Privacy Policy

Pet Circle | 2011-2022 Millell Pty Ltd | ABN: 17 148 151 213

Level 7/9 Castlereagh St, Sydney NSW 2000, Australia

Millel Pty Ltd trading as Pet Circle and Pet Circle Insurance (we, us, our) maintains a thorough commitment to your privacy and protecting your personal information. Our privacy policy outlines our approach to privacy and how we collect, use and protect your personal information. It also sets out your rights in relation to accessing the personal information we collect and hold about you. We are bound by the Australian Privacy Principles (or APP’s) in the Privacy Act 1988 (Cth).

By visiting our website for purchasing goods; using an insurance portal, authorising an insurance intermediary or referrer to provide us with your Personal Information otherwise providing us with your Personal Information, you consent to your Personal Information being collected, stored, used and disclosed by us as set out in this privacy policy.

This website may contain links to third party websites. As we are not responsible for how these third party websites collect, use and store your information, we recommend you review their privacy policy prior to accessing and/or using their website.

Pet Circle collects personal information to purposefully conduct our business and services as a pet services and e-commerce organisation. Any personal information we collect is done so when you perform a transaction on our website, register, subscribe to our newsletter or contact us.

Personal information we do collect includes your:

• Full name;
• Residential, billing and/or business postal address;
• email addresses;
• bank account, credit card and/or other payment details;
• Any information that you provided to us by you during your account creation process or added to your user profile;
• Any information collect when you place an order via a Website or an application to purchase goods and/or services;
• preferences and password for using this site and your computer and connection information; and
• any information that you otherwise share with us.

All personal information that we collect will be done so in a lawful and unobtrusive manner.

Pet Circle does not store credit card numbers. These are securely held by a large third-party payment processors.

We may collect information in various ways depending on the nature of services being provided and administered, including, but not limited to:

• directly from you via our websites;
• When you place order or an enquiry through our website or application
• through our insurance related portal;
• by telephone;
• in writing;
• by email; and/or
• from third parties (such as social media sites and other data providers, your insurance broker, premium funders, claims managers, other service providers or publicly from available sources). Each third party is also obliged to comply with the applicable privacy principles.

Should you decide to provide us with information willingly without us explicitly asking for it or needing it as part of a request, we will not hold such information and all effort will be made to de-identify this data.

This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. We collect IP addresses as part of the service of providing internet session management and for security and site experience purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.

Upon visiting our website, cookies may be placed on your browser to allow you to login to your account, maintain a shopping cart, retrieve an insurance quote or purchase items in your shopping cart. Pet Circle may use this information to provide you with a better user experience and more relevant advertising and marketing messages.

This site uses cookies tracking pixels, Internet tags or web beacons, and navigational data collection (log files, server logs, and clickstream data) (Cookies) in order to:

• remember your preferences for using this site;
• manage the signup process when you create an account with us;
• recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;
• facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process;
• show relevant notifications to you (eg, notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services);
• collect demographics and interest data; and
• remember details of data that you choose to submit to us (eg, through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).

By using the website and agreeing to this policy, you grant us permission to place and store cookies on your browser. Cookies collect limited information regarding your browser type, IP address, web pages visited and web page statistics. We do not collect or use any information during this process that could identify you as an individual. The information is anonymous and is used to support customised digital advertising and reporting. Additionally, third parties we have contracted to provide services on our website (such as PayPal) may place and read cookies on your browser.

All personal information we collect, use and disclose, will only be done so to fulfil the purpose for which it was collected and in accordance with this Privacy Policy. Our use and disclosure of your personal information is for the purpose of enabling us to function as an e-commerce business and provide products and services and delivering you a better user experience.

As part of our e-commerce business, and administering insurance products and services to you, we may collect information for a broader or more specific purpose which may include:

• Providing any goods and or services purchased via our website, or application
• Arranging for delivery of products purchase including liaising with couriers;
• Facilitating payment for products and services purchased
• Dealing with customer enquiries and communicating with you regarding your requests and feedback;
• Processing returns or refunds in accordance with our return policy and product recalls as may be required from time to time;
• helping us assess risks, to assess your request for insurance, to write and administer your insurance policy and any claim you may have and to clarify or assess information that you have provided;
• to help us improve our products and services including website usage analysis;
• providing customers and potential customers with our products and services;
• helping to develop and identify products and services that may interest customers, potential
• customer, and brokers and their customers, potential customers or others;
• billing and debt-recovery functions;
• carrying out administration, planning, account security, fraud detection and loss prevention activities, procurement, product and service development, quality control and market and customer research (including data and trend analysis and matching), to improve the way we provide products and services to you;
• marketing, telemarketing and sales services including providing you with offers and information regarding our products and services including entering you into competitions we offer our customers from time to time;
• developing, establishing and administering alliances and other arrangements with organisations not related to us in relation to the promotion, administration and use of our products and services;
• Maintain the functionality of the Website and any other digital platform such as the Pet Circle App
• As may be required for legal, technical or administrative purposes;
• To maintain our relationship with you including telling you about promotions and our other product and service offerings which we believe may be relevant to you; and
• any other purpose notified to you at the time your personal information is collected.

Personal information will only be used for marketing purposes if you have given either express or implied consent. Implied consent is assumed when signing up to use our site, registering your email address, or participating in any promotions which require you to disclose your email address.

When registering or purchasing from Pet Circle, you consent to Pet Circle using your personal information, such as your email address and other associated information, to provide you with offers and information regarding our products and services. All digital communications will comply with the requirements of the Spam Act 2003 (Cth).

If at any time you do not wish to receive any further such communications, you may ask us to not send those to you or disclose your information to third party organisations for that purpose by using the “unsubscribe” facility in direct marketing communications or by contacting us using our contact details below.

We will not sell or trade your Personal Information for marketing or any other purpose.

We will only disclose your Personal Information where it is required or reasonable to provide or administer a product or service that you have requested, or for any of the purposes outlined in this privacy policy. Where appropriate, we will disclose your personal information to:

• our related body corporates, your broker or third parties as is required in order to provide our products and services, including our external service providers, such as payment system operators, lawyers, accountants, other advisers, financial institutions and information technology providers;
• Third party advertisers; to deliver ads that are related to our products and services that are targeted and personalised to your interests, attributes, preferences and experiences on the Platforms or other websites, apps or online platforms;
• To our delivery partners to fulfil and deliver your purchases;
• to agents, insurer underwriters; insurers, reinsurers, other insurance intermediaries, insurance reference bureaus and industry bodies and groups;
• claims management and related service providers;
• the Australian Financial Complaints Authority or other alternative dispute resolution schemes;
• administrative service providers;
• government and regulatory authorities and other organisations, as required or authorised by law;
• your authorised representatives or legal advisers (when requested by you to do so);
• credit-reporting and fraud-checking agencies;
• credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);
• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others; and/or
• any other entities notified to you at the time of collection.

You authorise us to contact such third parties for the purposes of providing you with the products and services that you have requested.

Other than when required or permitted by law, as specified in this privacy policy or where you have provided your consent, we will not disclose your Personal Information for any other purpose. Nothing in this privacy policy prevents us from using and disclosing to others de-personalised data.

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

• be unlawful (eg, where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
• have an unreasonable impact on another person’s privacy; or
• prejudice an investigation of unlawful activity.

We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.

If we refuse to give you access, we will provide you with reasons for our refusal.

We take responsible steps to ensure that your Personal Information is accurate, complete and up-to-date whenever we collect, use or disclose it. However, we also rely on you to advise us of any changes to your Personal Information. All Personal Information identified as being incorrect is updated in our database.

Please update your details by logging into your account, contact us using our contact details below as soon as possible if there are any changes to your Personal Information or if you believe the Personal Information we hold about is not accurate or complete. We may refuse to correct Personal Information if the correction would not improve the accuracy, completeness, relevance or would make the information misleading.

When using, collecting and storing your personal information, we take every step to ensure that this is done so in a secure manner. All reasonable steps are taken to ensure that your personal information is not accessed, disclosed or collected by any unauthorised persons or third parties.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

However, data protection measures are never completely secure and despite the measures we have put in place, we cannot guarantee the security of your Personal Information. You should notify us as soon as possible if you become aware or suspect any security breaches.

If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us using the following contact details:

For Pet Circle related enquiries please direct those to Privacy@Petcircle.com.au or by phoning us on 1300 60 80 03.

Postal Address: Level 7, 9 Castlereagh Street Sydney NSW 2000

For Insurance related enquiries please direct those to

Privacy@PetcircleInsurance.com.au or by phoning us on 1800 951 130.

Postal Address: Level 7, 9 Castlereagh Street Sydney NSW 2000

If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Federal Privacy Commissioner’s website (see www.privacy.gov.au).

Our Privacy Policy may change from time to time as updated on this website. We maintain an obligation to inform you of said changes via digital written communications (email). Before providing us with Personal Information, please be sure to read this Policy on our website for any changes.

Privacy Policy last updated 31/01/2023