Privacy Statement

Gold Cross Products and Services Privacy Policy

1. Gold Cross Products and Services Privacy Policy - what you should know

We understand that keeping your information confidential and secure is important to you, and it is very important to us too. To help you understand how we collect, use and share your information, we have developed this Privacy Policy. This Privacy Policy (we refer to it as the 'Policy') sets out how Gold Cross Products and Services ('Gold Cross', 'we', 'us' and 'our') manages the collection, use, disclosure and security of personal information in line with the Privacy Act 1988 and the Australian Privacy Principles.

2. Why have a Privacy Policy?

So we can provide products and services to you, Gold Cross needs certain personal information to be collected, used, disclosed and retained. The type of information required will vary depending on the services and products we provide. It is important that you understand what type of information we need to collect and what processes we have around how we collect and manage your information.

By law, we are required to make our Policy available to the public.

Throughout this Policy, personal information handled by us can be classified into two categories:

  • Personal information is information that identifies or could identify a person. For example, a name, address or other contact details.
  • Sensitive information is information or an opinion that has been classified in the Privacy Act as sensitive information. It includes, but is not limited to, information on your health, criminal record, insurance history, membership of a professional or trade association, and Tax File Numbers.

To make things easier, when we mention 'personal information' it also includes sensitive information unless we specify otherwise.

3. Who's responsible?

We take the privacy of your information seriously and have made a number of people in our organisation responsible for ensuring this Policy is implemented and managed appropriately.

In particular, we have nominated a Privacy Officer who is responsible for the implementation of this Policy.

4. Our privacy processes

There are six processes that cover how we manage your personal information. These include:

  1. How we collect your personal information
  2. How we use and disclose your personal information, including through automated decision making
  3. How we store your personal information
  4. How we manage a request to disclose your information overseas (called Cross Border Disclosure)
  5. How you can access and correct your personal information
  6. How we handle complaints

To help you better understand what is involved with these processes, we have provided more information below.

4.1. Collecting your personal information

So we can provide our services to you, we need to obtain certain personal information from you. We only collect the following personal information where necessary. This can include your:

  • Name, date of birth and contact details
  • Employment information such as:
    • your employment details
    • your professional registration details
    • association membership information; and
    • other relevant details relating to your profession

You have the option of choosing not to provide all or some of the information requested, though this may impact our ability to provide our services.

You have the option of not identifying yourself, or of using a pseudonym, when dealing with Gold Cross in relation to the following matters:

  • When you browse our websites, Gold Cross does not collect your personal information
  • You can make a general inquiry without providing your personal details by telephone.

How we collect your personal information

We will only collect your personal information by lawful and fair means and, unless legally specified, only if you consent to the collection, through:

  • Phone, which may include recording telecommunications with your consent
  • Online forms, portals and tools, which include application and feedback forms that may include your Internet Protocol (IP) address
  • Email when you provide information via email, or ask to be on an email list, including the email address itself; and
  • Written material, in particular order forms, when you provide information in writing or by facsimile.

At times it may be impracticable or unreasonable to collect personal information directly from you. In these cases, and with your consent, personal information may also be collected from the following third parties:

  • Third parties you refer us to so we can obtain your personal information
  • Information that is available publicly
  • Related companies
  • Industry and professional associations

In some circumstances we may access mailing lists to acquire new customers or conduct market research. We use reputable mailing list companies that are also bound by the Privacy Act. We do not keep a record of any information about you from those lists unless you contact us. The information on those mailing lists remains the property of the company from which the list was provided.

4.2. Using and disclosing your personal information

Unless you have agreed, we will only use and disclose your personal information for:

  • The purpose for which it was given to us; and
  • Related purposes that you would reasonably expect.

We use and disclose personal information for the following purposes:

  • To verify your identity
  • To evaluate, effect, manage and administer the services provided by us
  • To inform you of other products and services offered by entities within the Guild Group of companies, any related entity or your representative. This includes marketing and promotion by direct mail, telemarketing, email, SMS and MMS messages. However, you may opt out of receiving direct marketing at any time
  • To use your personal information in automated processes, including computer programs and algorithms, to make or assist us to make certain decisions about you in connection with our products and services
  • When engaging third-party providers to perform services for Gold Cross that involve those third parties handling personal information
  • To research, develop and improve our services, including testing and improving systems for the management of the services provided
  • For security and audit purposes, service monitoring, internet traffic monitoring, troubleshooting and maintenance, and to protect against and identify security breaches, inappropriate behaviour, fraud and unauthorised access to the IT systems of either customers or Gold Cross
  • For communication purposes where contact details are received by us because you sent these to enable us to respond to your request
  • To and from your professional association for the purposes of administering and improving our services; and
  • Where required to do so by law.

4.2.1. Use of Automated Decision Making (ADM)

We may use automated processes, including computer programs and algorithms, to make or assist us to make certain decisions about you in connection with our products and services. Subject to confirmation of Gold Cross operational practices, these processes may be used in relation to:

  • eligibility for, or access to, a product or service
  • pricing, fees or other terms associated with a product or service
  • the processing, routing or prioritisation of applications, orders, enquiries or service requests; and
  • the identification or assessment of suspected fraud, security risks or unusual activity.

The automated processes we use may involve handling personal information about you, including:

  • information you provide to us, such as information in an application, order, enquiry or service request
  • information we obtain from third parties, such as service providers or publicly available sources; and
  • information generated or inferred by our systems, such as scores, indicators, recommendations, flags or assessments.

These processes may substantially assist our staff in making decisions, including by providing recommendations, scores, flags or assessments that are directly relevant to the decision.

Impact on you

Some automated or substantially automated decisions may significantly affect your rights or interests, including:

  • whether we provide you with a product or service and on what terms
  • the price, fee or other terms offered to you; and
  • how an application, order, enquiry or service request is processed.

Oversight and review

Where appropriate, we implement human oversight and review processes in relation to these automated systems.

You may contact us using the details below if you would like more information about how a decision was made or to request a review of a decision.

4.3. Storing your personal information, data retention and destruction

Ensuring the security of your personal information is very important to us, and we take all reasonable steps to store it in a way that protects it from misuse, loss, unauthorised access, modification or disclosure.

To support the protection of personal information, we have implemented a number of policies and processes, including but not limited to confidentiality requirements for employees, security measures for building and systems access, firewalls and other security measures for online systems.

Generally, hard and soft copy documentation is held in filing or on IT systems securely on Gold Cross premises. For archiving and back-up purposes, documentation may also be held in secure and professional offsite storage facilities.

We retain personal information for as long as it is required for business or statutory purposes. Once personal information is no longer needed, we take reasonable steps to securely destroy or de-identify it in accordance with applicable laws and regulations.

We regularly review our information storage and destruction processes to ensure that your personal information remains protected.

4.4. How we manage cross-border disclosure

Generally, Gold Cross will not be required to disclose personal information to overseas recipients.

However, personal information may be provided to overseas recipients providing offshoring operational and administrative functions in the Philippines under locally incorporated subsidiary Guild Solutions Inc (GSI). These functions comply with Guild Group policies and procedures.

If disclosure overseas is required, we take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles and handles an individual's personal information in accordance with Australian law.

4.5. How you can access and correct your personal information

You have the right to access your own personal information held by us and, where it is incorrect, to request that we correct the information.

4.5.1. Accessing your personal information

To access personal information, contact us by phone or in writing and request the personal information we hold on file in relation to you. The contact details are outlined below. We will provide access to the information fairly and efficiently, in an appropriate format and within a reasonable timeframe agreed with you.

There may be exceptional circumstances where we cannot provide you with access to your personal information for reasons outlined in the Australian Privacy Principles. In these cases, we will advise you in writing why we cannot provide the information and the mechanisms available should you want to lodge a complaint.

4.5.2. Correcting your personal information

If you believe we hold incorrect personal information, you can notify us using the contact details below.

If the information is confirmed to be incorrect, we will correct it as quickly as possible and confirm that the correction has been made.

In exceptional circumstances where we receive a request to correct your personal information but are unable to implement the correction, we will advise you in writing of the grounds for refusal and the mechanisms available should you wish to lodge a complaint.

4.5.3. Third-party service access and logins

Where you are using our services and have chosen to connect your social networks to the services, or if you authorise a third-party service to access your account, you agree that information about you may be provided to those social networks and third-party services under their respective terms and privacy policies. For example, if you choose to connect your Google account, the Google Privacy Policy will apply to you.

Removing access or data from added services

When using our services, you may access, update or correct most of your account information by logging in to your account to edit your profile or organisation record.

If you have requests that cannot be carried out by logging in to your account, such as accessing additional information or deleting information about you in relation to Gold Cross services, please complete our data privacy form.

Please note that we may need to retain certain information about you in order to continue providing the services you have requested.

Requests to access, correct, update or delete your information can be made in writing and will be handled within thirty (30) days unless they are unusually extensive or complex, in which case we will advise you of the expected timeframe for handling your request.

Removing access yourself

If you have authorised us to access your social network account or third-party platform to provide services such as a website login, you may revoke this access at any time by following the instructions provided by:

4.6. How we handle complaints

If you believe we have breached this Policy or not adhered to the Australian Privacy Principles, you have the right to lodge a complaint. We have a formal complaints and dispute resolution process in place that is fair, efficient and accessible to everyone.

To lodge a privacy complaint, you can contact us by phone or in writing using the contact details outlined below, or by using the feedback options on our websites.

Our complaints and dispute resolution process is available at no cost to you. We will keep you informed throughout the process and provide a formal response to the complaint.

At any time, or if after receiving the initial response you are not satisfied with the response, the privacy complaint can be escalated to the Privacy Officer using the contact details outlined in section 4.7.

Alternatively, you may lodge a complaint with the Office of the Australian Information Commissioner using the following details:

4.7. Contacting us

To access personal information, request a correction, ask about an automated decision or request a review, or lodge a privacy complaint, you can contact us as follows:

  • By phone during office hours on (02) 6270 8950
  • In writing to: Gold Cross Products and Services, Locked Bag 32010, Collins Street East, VIC 8003

5. Reviewing this Policy

This Policy is reviewed annually to help ensure that changes affecting us are included on an ongoing basis. This Policy may also be reviewed more frequently if circumstances such as legislative changes occur that impact it.

Last updated: September 2026