Privacy Policy

1. What is the purpose of this policy?

1.1 This privacy policy applies to the handling of personal information by SEC Victoria Pty Ltd ACN 670 408 116, SEC Energy Pty Ltd ACN 670 408 134 and SEC Infrastructure Pty Ltd ACN 670 408 125 (together, SEC, we, us, our).

1.2. The purpose of this policy is to demonstrate that the SEC understands the importance of protecting the privacy of an individual’s personal information and is committed to safeguarding such information it handles.

1.3. This privacy policy sets out how SEC will protect the privacy of your personal information, your rights in relation to your personal information managed by us and how SEC collects, holds, uses, discloses, and otherwise manages, your personal information.

1.4. When handling personal information, SEC adheres to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) and the Information Privacy Principles contained in the Privacy and Data Protection Act 2014 (Vic) (PDP Act), and any other applicable legislation (Privacy Laws).

1.5. SEC is also a credit provider for the purposes of the Privacy Act. Our Credit Collection Statement is our Credit Reporting Policy for the purposes of the Privacy Act. It describes how we comply with our credit reporting obligations.

2. What personal information is collected

2.1. Personal information includes information or an opinion about an identified, or reasonably identifiable, individual, regardless of whether it is true or not or recorded in material form.

2.2. As a result of undertaking our businesses or commercial activities or as a result of other interactions or dealings with you, SEC may collect your personal information.

2.3. The kinds of personal information that SEC collects will vary depending on our particular interactions or dealings with you. However, generally speaking, the kinds of personal information we collect may include:

• your basic contact or identification information such as your name, phone number, address and email address;
• if you interact with us regarding our consumer and household energy programs or information, we may collect information relating to your property or place of residence, living situation and household, appliances, energy usage and billing;
• if you are an employee or other representative of a government body or corporate entity that we provide energy or related services to, information relevant to your interactions with us on behalf of that government body or corporate entity;
• information you disclose to our customer service team or business, including feedback you may have about our business, products, services or programs;
• usage information regarding your use of or interaction with our websites, applications, online platforms or other similar tools we make available from time to time;
• information relating to a specific activity, event or promotion that we undertake or provide, including as set out in a collection statement relating to that specific activity, promotion or event;
• if you are a prospective employee seeking employment or engagement with us, names and contact information, CVs, information obtained through reference checks;
• the names, contact details and other relevant details of service providers, suppliers, co-investors, other representatives that SEC has a business relationship with;
• any other information you provide while interacting with us, including data required to provide our services.

2.4. SEC may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.

2.5. Generally, we do not collect sensitive information about individuals. Personal information about your racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law (for example, energy industry law requires us to collect your health information in certain circumstances where you have particular energy requirements due to special medical needs).

3. How we collect your personal information

3.1. SEC collects personal information from you in a variety of ways, including:

• when you participate, or apply to participate, in a program we are delivering;
• if you use any of the applications, online platforms or other similar tools we make available from time to time;
• if you sign up to any of our mailing lists, newsletters or other similar publications;
• when you interact with us electronically or in person, including by posting on our social media sites;
• where a government body or corporate entity that you are an employee or other representative of acquires energy or other similar services from us;
• when you provide feedback to us or complete any of our surveys or enter a promotion or a competition conducted by us;
• if you are a supplier or service provider to us, a co-investor with us or have another similar commercial relationship with us (or if you are an employee or other representative of such a party);
• if you seek employment or other similar engagements with us; or
• when we engage in other business activities with you.

3.2. We may receive personal information from sources other than you, including from third parties you authorise to disclose your information to us, from publicly available records or sources or from other organisations we work with, such as service providers or program collaborators. Generally, we will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.

4. How we use your personal information

4.1. Generally, SEC may use personal information collected from you to conduct, improve and promote our businesses, organisation, programs, services and products. We may also make you aware of new and additional products, services, programs and opportunities available to you in relation to energy and energy-related matters.

4.2. This may include using your personal information to:

• provide you with products and services during the usual course of our business activities;
• undertake our programs, information campaigns and other similar activities, including regarding renewable energy, energy transition;
• administer our business activities;
• manage, research, develop, administer and improve our products and services, including our provision of energy products and services;
• manage our relationships with suppliers, service providers, a co-investors and other parties we have commercial relationships with;
• identify customers that might be suitable candidates for certain pilot and trial programs
• undertake direct marketing (as detailed in paragraph 4.3);
• conduct promotions, competitions, giveaways and events;
• contact you to obtain your feedback, respond to your enquiry, conduct market research or investigate any complaints;
• consider job applications for current and future employment; and
• comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.

4.3. In addition to the purposes outlined in paragraph 4.2, SEC may use your personal information in order to inform you of promotions, competitions, events, programs, products or services that may be of interest to you. This may include using your personal information for the purpose of promoting third party products, services, programs or promotions. If you do not wish to receive such communications, you can opt-out by contacting us via the contact details set out in paragraph 10 of this privacy policy or through the opt-out mechanism contained in any such communication to you.

4.4. In addition to the purposes listed above, SEC may use your personal information for other purposes which we notify you of when we collect the information (including in a collection statement specific to an activity or program) and for purposes otherwise permitted or required by law.

4.5. You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide services or information to you or may be limited in how we can interact or deal with you.

5. Disclosure of your personal information

5.1. SEC may disclose your personal information to third parties from time to time in a manner consistent with all applicable privacy laws. SEC will generally disclose personal information to third parties for the purposes for which it was collected, for related purposes or for other purposes with your consent.

5.2. This may include SEC disclosing your personal information to:

• other SEC entities in order to provide our products or services to you or to undertake our programs or information campaigns;
• our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy;
• our information technology service providers or electronic data storage providers;
• other third party service providers who assist us to undertake our programs or provide our products or services;
• people or entities who invest or are considering acquiring an interest or investing in our business or assets; and
• government authorities where required by law.

5.3. SEC may also disclose your personal information for other purposes if the disclosure is required or authorised by law.

5.4. If you post information or other content to public sections of our website or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

5.5. Some of the parties that we disclose your personal information to may be located outside Victoria or Australia. We take reasonable steps to ensure that any such recipients located outside of Victoria or Australia do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Laws.

6. Links to other websites

6.1. When you access our website, applications or other online services or tools, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you.

6.2. Each website has its own privacy practices, as described in that site’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site.

6.3. To the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot and are not responsible for any information that you may submit to that site.

7. Security of your personal information

7.1. To secure your personal information, the SEC takes reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

7.2. SEC periodically reviews its ongoing need to collect and keep personal information. SEC will also take reasonable steps to destroy or de-identify personal information it holds about an individual if it is no longer needed for any purpose.

7.3. We have in place procedures for training our employees about their obligations under this privacy policy and disciplining them for failure to follow this privacy policy. We also have in place internal procedures to assess compliance with this privacy policy.

8. Access to and correction of your personal information

8.1. To ensure the accuracy of your personal information, the SEC takes steps reasonable in the circumstances to ensure personal information it holds is up-to-date, complete, relevant and not misleading.

8.2. Under the Privacy Laws, you have a right to:

• access the personal information that we hold about you;
• ask us to update or correct the personal information that we hold about you; and
• ask for a copy of the personal information that we hold about you.

8.3. SEC will comply with your request if it is reasonable and lawful to do so, although:

• we may need to confirm your identity beforehand so we can ensure that we keep the personal information that we hold secure;
• there may be certain circumstances in which we cannot comply with your request, for example if the request would require us to disclose personal information about other people or commercially sensitive information to you; and
• we may not always be able to update or correct personal information, for example where we are prevented by law from altering information.

8.4. If we refuse your request in part or full, we will:

• write to you to explain our decision (except if it’s unreasonable to do so); and
• give you information on your options, including how to make a complaint.

8.5. There is no cost for you to submit a request to us, but SEC may charge a fee if responding to the request places an unreasonable burden on SEC resources. If there is a fee, we will let you know how much it is likely to be beforehand, so you can choose if you want to go ahead.

8.6. We will try to make your personal information available within 30 days after your request, but complicated requests may take more time.

9. Changes to the Privacy Policy

9.1. SEC will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on our website at https://www.secvictoria.com.au/ or can otherwise be obtained by contacting us and requesting a copy.

10. Contacting SEC

10.1. For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact our Privacy Officer using any of the following contact details:
Email: suzanne.greenland@secvictoria.com.au
Post: Level 35, 2 Lonsdale Street, Melbourne VIC 3000

11. Complaints

11.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to SEC’s Privacy Officer. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

11.2. SEC’s Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation.

11.3. If you are not satisfied with SEC's response to a complaint, or you consider that SEC may have breached the Privacy Laws, a complaint may be made to the Office of the Victorian Information Commissioner or Office of the Australian Information Commissioner:

Office of the Victorian Information Commissioner

PO Box 24274, Melbourne VIC 3001
Telephone: 1300 006 842
Email: enquiries@ovic.vic.gov.au
Website: https://ovic.vic.gov.au

Office of the Australian Information Commissioner

GPO Box 5288, Sydney NSW 2001
Telephone: 1300 363 992
Online enquiry: https://www.oaic.gov.au/about-the-OAIC/contact-us
Website: www.oaic.gov.au

12. Cookies

12.1. Our websites, applications and other online services may use cookies and other technologies. A cookie is a small file stored on the hard drive of your device and sent via a web server so that some information about your use of our websites, applications and other online services can be collected, for example:

• browser and device data, such as IP address, device type, operating system and internet browser type; and
• usage data, such as time spent on a website, pages visited, links clicked, language preferences, and the pages that led or referred you to a website.

12.2. You can change your web browser settings to limit the number of cookies accepted or to block cookies. Please be aware that by limiting or blocking cookies, certain functionalities of our websites, applications and other online services may not be available.

12.3. We will not normally collect personal information about you using cookies.