Privacy

Privacy Statement - Energy

This policy explains how Sumo manages your personal information, credit information and credit eligibility information. Personal information is information that can be used to identify you, and includes your name, address, telephone number and email address. Credit information is information that relates to credit that you have applied for (such as loans, hire purchase agreements or other deferred debts) and includes information about the types of credit provided to you and any payments for credit that are overdue. Credit eligibility information is credit information about you that is disclosed to us by a credit reporting body. We are committed to complying with the Privacy Act 1988.  We are also committed to complying with the Spam Act 2003 (which deals with restrictions on sending emails) and the Do Not Call Register Act 2006 (which deals with restrictions on making telephone calls).

 

What information does Sumo collect?

Sumo is an energy retailer. We supply and sell energy and related services to households and businesses, and collect, hold, use and disclose information for this purpose. We collect and hold personal information about you, our customer or prospective customer, including your name, address, date of birth, telephone number, email address, bank account and credit card details and concession entitlements. We also collect and hold information about your past energy consumption or likely future energy consumption, as well as credit information and credit eligibility information about you (including your credit history and problems meeting repayments such as defaults and judgements).  In some instances, we may also collect sensitive information about you (for instance, if life support equipment is used at your premises). If you provide us with personal information about another person (such as an additional account holder or a family member), we will ask you to also tell that person about this Privacy Policy. We also collect and hold information about our suppliers, employees and contractors (and prospective employees and contractors) and business customers. We collect personal information in a variety of ways, including directly from you, from your authorised representative or an additional account holder, from our agents or third parties with whom we have business relationships, from other energy market participants or the market operator, from credit reporting bodies, and from public sources (such as telephone directories).  For prospective customers, we also receive and collect personal information about you from third parties who have identified you as a person who may wish to receive offers relating to our products and services. We may record your telephone calls with us, including for training, service quality, verification and compliance purposes.

 

Credit reporting

We may collect and hold credit related information from credit reporting bodies from time to time. Credit related information assists us to determine whether we will provide or continue to provide any products or services to you on credit and to manage our relationship with you.  Credit related information includes your credit history, details of any credit you have sought or obtained from other credit providers, a credit rating or credit assessment score and details of any credit related court proceedings or insolvency applications that relate to you. When requesting a report from a credit reporting body, we will provide information that identifies you to the credit reporting body. We may use and disclose the credit related information we collect as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code, including using your credit related information to assess an application for credit made by you to us and to collect payments you owe us. If your application for credit is refused by us based on information provided to us by a credit reporting body, we will inform you of this and provide you with the name and contact details of that body (together with any other information required to be provided to you).

 

How does Sumo use and disclose information?

We may use or disclose your personal information, credit information and credit eligibility information to sell energy or provide other products and services to you, and in the administration of our business. For example, we may disclose personal information, credit information and credit eligibility information to our agents, advisors, contractors, service providers and entities related to us (including to entities located overseas), but only for the purposes of our business. This will include disclosing personal information, credit information and credit eligibility information for the purposes of any energy market process or system (including to distributors of energy or a market operator) and to credit reporting bodies. If you fail to make payments or you default on your obligations, we may report this information to a credit reporting body. We may tell a credit reporting body if we suspect you have committed a serious credit infringement (for example, if you deliberately seek to evade your payment obligations). We may also use or disclose information where required or permitted by law (for example to a law enforcement agency, a regulatory body or an industry ombudsman), to any organisation involved in a corporate reorganisation with us or considering acquiring an interest in our assets or business, or to any person or organisation where you have given your consent (whether express or implied). Where we provide your personal information, credit information and credit eligibility information to other parties, we take steps to ensure the other party maintains the privacy of that information. We may analyse customer information so that we can manage and improve our services. We may also use your personal information, credit information and credit eligibility information to provide you information about other products and services of ours and of other suppliers that you might be interested in, although you may opt out of receiving this information. We may need to disclose your information, including information we receive through the credit reporting body, to organisations located overseas. These organisations are service providers which perform a range of operational and customer service functions on our behalf. We only disclose your information to these organisations when it is necessary for the services they provide. When we disclose your information to our service providers located overseas, we take measures to ensure your information is treated in accordance with the standards that apply in Australia.

 

Our website

We generally only collect your personal information on our website where you provide it knowingly and voluntarily (for example, by entering your details as part of our online sign-up process, filling out a form or emailing an inquiry, even if the contract is not submitted, or the form or inquiry not sent).  We may also collect other information about your use of the website that cannot be used to identify you, including your server address, your top level domain name, the date and time of the visit, pages accessed and documents downloaded and the address of any website that linked you directly to our site. We may use ‘cookie’ technology on our website. A ‘cookie’ is a small message given to your web browser by our web server. The browser stores the message in a text file, and the message is then sent back to the server each time the browser requests a page from the server. A cookie does not give us any personal information about you. We use cookies to measure usage sessions accurately, and to gain a clear picture of which areas of the site attracts traffic. We also use cookies to improve the functionality of our website. Our website may also contain links to other websites operated by third parties.  We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.  Third party websites are responsible for informing you about their own privacy practices.

 

Employees and contractors

If you are applying for a position with us (either as an employee or a contractor), we will ask you to provide specific personal information, such as your name, email address, telephone number, qualifications and career history. We may also ask you for other information such as your interests and the position(s) you are interested in. Any personal information that you provide to us in connection with your application may be used to consider you for current and future employment or engagement as an employee or a contractor. We may disclose any personal information that you provide to our external advisors to assist us in the selection and recruitment and employment processes. If your application is unsuccessful, the Privacy Act will apply to any personal information that we collect, use, hold and disclose about you. We may retain this information for a reasonable period, and may use it to contact you in relation to other employment or contracting opportunities that you may be interested in. If you are or become our employee, we will collect employee records and personal details, referee reports and other information about you. The handling of your personal information as an employee is exempt from the Privacy Act if it is directly related to your current or former employment relationship with us. We will not disclose your personal information for any other purpose, other than as required by law or to manage your employment relationship with us. If you are engaged by us as a contractor, the Privacy Act will apply to any personal information that we collect, use, hold and disclose about you. We will collect, use, hold and disclose personal information about you in order to manage and administer your engagement as a contractor. This may include disclosing your personal information to employees and other contractors of ours so they may contact you in relation to your engagement as a contractor, including to provide instructions or information to you and collecting, using and disclosing your personal information in relation to reviewing and paying any invoices related to your engagement as a contractor, and ensuring appropriate training is provided.

 

How does Sumo manage information?

We take reasonable steps to maintain the security of information held by us to ensure it is protected from loss or unauthorised access, destruction, use, modification or disclosure. Access to personal information, credit information and credit eligibility information is restricted to authorised personnel. We do not sell or trade your personal information, credit information or credit eligibility information, although we may disclose your information to a third party in connection with a sale to that party of a debt owed by you to us. If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you have the right to request credit reporting bodies not to use or disclose credit reporting information about you.

 

How can you access your information?

You have a right to access your personal information, credit information and credit eligibility information. However, we may limit your access if access would disclose personal information about another person, or where it would disclose commercially sensitive information. If you would like to request access to your information held by us, please contact us in writing using the contact details provided below. We will seek to ensure that your personal information, credit information and credit eligibility information is accurate and complete. However, if you would like to update your details or if you believe that the information held is incorrect, please contact us in writing using the contact details below. Complaints about privacy If you have a complaint about how Sumo has handled your information, you can contact us at the address below. We will do our best to respond to your complaint within 30 days. If you are unhappy with the resolution of your complaint you can refer the matter to the Office of the Australian Information Commissioner.  For more information, see www.oaic.gov.au. How to contact Sumo If you have any questions about how Sumo handles personal information, or about your credit information or credit eligibility information, please contact us: Email: privacy@sumo.com.au Phone: 03 9102 8400 Address: South Melbourne Market Street, PO Box 5329, South Melbourne VIC 3205 Changes to this privacy policy We may update our privacy policy from time to time.  This privacy policy was last updated on 27 June 2017.

We generally collect your personal information so we can supply and sell you energy and manage your energy account. Without limiting this general statement:

 

  • We may assess your creditworthiness by conducting a credit check. We will use your identification information for this purpose, and will disclose your credit-related information to a credit reporting body to obtain from them a credit report about you. See more information below under ‘Statement of notifiable matters’.
     
  • We will use your life support details to register your property for life support, to ensure you are notified before any planned electricity outage.
     
  • If you gave your consent, we will use your personal information to let you know about great products and offers from us and other suppliers. We may also disclose your name and email address to a third-party loyalty rewards program provider, which will enable you to access benefits directly from that provider. If we do, your name and email address will not be used or further disclosed for any other purpose, unless you use the third-party loyalty rewards program provider’s service, in which case that provider’s privacy policy will apply. The third-party loyalty rewards program provider may also share some of your personal information with us, such as your name, contact details, buying habits and product preferences, and we may use this information to assess the performance of the rewards program, and for further marketing to you.

 

If you don’t provide these details, we won’t be able to do these things. We usually disclose customer personal information to related parties, contractors, agents, energy distributors or retailers, government bodies, regulatory authorities (where required or authorised by law) and our service providers. We engage some sales and marketing providers who are located in New Zealand. We may provide them with personal information to the extent necessary to administer the payment of sales commissions, to respond to an inquiry or complaint by you or to process your request not to be contacted for marketing purposes. More information is contained in our privacy policy, including how you may access and correct the personal information we hold about you and how to lodge a complaint. The privacy policy can be found at www.sumo.com.au/privacy-policy.

We collect your personal information so we can answer your query or give you the information you requested. If you don’t provide your details, we may not be able to respond as requested. We may also use your personal information to let you know about great products and offers from us and other suppliers. We may disclose your personal information to our contractors, agents, government bodies, regulatory authorities and our service providers. More information is contained in our privacy policy, including how you may access and correct the personal information we hold about you and how to lodge a complaint. This Privacy Collection Statement was last updated 27 March 2018.

Privacy Statement - Telco

 

For specific information on the type of information that we collect about you and why we do this, you should read the appropriate collections statement:

 

Introduction This statement includes:

 

  • our collection statement, explaining aspects of our collection and use of personal information
     
  • our privacy policy, further explaining how we manage personal information
     
  • our credit reporting policy, explaining how we manage we manage credit information and credit eligibility information.

 

Who we are Sumo Telco Pty Ltd  ACN 621 160 058 Our contact details

 

 

Collection from third party sources We may collect personal information from someone other than you, and you may not be aware of the collection, when it is not reasonable or practicable to collect it from you, and it is available from:

 

  • publicly available sources like phone books
     
  • other companies in our group that you may have dealt with
     
  • third parties like our business partners, your authorised representative/s and wholesalers
    information brokers
     
  • other telecommunication and information service providers that interact with us in providing products to you (eg overseas when you use a roaming mobile service)
     
  • credit reporting bodies, credit providers, fraud checking agencies
     
  • our dealers, contractors and other representatives that you may deal with
     
  • our websites and how you use them
     
  • various parties listed under Disclosing personal information in our Privacy Policy.

 

Collection under law   We may be required to collect personal information under the Telecommunications Act 1997 and laws made under it (eg if we supply a pre-paid public mobile telecommunications service, we are required by law to carry out an identity check.) We may be required to collect information, relating to an individual or a communication to which an individual is a party, under the ‘data retention’ provisions of the Telecommunications (interception and Access) Act 1979 (‘Data Retention Law’). Why we collect and hold personal information   We collect and hold personal information because:

 

  • we may need to use it to operate our business
     
  • we may need to provide it to other parties in connection with our business
     
  • we may need it to comply with the law, including the Data Retention Law.

 

The uses and disclosures we may make of personal information are detailed in our Privacy Policy. Unavailability of personal information If we cannot collect the information we need about you, we may not be able to supply the products or service you want. Disclosing personal information We may disclose personal information as reasonably required to contractors and suppliers of goods and services that we use to operate our business and provide products and support to you, and to other parties detailed in our Privacy Policy.  We may also disclose it to authorised agencies under the Data Retention Law. Some of these parties may be based overseas eg South Africa, India and New Zealand and countries where you use roaming services while travelling. Access and correction Our privacy policy contains information about how you can access and seek correction of the personal information about you that we hold. Complaints Our privacy policy explains how you can complain about a breach of the Australian Privacy Principles, and how we will deal with such a complaint. Credit related information Our Credit Reporting Policy is on our website and contains information about:

 

  • how you may access credit eligibility information we hold about you
     
  • how you may seek correction of credit information or credit eligibility information we hold about you
     
  • how you may complain about our failure to comply with the credit reporting rules in the Privacy Act
     
  • how we will deal with a complaint.

 

We are not likely disclose credit information or credit eligibility information to entities that do not have an Australian link (as that term is defined by the Privacy Act). Website and credit notifiable matters If there are any Credit Reporting Bodies (CRB) to which we are likely to disclose your credit information, our website also contains information about credit reporting, including details of each CRB and a statement of ‘notifiable matters’ that explains:

 

  • that the CRB may include the information in credit reports
     
  • that we may disclose certain credit defaults to the CRB
     
  • how to obtain the credit-related information management policies of us and the CRB
     
  • your right to access and seek correction of credit-related information about you, and make a complaint
     
  • your right to ask the CRB not to use credit reporting information to facilitate direct marketing
     
  • your right to ask the CRB not to use or disclose credit reporting information about you where there may have been fraud.

 

You can ask for the statement of notifiable matters in an alternative form, such as a hard copy.

Personal information This refers to information or an opinion about a living person who is identified or reasonably identifiable, whether or not true and whether or not recorded in material form.  For the purposes of the Data Retention Law, it also refers to information retained for the purposes of that law, if it relates to an individual or a communication to which the individual is a party. Kinds of personal information we collect and hold Broadly, we may collect and hold:

 

  • personal details like name, date of birth, gender, occupation and driver licence number
     
  • contact details like physical, postal, work and email addresses and phone numbers
     
  • financial details like bank account, credit card numbers and your billing and payment history with us
     
  • service-related details like your user name, encrypted password and service usage history, support incidents, enquiries and complaints
     
  • other details relating to special situations like specific health information if you apply for priority assistance and information about any authorised representative you appoint
     
  • Data Retention Law details (where that law applies) like subscriber and account details, service details, details about telecommunications devices, the source and destination of communications, the date and time of communications and connection to services, the type of a communication or service and location details.

 

In any case, we only collect personal information that is reasonably necessary to support our functions and activities.  If we cannot collect the information we need about you, we may not be able to supply the products or service you want. Collecting personal information Unless it is not reasonable or practicable to do so, and in other cases allowed by law, we will collect personal information about you directly from you (eg when you contact us by phone or online, or at our premises, or fill in an application form). In other cases, we may collect personal information about you from:

 

  • publicly available sources like phone books
     
  • other companies in our group that you may have dealt with
     
  • third parties like our business partners, your authorised representative/s and wholesalers
     
  • information brokers
     
  • other telecommunication and information service providers that interact with us in providing products to you (eg overseas when you use a roaming mobile service)
     
  • credit reporting bodies, credit providers, fraud checking agencies
     
  • our dealers, contractors and other representatives that you may deal with
     
  • our websites and how you use them
     
  • third parties that have identified you as a person who may wish to receive information or offers about our products
     
  • various parties listed under Disclosing personal information below.

 

Our website   We generally only collect your personal information on our website where you provide it knowingly and voluntarily (eg by entering your details as part of an on-line sign-up process, filling out a form or emailing an inquiry, even if the sign-up is not submitted or the form or inquiry is not sent). Our website may contain links to other websites operated by third parties.  We make no representations or warranties about the privacy practices of any third party and we are not responsible for the privacy policies or content of any third party website. Holding personal information We hold personal information in hard and/or soft copy at our offices and in other facilities that we own or license from third parties, like data centres. We take reasonable steps to keep it secure and to protect it from unauthorised access, use or alteration.  Where required by the Data Retention Law, it will be encrypted. Why we collect and hold personal information We collect and hold personal information because:

 

  • we may need to use it to operate our business
     
  • we may need to provide it to other parties in connection with our business
     
  • we may need it to comply with the law, including the Data Retention Law.

 

Using personal information   We may use personal information:

 

  • to identify you
     
  • for credit checks
     
  • to prevent fraud
     
  • to supply products (including goods and/or services) to you
     
  • to give you information about us and our products, and product offers
     
  • for direct marketing – see Direct marketing for details
     
  • to improve our products, our marketing and our website
     
  • to answer your enquiries
     
  • to give you customer support and service
     
  • to better understand your needs and respond to them
     
  • to manage and plan our products and business
     
  • to charge and bill you for products you use
     
  • to collect payment from you
     
  • to monitor, manage, test and improve our network and facilities
     
  • to comply with various laws that apply to us, including the Telecommunications Act 1997, the Data Retention Law and our obligations under any carrier licence that we hold
     
  • for other purposes related to the operation of our business.

 

Disclosing personal information We may disclose personal information as reasonably required:

 

  • to contractors and suppliers who supply or support us in:
    market research, sales and marketing
    direct marketing – see Direct marketing for details
    identity and fraud checking
    credit-related matters like credit rating, creditworthiness and credit provision
    credit management
    service provisioning
    installation, maintenance and repairs
    helpdesk and enquiries
    support and complaint management
    communications and mailing
    billing, debt recovery and credit management
    network and product design and maintenance
    corporate strategy
    legal and regulatory advice and compliance
    accounting and financial planning
    risk management
    otherwise providing goods and services that we use to operate our business and provide products and support to you
     
  • to your authorised representative/s
     
  • if you ask us to do so
     
  • to our agents and dealers
     
  • to members of our corporate group (including to facilitate them direct marketing their products and services to you)
     
  • to our business partners and wholesale suppliers
     
  • to other telecommunication and information service providers that interact with us in providing products to you (eg overseas when you use a roaming mobile service)
     
  • to the manager of the Integrated Public Number Database, the Australian Communications and Media Authority, police, law enforcement and national security agencies and other authorities when and as required by law
     
  • to authorised agencies under the Data Retention Law
     
  • to organisations that provide credit or finance to us
     
  • to persons who invest in or acquire all or part of our business or company, or are considering doing so.
     
  • Some of these parties may be based overseas eg South Africa, India and New Zealand and countries where you use roaming services while travelling.

 

Direct marketing We may use and disclose personal information to direct market to you products offered by us, our agents, dealers and members of our corporate group, and our business partners, where we think the offers will be of interest to you, using:

 

  • post
     
  • email
     
  • electronic messaging
     
  • social media
     
  • targeted web content
     
  • other direct marketing channels.

 

Direct marketing may continue until you opt-out by calling the number in Contacting us even if you are no longer our customer. Accessing and correcting personal information Please contact us for these purposes using the details in Contacting us below.  We shall process and respond to your request in accordance with Australian Privacy Principle 12. There is no charge for making a request but a reasonable administrative charge, on a cost recovery basis, may be payable before we agree to provide access. Complaints If you wish to complain about a breach of the Australian Privacy Principles, please contact us using the details in Contacting us below.  We shall:

 

  • acknowledge your complaint within a reasonable time
     
  • do our best to respond within 30 days
     
  • allocate your complaint to a suitably senior staff member
     
  • process and respond to your complaint as soon as we reasonably can.

 

Contacting us Questions, requests and complaints regarding our Privacy Statement or our compliance with privacy laws should be directed to us by telephone on 03 9102 8400 or email to privacy@sumo.com.au.

Credit information This refers to information such as:

 

  • identification information
     
  • basic details of a credit account (eg establishment date)
     
  • details of enquiries we make to Credit Reporting Bodies (CRBs) about you
     
  • details of some overdue payments and serious credit infringements and of payments or later arrangements in relation to either of these
     
  • publicly available information like bankruptcy and court judgments for debts,
     
  • more fully defined in the Privacy Act.

 

Credit eligibility information This refers to credit information (together with other credit-related information that CRBs derive from it) we obtain from a CRB together with credit-related information that we derive from it, and is more fully defined in the Privacy Act. Dealing in credit-related information If we provide credit, as defined in the Privacy Act, we may collect and deal in credit information, credit reporting information and credit eligibility information (eg if we supply equipment on credit terms or a post-paid product). Collecting credit information We may collect credit information in the same way as other personal information.  See Collecting personal information above for details. Collecting credit eligibility information We may collect credit information from CRBs and other credit providers. Holding credit-related information We hold and protect credit information and credit eligibility information in the same way as other personal information.  See Holding personal information above. Using credit information We use credit information in the same way as other personal information.  See Using personal information above. Using credit eligibility information   We use credit eligibility information in ways permitted by the Privacy Act and the Credit Reporting Privacy Code, such as:

 

  • processing credit applications
     
  • managing credit we provide
     
  • helping you avoid defaults
     
  • collecting credit-related debts you owe us
     
  • dealing with serious credit infringements
     
  • participating in the credit reporting system
     
  • transferring our debts to third parties
     
  • dealing with complaints relating to credit or credit reporting
     
  • for regulatory compliance purposes
     
  • in accordance with laws.

 

Disclosing credit information We may disclose credit information:

 

  • in the same way as other personal information. See Disclosing personal information above; and
     
  • to CRBs, which may disclose it to other credit providers.

 

Disclosing credit eligibility information We may disclose credit eligibility information for purposes permitted by the Privacy Act and the Credit Reporting Privacy Code, such as those detailed in Using credit eligibility information above. Accessing and correcting credit information or credit eligibility information Please contact us for these purposes using the details in Contacting us.  There is no charge for making a request but a reasonable administrative charge, on a cost recovery basis, may be payable before we agree to provide access. Complaints about credit compliance If you wish to complain about a breach of Part IIIA of the Privacy Act or the Credit Reporting Privacy Code, please contact us using the details in Contacting us.  We shall:

 

  • acknowledge your complaint within seven days, and sooner if practicable
     
  • try to investigate and resolve the matter within 30 days
     
  • explain any delay if we need more time, and seek your agreement (but if you do not agree, we might be unable to finalise the matter)
     
  • communicate, if necessary, with any other credit provider or CRB relevant to the matter.

 

If you are dissatisfied with the result of a complaint, you may escalate it to any external dispute resolution scheme (EDR) we are a member of, the Australian Information Commissioner (www.oaic.gov.au) or the Telecommunications Industry Ombudsman (www.tio.com.au). We may update our Privacy Statement from time to time.  It was last updated on 21 March 2018.

Statement of notifiable matters regarding credit-related personal information

In relation to credit-related personal information:

 

  • The credit reporting bodies to which we provide your credit-related personal information may include your
    information in reports it provides to credit providers to assist them to assess your credit worthiness;
     
  • if you fail to meet your payment obligations in relation to consumer credit or commit a serious credit
    infringement, we may be entitled to disclose this to the credit reporting body;
     
  • our privacy policy is available on our website at sumo.com.au/privacy-policy and also contains our policy about the
    management of credit-related personal information; each credit reporting body also has a policy dealing with its management of credit-related personal information;
     
  • you have the right to access your credit-related personal information from us, and to request the us to correct
    the information. You may also contact us or make a complaint on 03 9102 8400 or at privacy@sumo.com.au;
     
  • you have the right to request a credit reporting body not to use your credit-related personal information for
    the purposes of pre-screening of direct marketing by a credit provider;
     
  • you have the right to request the credit reporting body not to use or disclose credit reporting information
    about you, if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud;
     
  • The credit reporting bodies that we may disclose your information to are:

    Equifax
    Call: 13 83 32
    Mail: GPO Box 964 North Sydney NSW 2059.
    Web: Contact Us | Equifax


    Experian
    Call: 1300 783 684
    Email: creditreport@au.experian.com
    Web: Contact Us | Experian Australia


    Illion
    Call: 13 23 33 or +61 3 9828 3200
    Mail: PO Box 7405 St. Kilda Rd Melbourne VIC 3004.
    Web: Contact Us | Illion