customer information call centre or a freight provider.
2. We do not disclose personal information to overseas recipients unless you have given approval for us to do so, e., you ask us to, or it is required by law to disclose personal information to the overseas recipient.
3. Australian law may not apply to overseas If we do provide your personal information to an overseas recipient, in accordance with the Privacy Act we take reasonable steps to ensure that the overseas recipient will handle your personal information in accordance with the APPs. We also ensure proper data handling and security arrangements are in place to protect your information. We take all reasonable steps to make sure overseas recipients are bound by our privacy and confidentiality obligations.

Disclosure of Personal Information to Third Parties

1. If your personal information is to be disclosed to a third party, we take all reasonable steps to protect that information by ensuring the third party is bound by the Privacy Act and the APPs. We apply the same restrictions to third parties as required by us in the Privacy Act
2. for the collection and use of your personal information.
3. We do not use or share your personal information other than for these purposes:
   • As required or permitted by law;
   • As set out in this Privacy Policy (primary or secondary purposes above);
   • As you would reasonably expect.

Destroying Information No Longer Needing To Be Kept

When we no longer need your personal information for any purpose for which the information may have been used or disclosed under this policy, we will take reasonable steps to destroy the information or ensure that it is de-identified if we are lawfully able to do so.

Accessing your Personal Information we Hold

1. You may access personal information we hold about you unless it is deemed commercially sensitive or granting access may pose a serious threat to the life, health or safety of any individual, or to public health or public If we grant you conditional access, or deny your request, we’ll write to you to explain our decision.

Correction of Personal Information we Hold About You

1. If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to make corrections to your personal information. We will consider your request and if we agree, we will take reasonable steps to correct your personal information to ensure that, having regard to the purpose for which it is held, it is accurate, up-to-date, complete, relevant and not misleading.
2. If we do not think the information needs correcting, we’ll write to you to let you know why. You can ask us to include a statement that says you believe the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
3. You can contact our Marketing Manager to view information we hold about you or ask us to correct information at:

Phone:  07 4671 3780
Email:   reception@lowespetrol.com.au

Complaints

1. Complaints regarding a breach of the Privacy Act, the APPs or this Privacy Policy should be directed to our Marketing Manager – see the “Correction of Personal Information We Hold About You” section above for contact We are entitled to verify the identify of the complainant and will take reasonable steps to reply to the enquiry within 30 days.
2. If the complaint is not resolved in a manner acceptable to you, the complaint may be submitted to the Office of the Australian Information Commissioner.

Related Documents

• Australian Privacy Principles (APPs)
• Do Not Call’ Register
• Privacy Act 1988 (Privacy Act)

Definition of Terms