Privacy Policy

This policy applies to personal information handled through our websites, landing pages, contact and quote forms, telephone calls, SMS, email, social media, advertising platforms, customer portals, CRM systems, eligibility assessments, quotations, proposals, contracts, finance referrals, site inspections, installations, commissioning, rebate and certificate claims, quality assurance, audits, warranty and service work, complaints and dispute resolution.

Depending on your dealings with us, we may collect:

• Identity information such as your name, date of birth where required, signature and identity-verification details.
• Contact information such as residential or business address, installation address, email address and telephone number.
• Property information including ownership or occupancy status, landlord or owner authorisation, body corporate or owners-corporation details, rates notices where relevant, property type, site access and relevant building characteristics.
• Energy information including electricity or gas bills, National Metering Identifier (NMI) or other energy-account information where reasonably required, tariff information, usage patterns and existing equipment details.
• Eligibility information relevant to VEU, Solar Victoria, CER/SRES, rebates, loans, certificates, finance or other programs.
• Quotation, proposal, contract, invoice, payment, refund, cancellation, warranty, service and complaint information.
• Technical information about installed or proposed products, including brand, model, serial number, capacity, system design, inverter, battery, solar PV, heat pump, air-conditioning, electrical, plumbing and commissioning information.
• Installation evidence including photographs, videos, geolocation, date and time stamps, QR-code scans, certificates of electrical safety, plumbing compliance certificates, installer attendance evidence and other compliance evidence.
• Consent records, including the wording, method, date, time, source and scope of marketing, contact, program, installation, certificate-assignment, privacy and audit consents.
• Telephone call recordings, call notes, SMS or email records and other communications, where lawful and reasonably required for customer service, consent verification, quality assurance, training, dispute resolution, audit or compliance.
• Finance-related information provided to us or to a finance provider where you ask us to assist with a finance application or referral.
• Online information such as IP address, browser, device identifiers, cookies, analytics events, referral source, pages viewed and interactions with our websites or advertisements.
• Information reasonably required to investigate fraud, misuse, safety incidents, complaints, warranty claims, legal claims or regulatory matters.

We do not seek sensitive information unless it is reasonably necessary for our functions and permitted by law. Where consent is required, we will seek it before collecting sensitive information. If we collect a government-related identifier for a lawful verification, rebate, finance, program or compliance purpose, we will not adopt it as our own identifier and will only use or disclose it as permitted by law.

We generally collect personal information directly from you through enquiries, forms, calls, electronic communications, site visits, quotations, contracts, installation activity, support interactions, consent forms and program documentation. We may also receive information from an owner, landlord, tenant, authorised representative, referral partner, lead provider, installer, subcontractor, supplier, manufacturer, finance provider, electricity retailer, distributor or network service provider, auditor, certificate creator or agent, government department, regulator, scheme administrator, public register or another party involved in providing the requested service.

Where information is collected from a third party, we will take reasonable steps to ensure the collection is lawful and, where required, notify you of the collection and relevant circumstances.

Where practicable and lawful, you may make a general enquiry without identifying yourself or by using a pseudonym. We will normally require your real identity for quotations, contracts, property access, installations, finance, rebate or certificate claims, safety matters, warranty work, complaints, audits and other transactions connected with a specific person or property.

We may collect, hold, use and disclose personal information to:

• Respond to enquiries and provide information about our products and services.
• Assess suitability and eligibility for products, VEU activities, Solar Victoria programs, SRES/STCs and other incentives.
• Prepare quotations, proposals, designs, performance estimates, site assessments and contracts.
• Arrange site inspections, deliveries, installations, commissioning, servicing and rectification.
• Verify ownership, occupancy, consent, authority, eligibility and installation completion.
• Communicate with customers, installers, subcontractors, suppliers, manufacturers, network businesses, program administrators and professional advisers.
• Process payments, refunds, financing referrals, rebates, discounts, certificates and environmental benefits.
• Create, support, verify or audit VEEC, STC or other certificate claims and assignments.
• Administer product, manufacturer and workmanship warranties and after-sales service.
• Conduct quality assurance, telephone audits, field audits, compliance reviews and investigations.
• Meet obligations relating to electrical, plumbing, refrigeration, building, workplace safety and product safety.
• Prevent, detect and investigate fraud, duplicate claims, misrepresentation, misuse and security incidents.
• Handle complaints, disputes, chargebacks, legal claims and regulatory enquiries.
• Maintain records required by law, insurers, regulators, government programs and certificate schemes.
• Improve our systems, products, customer experience, staff training and service quality.
• Send direct marketing where permitted by law and by the consent or other lawful basis applicable to the communication.

If you participate in a Victorian Energy Upgrades activity, we may collect and retain information and evidence required by the Essential Services Commission, the Department of Energy, Environment and Climate Action, an accredited person, scheme participant, auditor or other authorised body. This may include signed or electronic consent, Statement of Rights acknowledgements, invoices, product and serial-number evidence, photographs, recordings, installation dates, installer details, customer declarations, property information, telephone-audit evidence and other records needed to demonstrate that the activity was lawfully undertaken and that any Victorian Energy Efficiency Certificates (VEECs) are valid.

Where VEU marketing contact requires express prior consent, we may retain records showing who obtained consent, who the consumer consented to be contacted by, the purpose and method of contact, the date and time, any nominated contact period, the source of consent and any withdrawal of consent. VEU cold-call telemarketing and doorknocking will not be conducted where prohibited.

Where VEU law requires records to be kept, VES may retain the relevant records for at least six years after the records were made or the completion of the transactions to which they relate, whichever is later, and for any longer period required by another applicable law, audit, investigation, warranty, insurance or legal hold.

Where you participate in a Solar Victoria program, information may be collected, used and disclosed to assess eligibility, submit or support an application, validate a rebate or loan, confirm completion, verify installer and retailer compliance, undertake safety and quality audits, resolve complaints, and meet program reporting and integrity requirements.

Relevant evidence may include quotations, invoices, system designs, performance estimates, DNSP pre-approval or export-limit information, installation evidence, QR-code scans, product warranty information, compliance certificates, customer declarations and other documents required by Solar Victoria.

For eligible systems under the Small-scale Renewable Energy Scheme, we may collect and disclose information necessary to create or support Small-scale Technology Certificate claims. Depending on the system, this can include retailer, designer, installer and owner statements, STC assignment forms, invoices, certificates of electrical safety or compliance, serial-number photographs, installer attendance photographs, critical labelling evidence, product information and other documents requested by the Clean Energy Regulator or a registered agent.

The Clean Energy Regulator may request supporting STC documents for up to five years after certificate creation. We may therefore retain relevant evidence for at least the period reasonably necessary to satisfy that requirement and any longer period required by another applicable law, warranty, insurance or program obligation.

VES may contact a person about an enquiry, quotation, requested service, existing contract, installation, delivery, site inspection, audit, warranty, recall, safety matter, complaint or other transaction where that contact is reasonably necessary to respond to the person's request or administer the relationship. This operational contact is separate from consent to receive promotional or lead-generation marketing.

Where marketing consent is required, VES will obtain and rely on consent only to the extent permitted by applicable law and program rules. Consent may be given through an online enquiry or contact form, a written or electronic consent form, email, recorded telephone request, or another method capable of establishing that the person freely and expressly agreed to the relevant contact.

For electronic marketing such as email or SMS, VES will comply with the Spam Act 2003 (Cth), including applicable requirements concerning consent, sender identification and a functional unsubscribe facility. A person may opt out of marketing communications at any time.

For telemarketing, VES will comply with the Do Not Call Register Act 2006 (Cth), applicable industry standards and any stricter VEU requirements. Where a person has withdrawn consent or another legal restriction applies, VES will not continue marketing contact merely because the person previously submitted an enquiry.

Opting out of marketing does not prevent VES from contacting a person where reasonably necessary to respond to an active enquiry or quotation, administer an accepted contract, arrange an agreed site visit or installation, provide safety or recall information, conduct lawful quality-assurance or audit activity, manage a warranty or service issue, handle a complaint, collect a lawful debt, or comply with a legal or regulatory obligation.

10.1 Express prior consent for VEU marketing by telephone or on-site visit

The Victorian Energy Upgrades program prohibits cold-call telemarketing and doorknocking for VEU lead generation or marketing. VES will only make a VEU marketing telephone call or marketing visit to a person's home or business premises where the person has provided valid express prior consent, or where another permitted exception under the VEU rules applies.

For VEU purposes, express prior consent means that the consumer has agreed in advance to be contacted by Vision Environmental Solutions Pty Ltd for the purpose of obtaining information about one or more prescribed VEU activities, or VEU activities generally, using the contact method covered by the consent.

Where a website or enquiry form is used to obtain express prior consent, VES may retain the form submission, checkbox state, consent wording displayed at the time, name, telephone number, email address, property address where relevant, date and time, IP/device or audit-log information where available, referral/source information and other evidence reasonably necessary to prove the consent.

10.2 What a VEU consent record may contain

To support VEU compliance and auditability, the consent record may identify:

• the identity of the consumer who provided the consent;
• Vision Environmental Solutions Pty Ltd as the business authorised to contact the consumer, and any other specifically identified organisation if the consumer expressly consents to that organisation;
• the VEU prescribed activity or activities about which the consumer agreed to receive information, or an express statement that the consent covers VEU activities generally;
• whether the consumer agreed to telephone contact, an on-site/home or business visit, or both;
• the date and time the consent was given;
• the period for which the consent is valid and its expiry date;
• the source and method by which the consent was obtained;
• where applicable, the date, time and method by which the consent was withdrawn; and
• a copy or reliable record of the consent wording presented to the consumer.

10.3 Duration and withdrawal of VEU express prior consent

Unless the consumer expressly agrees at the time of giving consent to a longer specified period, VEU express prior consent for marketing telephone calls or marketing visits is treated as withdrawn three months after the day on which the consent is given. If the consumer expressly specifies a longer period, the consent remains valid only for that specified period, unless withdrawn earlier.

A consumer may withdraw VEU marketing consent at any time by telling VES by telephone, email, SMS, web request or another reasonable method. VES will record the withdrawal and cease relying on that consent for future VEU marketing as soon as reasonably practicable. Withdrawal does not invalidate contact or other action lawfully taken before the withdrawal.

VES may ask the consumer to provide a fresh consent after an earlier consent expires. VES will not treat silence, inactivity, pre-ticked boxes or a previous customer relationship as fresh express prior consent where VEU rules require an affirmative opt-in.

10.4 Contact Us and enquiry forms

Where a person affirmatively ticks a consent checkbox on a VES Contact Us, enquiry, quote or eligibility form and submits the form, VES may rely on that affirmative action as evidence of the consent described beside the checkbox, subject to applicable law and VEU requirements. The exact scope of consent is limited to the wording shown to the person when the form is submitted.

A general agreement to the Terms and Conditions and Privacy Policy does not, by itself, authorise VEU telemarketing or an on-site marketing visit unless the form also clearly states that the person is expressly consenting to that type of VEU contact. Where VES intends to rely on a form for VEU express prior consent, the relevant contact methods and VEU marketing purpose will be stated clearly and the checkbox will require an affirmative action.

Submitting a form does not compel a person to participate in the VEU program, purchase a product or enter a contract. Participation remains voluntary, and the person may decline an upgrade or withdraw applicable marketing consent.

10.5 Contact by authorised contractors, installers and service providers

VES may use employees, installers, subcontractors or service providers to respond to an enquiry or administer an agreed service. This does not automatically authorise an unrelated third party to conduct its own marketing. Where VEU rules require the consumer to identify the person or organisation authorised to make a marketing call or visit, VES will not treat consent given only to VES as blanket consent for unidentified third-party marketers.

We may record or monitor telephone calls where lawful for quality assurance, training, evidence of instructions or consent, complaint management, fraud prevention, audit and regulatory compliance. Where notice is legally required, we will provide it. Recordings are restricted to authorised persons and retained only for as long as reasonably necessary or legally required.

Our websites may use cookies, pixels, analytics tools and similar technologies to operate the site, remember preferences, measure traffic and advertising performance, detect security issues and improve user experience. These technologies may collect device identifiers, IP address, browser information, referral details, pages viewed and interactions with advertisements. Where consent or notice is required for a particular technology, we will provide it.

We may disclose relevant personal information to:

• Employees, contractors, installers, electricians, plumbers, refrigeration technicians, designers and other scheme participants involved in your job.
• Product manufacturers, distributors, suppliers, warranty providers and service agents.
• CRM, cloud-hosting, email, SMS, telephony, document-signing, payment, accounting, analytics and cyber-security service providers.
• Finance providers and brokers where you ask us to assist with or refer a finance application.
• Electricity retailers, distributors, DNSPs, metering providers and network businesses where necessary for connection, export, metering or installation requirements.
• Solar Victoria and other Victorian Government departments or agencies.
• The Essential Services Commission and persons authorised to administer, audit or investigate VEU activities.
• The Clean Energy Regulator, REC Registry participants, registered agents, certificate creators and auditors.
• Solar Accreditation Australia, Energy Safe Victoria, the Building and Plumbing Commission, Consumer Affairs Victoria, WorkSafe Victoria and other regulatory bodies where relevant.
• Insurers, lawyers, accountants, auditors, consultants and other professional advisers.
• Courts, tribunals, law-enforcement bodies, regulators or other persons where disclosure is required or authorised by law.
• A prospective purchaser or adviser in connection with a genuine corporate transaction, subject to appropriate confidentiality and privacy safeguards.

Some technology or service providers may store, process or support information outside Australia. Where APP 8 applies, we will take reasonable steps required by law before disclosing personal information overseas. The location of cloud processing can change as providers change infrastructure, and further information about relevant providers or countries may be made available on request where practicable.

We take reasonable steps to ensure personal information we use or disclose is accurate, up to date, complete and relevant for the purpose. Customers must promptly tell us if relevant details change, particularly contact, property, eligibility, ownership or payment information.

We take reasonable technical, administrative and physical steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Measures may include access controls, authentication, audit logging, staff confidentiality obligations, vendor controls, backups, encryption where appropriate, secure storage and incident-response processes. No electronic system can be guaranteed to be completely secure.

We retain personal information only for as long as reasonably necessary for the purposes described in this policy and to satisfy legal, tax, warranty, insurance, audit, certificate, program and dispute-resolution obligations. If a complaint, investigation, audit, litigation hold or regulatory request is active, relevant records may be retained until the matter is finally resolved. When information is no longer required and there is no lawful reason to retain it, we will take reasonable steps to destroy or de-identify it.

We maintain processes to identify, contain, assess and respond to suspected data breaches. Where the Notifiable Data Breaches scheme applies and an eligible data breach occurs, we will notify the Office of the Australian Information Commissioner and affected individuals as required by law.

You may request access to personal information we hold about you or ask us to correct it. We may need to verify your identity. We will respond within a reasonable period and may refuse access or correction only where permitted by law. Where required, we will provide reasons and information about how to complain.

Privacy complaints may be made using the contact details below. We will investigate the complaint fairly and respond within a reasonable period. If you remain dissatisfied, you may contact the Office of the Australian Information Commissioner. A privacy complaint that is also connected with a VEU, Solar Victoria, installation, warranty or consumer issue may also be handled under our Cancellation and Refund Policy and its complaint and dispute-resolution process.

We may update this Privacy Policy from time to time to reflect changes in our business, technology, regulatory obligations or program participation. The version published on our website, together with its effective date, is the current version.

Privacy Officer — Vision Environmental Solutions Pty Ltd

ABN 29 639 946 115

Phone: 1300 669 789

Email: [email protected]

Address: Level 26, 360 Collins Street, Melbourne VIC 3000