PRIVACY POLICY

1. About Assurant

Assurant Reverse Logistics Pty Ltd is a member of the Assurant group of companies. Assurant operates globally and provides services across a range of sectors including device lifecycle management, trade-in programmes, refurbishment, repair, reverse logistics, inventory recovery, warranties, insurance and related services.

The SolvUp website is operated as part of Assurant’s technology solutions and device lifecycle management business. Personal information collected through the website may be accessed, processed and managed by Assurant personnel, systems and service providers located in Australia, New Zealand and other countries where Assurant operates.

In this Privacy Policy, “we, our, us, Assurant and SolvUp” means Assurant Reverse Logistics Pty Ltd and, where relevant, its related bodies corporate and affiliated entities within the Assurant group of companies.

2. Introduction

At Assurant, we are committed to protecting your personal information and handling it responsibly and transparently in accordance with applicable privacy laws, including:

  • The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and
  • The Privacy Act 2020 (New Zealand) and the Information Privacy Principles (IPPs).

This Privacy Policy explains how personal information is collected, held, used, disclosed and protected through the SolvUp website and our related technology solutions, device lifecycle management, repair, refurbishment, trade-in, sustainability and circular economy activities.

Our overall approach for complying with applicable privacy requirements includes:

  • Respecting and maintaining our customers’ privacy.
  • Embracing Privacy by Design by building privacy protections into our products and services from the outset.
  • Complying with all relevant privacy and data protection requirements and obligations.
  • Complying with our approach to the management of personal information as explained in this Privacy Policy.
  • Ensuring appropriate resources are allocated to privacy, including technology systems and services, and our overall framework, and
  • Training our employees.

3. Who This Privacy Policy Applies To

This Privacy Policy applies to individuals who:

  • Visit the SolvUp website
  • Submit an enquiry through the website
  • Contact us regarding SolvUp products, services, or solutions
  • Participate in device lifecycle, trade-in, repair, refurbishment, recovery or sustainability programmes
  • Act on behalf of organisations that engage with SolvUp, or
  • Otherwise interact with Assurant through the SolvUp website in Australia or New Zealand.

4. What is Personal Information?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

In some circumstances we may also collect information that is classified as sensitive information under Australian law or personal information subject to enhanced protection under New Zealand law. Where this occurs, we will do so only where authorised by law or with appropriate consent.

5. Collecting Personal Information

5.1. The types of personal information we may collect

Depending on the nature of your interaction with us, we may collect:

  • Your name, contact details, postal address, phone number and email address
  • Your business name, job title or role
  • Information relating to products, devices, services, programmes, sustainability initiatives or business opportunities
  • Device, product, service or programme information relating to your enquiry or participation in SolvUp services
  • Transaction, service request, repair, trade-in or programme participation information, where relevant to the products or services you enquire about or receive
  • Details about your interactions with us, like phone calls and emails, as well as information submitted through enquiry forms, and
  • Any other information you voluntarily provide.

We may also collect information about your interaction with the website, including:

  • IP address
  • Browser type
  • Device information
  • Pages viewed
  • Website navigation activity, and
  • Cookie-related information.

We do not adopt, use or disclose government-related identifiers except as permitted by law. We do not intend to collect sensitive information, payment card information or identity documents through the website’s enquiry forms. Please do not provide unnecessary personal information.

However, in limited circumstances and where permitted by law, we may collect and process sensitive information where reasonably necessary for legal, regulatory, compliance, fraud prevention, Know Your Customer (KYC), Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) or related business purposes.

If you wish to remain anonymous or to use a pseudonym when dealing with us, we may only be able to provide you with limited information or services. However, in many cases it will not be possible for us to assist you with your specific needs if you wish to remain anonymous or use a pseudonym.

5.2. How we collect personal information

We collect personal information directly from you in several ways, including when you:

  • Submit enquiries
  • Complete online forms
  • Communicate with us by telephone or email
  • Engage with us regarding business opportunities, or
  • Otherwise interact with our website.

We may also collect personal information about you from third parties when it is not reasonable or practical to collect it directly from you, when you have authorised us to do so, or where permitted by law to provide products or services, manage risk, or to meet our legal and regulatory obligations.

This may include personal information collected from:

  • Other companies within Assurant
  • Retailers, dealers, distributors or other business partners
  • Persons or organisations legally acting on your behalf, such as your next of kin, nominated representative, legal guardian, or other person acting under a power of attorney
  • Government agencies, regulators or publicly available resources, and
  • Other third parties where permitted by law.

If you provide personal information about another individual, you must ensure you are authorised to do so and that the individual has been informed about this Privacy Policy.

5.3. Why we collect, hold, use and disclose personal information

We may collect, hold, use, and disclose personal information for our business and related activities, including to:

  • Respond to enquiries
  • Provide information regarding SolvUp products, services and solutions
  • Administer customer, supplier and business relationships
  • Support repair, refurbishment, recovery and trade-in programmes
  • Support sustainability and circular economy initiatives
  • Deliver device lifecycle management services
  • Communicate with customers, suppliers, partners and service providers
  • Operate, maintain and improve the website
  • Perform analytics and business improvement activities
  • Manage risk, fraud prevention and security activities
  • Support compliance, legal and regulatory obligations, and
  • Facilitate business activities across the Assurant group.

We may also use personal information for related secondary purposes that you would reasonably expect in the circumstances.

5.4. What happens if you do not provide personal information?

If you do not provide the personal information that is reasonably necessary for our functions and activities, we may not be able to respond to or assess your enquiry, service request, programme participation or business opportunity.

6. Business Communications and Direct Marketing

We may use your contact details to respond to your enquiry and communicate with you about SolvUp products, services, programmes, solutions and business opportunities that are relevant to your relationship with us.

Where required by applicable law, we will obtain your consent before sending marketing communications. You may opt out of receiving marketing communications at any time.

7. Storing and Disclosing Your Personal Information

We will only disclose your personal information to a third party, if permitted by applicable privacy and data protection laws, or if required by law. For example, we may share your personal information with the following parties:

  • Other related entities in the Assurant group for reasonable business purposes, including those located in Australia, India, United States of America, United Kingdom and the Philippines
  • Assurant employees and authorised representatives
  • Cloud hosting and technology providers
  • Consultants, contractors and professional advisers
  • Customer service personnel, programme administrators, repair providers, device lifecycle personnel and other authorised Assurant representatives
  • Communication and customer relationship management providers
  • Auditors and compliance service providers
  • Regulators, government agencies and law enforcement authorities, and
  • Other persons authorised by you or permitted by law.

Personal information held and stored by our business partners, service providers and other third parties we engage to provide and support the products and services we offer, will be done so in accordance with their individual privacy policies.

In using and storing your personal information, we may disclose your personal information to others including outside the country of collection for reasons related to the primary purpose for which it was collected. Secondly, some of the entities that we share information with may be located in, or have operations in, other countries. This means that your information might end up stored or accessed in overseas countries, including countries within the European Union, India, Japan, Philippines, United Kingdom, and the United States of America. In some circumstances, by providing your personal information to us, you acknowledge that your information may be disclosed to overseas recipients as described in this Privacy Policy and consent to those disclosures where permitted by law.

When we pass on, transfer or share your personal information in this way, Assurant takes reasonable steps to ensure that the recipient is subject to privacy protection comparable to those required under Australia and New Zealand privacy laws, or otherwise complies with applicable cross-border disclosure requirements and data protection laws. This may include entering into contractual arrangements, conducting due diligence, or relying on other measures permitted under applicable privacy laws.

To comply with a legal and regulatory obligation, or to the extent that we have a legitimate purpose (such as to manage our business operations or to conduct data analytics to improve our services), we may also share with others and disclose information from which personal information has been removed (including aggregated, anonymous or pseudonymised information) so that no privacy is affected.

We may also use third party providers to perform services for us, on your behalf, or to manage some of our processes and services. To enable those services and processes to be performed, we may need to provide those third parties with your personal information. We may also engage, or be engaged by, third parties including government agencies, in circumstances which require us to provide your personal information to them, or to another party, to meet our contractual, legal or regulatory obligations. You authorise us to disclose your personal information to those third parties where needed or required for those purposes.

There may be times when we must pass on personal information for legal or safety reasons or other special circumstances, such as complying with a legal or regulatory obligation that we have or when it is in your best interest.

We do not sell personal information.

8. Data Quality and Retention

We do our best to ensure that personal information we hold is accurate, complete, up to date and relevant. You are encouraged to notify us if your details change or if you believe information we hold about you is incorrect.

We retain your personal information only for as long as it is necessary to fulfil the purposes for which the information was collected, and to meet our legal and regulatory obligations. We have regular data retention management and purging practices in place to ensure information is securely destroyed or de-identified when no longer required, in accordance with APP 11.2. However, we may be required to keep some of your personal information for specified periods of time under applicable laws or regulations such as financial reporting and employment legislation, or due to legal or contractual obligations.

9. Protecting Your Personal Information

We use a combination of physical, electronic, and procedural safeguards, including technical measures to safeguard the personal information we store, as part of our business systems and processes. We take steps to protect your personal information from misuse, interference or loss and unauthorised access, modification and disclosure with appropriate safeguards and security measures. This includes in storage and when we transfer or share it, such as across borders, to ensure compliance with international data protection standards.

All our staff are trained to understand privacy and data protection requirements. We also conduct Privacy Impact Assessments on new systems and processes, to ensure we are adhering to privacy requirements and putting the right protection in place when making changes. We have teams and programmes in place to check our protections are working and remain up to date, including our protections to prevent and detect cyber threats. We are regularly audited to provide an independent assessment of our protection measures and help us to continue to maintain standards of personal information management and protection.

While we take steps to protect your personal information when you send it to us, you should keep in mind that no internet transmission is ever completely secure or error-free. If you provide any personal information to us via our online services (including email or a web-based service through a portal), or if we provide information to you or others by these means, the privacy, security and integrity of any data transfer over the internet cannot be guaranteed. When you share information with us (such as over the internet, or sending us an email), it is at your own risk as factors beyond our control include the security of the device and/or program you use to communicate with us, and steps you take to protect your login details and password. If you believe that there has been unauthorised use or disclosure of your personal information, please contact us (see below).

Our website may contain links or references to other websites or social media platforms, not subject to this Privacy Policy. You should check their own privacy policies before providing your personal information.

9.1. Websites, cookies and digital interactions

When you visit our websites, we may collect limited technical and usage information that is necessary to operate, maintain and protect the website. Each time you visit our websites, we may collect information about your visit which may include the following:

  • The date and time of visits
  • Pages accessed during your visit
  • Technical information necessary to support the operation and security of the website
  • General location information, and
  • Information about the device used to visit our website (including tablet or mobile devices such as device IDs).

Cookies are small information files placed on your device when you visit a website. SolvUp currently uses only essential cookies that are necessary for website functionality, security, navigation and session management. These cookies do not track your browsing activity across other websites, do not create profiles about you, and are not used for advertising purposes.

For information on disabling these cookies, please go to the privacy settings section within your browser. If you choose to disable cookie acceptance in your browser, you may not be able to access some parts of our websites, particularly the secure parts of the website. We therefore recommend you enable cookie acceptance to benefit from all the services on the website.

We also engage external service providers to support website hosting, maintenance, security and related technical services.

We maintain a data breach response plan and will comply with the Notifiable Data Breaches scheme under the Privacy Act where applicable.

10. Your Right to Access and/or Request Correction of Your Personal Information

You have the right to request confirmation of whether we hold any of your personal information, and if so, request access to or a copy of that information. You may also request that your personal information be corrected if you think it is wrong, incomplete or out of date.

We will disclose your requested personal information to you where it can be readily retrieved, unless there is a lawful reason for not doing so, including where such a disclosure would breach someone else’s rights to privacy and/or the law. Where required by applicable law, you may also request that a statement of correction be attached to your personal information if we do not agree to make the requested correction.

To request access to and/or correct your personal information, please contact us at the details below.

Assurant Reverse Logistics Pty Ltd
30 Niton Drive
Truganina VIC, 3029 Australia
Phone: +61 3 9862 3200
Email: privacy.ANZ@assurant.com

We will respond to your request for access to personal information we hold about you within the timeframes required by applicable privacy laws in Australia and New Zealand, and otherwise as soon as reasonably practicable, including notifying you if we are unable to provide access (such as when we no longer hold the information) or if we are permitted by applicable laws to refuse access. Generally, we do not impose a charge for requests for access, but where permitted to do so by applicable law, we may charge you a reasonable fee for the retrieval costs associated with providing you with access.

11. Contacting Us Regarding this Privacy Policy or To Make a Complaint

You may wish to contact us to seek more information about this Privacy Policy, to request a printed copy of this Privacy Policy, to access or correct your personal information, opt out of receiving direct marketing material, or make a privacy related complaint.

We take privacy-related complaints very seriously and consider all complaints carefully as part of our commitment to being open, honest, and fair in dealing with your concerns. We will acknowledge your complaint promptly and investigate and respond within the timeframes required by applicable privacy laws, or otherwise within a reasonable period, and keep you informed of progress if additional time is required.

If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you can ask for your concerns to be escalated to our Privacy Officer by email to privacy.ANZ@assurant.com.

You may also escalate your complaint to the Assurant Global Privacy Office. Please write to us at 260 Interstate North Circle SE, Atlanta, Georgia 30339, USA or send an email to theprivacyoffice@assurant.com.

If you are not satisfied with our response, you may contact:

Australia

Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by phone on 1300 363 992.

New Zealand

Office of the Privacy Commissioner (OPC) at www.privacy.org.nz or by phone on 0800 803 909.

12. Updating Our Privacy Policy

We may update this Privacy Policy when our information handling practices change, or to account for new laws and technology. We will post the updated policy on our website and encourage you to check our website from time to time to view our current policy or contact us for a printed copy.

This Privacy Policy was last updated August 2026.