Privacy Policy
About this Policy
This is the privacy policy of 4 Square Energy Pty Ltd (ABN 51 672 306 928, AFS Representative No. 001309061) (‘4 Square’, ‘we’ or ‘us’). This Privacy Policy applies to all information collected by us, including via any of our websites at the domain www.4square.energy (‘website’).
Application of this Policy
The purpose of this Policy is to ensure that any individual who provides personal information to 4 Square is protected under Australian law in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act) and any other relevant laws. Words defined in the Privacy Act have the same meaning when used in this Policy.
Collection of Personal Information
When we refer to personal information, we mean information from which your identity is reasonably apparent.
Information We Collect From You
The main way we collect personal information from you is when you interact with us. For example, when you:
- Email, call or mail us;
- Engage with a service we offer or invest in a product we promote;
- Make an enquiry about our services or the products we promote;
- Register your interest in receiving information about our services or the products we promote;
- Insert information into one of our forms;
- Ask to be placed on one of our mailing lists;
- Visit our websites;
- Contact, register with, post to, like or follow any of our social media pages;
- Register for our events; or
- Participate in our competitions, promotions or surveys.
If you provide the personal information of another person in any correspondence with us, you warrant that that person has consented to the collection of their personal information for the reasons it is being collected.
The details of exactly what types of personal information we collect can be found in our disclosure documents, on our forms and websites, and in the questions we ask when we communicate with you.
Information We Collect From Other Parties
We may also collect information about you from other parties such as credit reporting agencies and identification verification services.
Sensitive Information
We may collect sensitive information about you. Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, health, political opinions, religion, trade union or other professional associates or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.
Your sensitive information may only be used and disclosed for purposes which are directly related to the primary purpose for which the sensitive information was collected, including:
- for the purpose of us maintaining a comprehensive company file;
- for the purpose of data compilation or analysis for internal purposes (for example, as part of our ESG framework); and
- in an anonymised format for the purpose of data compilation or analysis to share with third parties.
Sensitive information may also be used or disclosed if required or authorised by law.
Holding and Retaining Your Personal Information
We take reasonable precautions to protect and secure your personal information from misuse, interference and loss, as well as unauthorised access, modification and disclosure.
Your personal information is stored electronically on secure systems provided by cloud service providers. Access to these systems is restricted and controlled via passwords, encryption and firewalls in line with Australian information security standards. Where your personal information is held in hard copy form, these paper files are archived in a secure facility.
Access to your personal information is limited to those individuals or entities who require your information to perform a specific task or function.
Your personal information is only retained for as long as necessary to fulfill the purpose/s for which it was collected, unless we are required to retain the information for a certain period of time under an Australian law or court or tribunal order. Once no longer required, we take such steps as are reasonable in the circumstances to destroy or permanently de-identify your personal information.
Use of Personal Information
We use the personal information we have collected about you in order to:
- Perform administrative and operational functions associated with providing you with access to our services and the products we promote;
- Contact you to provide you with information about our services and the products we promote;
- Contact you to conduct product and market research, surveys and other promotions; and
- Comply with our legal obligations.
Our Privacy Policy explains:
- Why we are collecting the information;
- How we intend to use it;
- If we are likely to disclose your personal information to overseas recipients;
- The consequences if the personal information is not collected;
- How you may access and correct your personal information;
- How you can opt-out of having your personal information used (if appropriate); and
- How you can make a complaint about a privacy breach.
What Happens If You Choose Not To Provide The Information?
You do not have to give us your personal information. However, if you choose not to, we may not be able to provide you with information or access to our services or the products we promote.
Disclosure of Personal Information
We will not disclose information we collect about you to any third parties without your prior consent. Similarly, we will not sell any information we collect about you.
However, we may disclose personal information for the purpose specified to you at the time of collection or for other purposes if:
- You would reasonably expect us to disclose such information for that purpose;
- That purpose is related to the purpose specified to you at the time of collection, or;
- Where we are permitted or required by law, or it is in the interests of public safety to do so.
For instance, in the course of conducting our business we may disclose your personal information to:
- Our related companies;
- Employees, contractors and subcontractors;
- Your representatives;
- Government and regulatory authorities;
- Our professional advisers, including our lawyers, auditors and accountants; and
- Our Licensee relating to our Australian Financial Services authorisations. 4 Square is a Corporate Authorised Representative (AFS Representative No. 001309061) of True Oak Investments Ltd (ABN 81 002 558 956, AFSL 238184).
We may disclose your personal information to our third party service providers when we engage them to undertake works as part of our services to our clients, including those who provide us with:
- Mailing services;
- Billing and debt recovery functions;
- Marketing functions; and
- Website, data management and technology services.
Disclosure Overseas
Some of our communications service providers may be located outside of Australia, meaning your personal information may be disclosed to a recipient in other countries.
In addition, anonymised web traffic information is disclosed to third party analytics platforms when you visit our websites (who may store the information across multiple countries) and when you communicate with us through our social media applications, where the provider and its partners may collect and hold your personal information overseas.
We will not disclose your personal information to overseas recipients unless and until we have taken reasonable steps to ensure that the overseas recipient will handle your personal information in a manner consistent with the APPs, or you have consented to the transfer of the information.
Direct Marketing
We may use your personal information to contact you with new information or offers for products or services from us and our partners. Your personal information will never be added to a general marketing database. We do not sell, rent or trade your personal information to or with third parties for the purpose of allowing them to send marketing material directly to you.
If you don’t wish to receive marketing material, you may opt out by contacting us by email at info@4square.energy
Privacy on the Internet
The Internet is not a secure environment. If you use the Internet to send us personal information you do so at your own risk.
Website Cookies
We make use of “cookies” technology on our website. Cookies are small data files transferred onto your computer or electronic devices which tells us when you visited our website, the pages you visited and the information you downloaded. We use cookies to improve the functionality of our website and to learn more about the way that you interact with our content. Cookies are a feature of your Internet browser which you can disable at any time.
Links to Other Websites
You may be able to access external websites, apps or platforms operated by third parties by clicking on links provided on our website. These links are provided for convenience and may not remain current or be maintained. In addition, these websites, apps and platforms aren’t subject to our privacy standards and procedures.
Once you leave our website, our privacy policy no longer applies. You’ll need to review these websites, apps and platforms directly to view a copy of their privacy policies and to ensure your personal information is protected.
Social Media Applications
Whilst we may use social networking platforms for communications, we won’t ask you to supply personal information publicly over these platforms. Sometimes we’ll invite you to send your details to us via direct message, for example, if you have made a complaint via social media and we need to know how to contact you.
Any personal information that you contribute to the publicly accessible sections of social media applications can be read, collected and used by other users of the application. We have little or no control over these other users and cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with our privacy standards.
Data Analytics
We may analyse customer information we hold against information we are permitted to use from external sources such as statistical data. Generally, this information is based on aggregated data that doesn’t contain information that identifies individuals.
You Can Access and Correct Information
We take all reasonable steps to ensure that the personal information which we collect, use or disclose is accurate, complete and up to date.
If you think that the personal information that we hold about you is incorrect, please contact our Privacy Officer via email to info@4square.energy. You can also request that certain personal information we hold about you be deleted.
We reserve our right to refuse your request for access to, or correction or deletion of, your personal information if, for example, we consider your request to be frivolous or vexatious, or if we are legally entitled to do so. If we refuse your request, we will give you our reasons in writing and information about how to make a complaint about the refusal.
When You Contact Us
We must be certain of your identity before we can discuss specific account details with you. If you contact us to discuss your account, you must be able to prove your identity. This ensures that we are able to protect your personal information by only giving it to you or someone who can prove that they are lawfully authorised to act on your behalf.
If you have a general enquiry that does not involve discussing your personal information, you do not have to provide identification. In these situations, you will be able to deal with us without identifying yourself.
Data Breaches
We are required by the Privacy Act 1988 to notify you and the Office of the Australian Information Commissioner (OAIC) in the event of an eligible data breach occurring. For example, if a database containing your personal information is hacked or your personal information is mistakenly provided to the wrong person, and we have not been able to prevent the likelihood of serious harm to you because of the breach.
Our notification to you will be sent as soon as practicable and will contain:
- A description of the data breach;
- The kinds of information concerned;
- The steps we have or will take to rectify the data breach; and
- Recommendations about the steps you should take in response to the data breach.
Complaints Handling
If you are dissatisfied or have a complaint about our privacy practices, we encourage you to contact us to tell us about your complaint.
The Complaints Officer
4 Square Energy Pty Ltd
Email: info@4square.energy
We’ll acknowledge your complaint within one business day of its receipt.
Your complaint will be investigated, and action will be initiated to address the matter. The Complaints Officer will write to inform you of the results of the investigation and the proposed resolution, no later than 30 calendar days after receiving your complaint.
If you’re not satisfied with our response or you have not received a response within the required timeframe, you may be able to refer your complaint to the Australian Financial Complaints Authority (AFCA), an independent dispute resolution service established by the Government.
Australian Financial Complaints Authority
GPO Box 3 MELBOURNE VIC 3001
Phone: 1800 931 678
Email: info@afca.org.au
Website: www.afca.org.au
Time limits may apply to complain to AFCA and so you should act promptly or otherwise consult the AFCA website to find out if or when the time limit relevant to your circumstances expires.
Complainants are encouraged to pursue internal dispute resolution before making a complaint to AFCA.
More Information About Your Privacy Rights
If you would like more information about your privacy rights, you can contact the Office of the Australian Information Commissioner (OAIC).
Attention: Director of Compliance (Investigations)
Office of the Australian Information Commissioner
Post: GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Updating Our Privacy Statement
We may revise or update our privacy statement occasionally by posting it on our website. The current version at the time we collect or use your personal information is the version that will apply.
Effective: 22 May 2024