Privacy Policy

Issue Date: 16 December 2025

1. Purpose

NobleOak Life Limited is a registered friendly society under the Life Insurance Act. NobleOak is regulated by the Australian Prudential Regulation Authority (APRA) and the Australian Securities & Investments Commission (ASIC).

This Privacy Policy (Policy) explains:

• why we need to collect your information;
• what information we collect and how we will collect your information;
• how we will use and disclose your information;
• how we store and secure your information;
• how you can access information we hold about you and how you can correct that information; and
• where to direct any requests for information or complaints about our information handling practices.

2. Scope

This Privacy Policy applies to NobleOak Life Limited and its subsidiary companies, including all its directors, employees, contractors and agents.

NobleOak requires its directors, employees, contractors, and agents (wherever they are located) to comply with this Privacy Policy and the Australian Privacy Principles (APPs).

3. Definitions

Personal information includes information or an opinion about an identified individual or an individual person who is reasonably identifiable.

Sensitive information includes medical and health information about an individual.

NobleOak is bound by the Privacy Act 1988 (Cth) (Privacy Act), including the thirteen Australian Privacy Principles (APPs) which protect personal information. NobleOak respects your right to privacy and values the trust you place in us to manage your personal and sensitive information.

4. Collection of personal information, including sensitive information

NobleOak only collects personal information necessary to assist us in providing a service to you and your family/employees. When you provide your personal information to us, you are consenting to its use in accordance with this Policy.

We retain a record of:

• Personal information that identifies you, such as your name, date of birth and address, your financial institution details, your vocational and your lifestyle pursuits;
• Sensitive information about you including, amongst other things, health information for the purposes of assessing applications and claims under life insurance products. We will obtain your consent before we collect sensitive information about you, unless we are otherwise permitted by law to make the collection;
• Information from other service providers we use in the life insurance application process and administration of your Life insurance cover, such as medical practitioners, pathologists, and other service providers we use for the purposes of assessing your life insurance application and managing any claim;
• If you are a client utilising our Wealth Maximiser wealth service, we use information necessary for NobleOak Services Limited (NOS) to provide wealth coaching services, for example information detailing your income, expenses, assets and liabilities.

We may collect personal information, including sensitive information, directly from you or from your nominated treating doctor or other health provider. If we are required to collect personal or sensitive information from third parties, we will ask for your consent to do so.

The Privacy Laws provide individuals with the right not to identify themselves or use a pseudonym when transacting with organisations. When applying for Life insurance, it is not practicable for a Life insurance company to allow a person to remain anonymous or the use of a pseudonym, due to life insurance industry risk selection requirements.

5. Use and disclosure of personal information

NobleOak will use or disclose personal information that you provide to us for the primary purposes of:

• assessing and providing your insurance cover or wealth advisory services;
• managing your policy including any claims;
• another purpose which has been disclosed to you, with your consent; or
• if we are required or authorised by law to do so.

NobleOak may also disclose personal information (not sensitive information) to a third party with whom we have marketing or distribution arrangements for our insurance products or Wealth Maximiser wealth coaching service, with your express consent.

We may disclose your personal and sensitive information to appointed service providers, with your consent, where this information will assist with processing your life insurance application and any changes you seek to make to it. You can also request that we disclose information to another person on your behalf.

We may also use your information to develop insights and conduct data analysis to improve the delivery of our services and products, and for this purpose, we may provide it to third party organisations, such as those that conduct surveys, customer reviews or ratings on our behalf.

When we do this, the data we provide will be limited to the minimum data required for that activity and those companies are required to keep the information secure and confidential and only use it for the agreed purpose.

If you are a client utilising our Wealth Maximiser wealth coaching service: Any information provided to NobleOak in connection with your NobleOak insurance policy will not be used for the purposes of NobleOak Services providing wealth advisory services, unless we have your express consent to do so.

If you provide personal information (including sensitive information) to us through online forms through our website, the information you provide will be held by a third party, (EasySend) who provides us with the functionality. The information is held only momentarily by EasySend on a secure Amazon Web Services cloud platform (based within Australia) for the purpose of being transmitted to us.

We will take reasonable steps to ensure that third parties to NobleOak are also bound by the Privacy Act, confidentiality and non-disclosure principles and are prohibited from using your personal information for any other purpose than those described in this Policy.

6. Cross border disclosure of information

NobleOak is committed to handling your personal information in accordance with the Privacy Laws and the APPs. Currently all client personal and sensitive information is stored in Australia with minor exceptions detailed below.

If you are the holder of the Professionals Choice insurance product issued through the PPS Mutual Benefit Fund, your personal information is stored in Australia and accessed by secure network by the PPS Mutual Benefit Fund Administrator, the Professional Provident Society in South Africa. Your information is handled in line with the requirements of Australian Privacy laws, the APPs and NobleOak and PPS Privacy Policies.

If you are a member of the Neos Benefit Fund and have a claim, some of your personal information including your name, tax file number, date of birth and bank account information may be stored in an encrypted accounting system located in the United States.

7. Government-related identifiers

NobleOak will not use Government-related identifiers (such as a Medicare number) as our reference number for you in our systems. We will only use or disclose any government identifier that you provide to us as required (such as to assist with a claim assessment) or where authorised by law.

8. Security

NobleOak will take reasonable steps to protect personal information from misuse, loss, unauthorised access, interference, modification, and disclosure. All information entrusted to us is securely stored in physical and/or electronic form.

Where we no longer require your personal information, we will take reasonable steps to destroy or permanently de-identify that information.

NobleOak has internal procedures which require our employees to ensure the safe handling and storage of all private and sensitive information.

A data breach occurs when personal information is accessed or disclosed without authorisation. In the event that such a breach occurs, NobleOak will assess the impact of the breach and if there is the likelihood of any serious harm to you then we will contact you about the breach and advise of corrective action we have taken including reporting the breach to the Office of the Australian Information Commissioner (OAIC), where required

9. Access and correction of information we hold about you 

NobleOak is committed to keeping up-to-date records of your personal information. We will take reasonable steps to ensure that any personal information collected, used, or disclosed by us is accurate, complete, and up to date.

You may request access to your information from NobleOak at any time by contacting the NobleOak Privacy Officer via email at: [email protected]. NobleOak commits to responding to any access or correction request in a timely manner.

If you establish that personal information held by us is not accurate, complete, relevant, up-to-date or is misleading, we will establish your identify and take reasonable steps to correct the information. If we refuse to provide you with access or to correct such information, we will provide you with written reasons for our denial of access or refusal to correct your personal information. We may charge you a reasonable fee for providing you with access to that personal information.

10. Direct marketing

When you provide contact information to us, you agree to us contacting you in relation to promoting our products and services, assessing your application, and administering your policy or claim. In doing so, we may provide personal information about you to a related company or service provider.

NobleOak may receive basic information about you (such as your name and email/address) from one of our alliance partners (such as another friendly society or association of which you are a member) as part of a referral program established between NobleOak and the alliance partner. We may also provide basic information about you (your name, email details, and type of policy) to the alliance partner which referred you to NobleOak as part of the referral program management.

If you are unsure as to where we first obtained your contact information, you may ask us to provide the source of that information. If you do not wish to receive information on other products or services offered by or through us, you may request not to receive direct marketing communications by contacting us.

11. Cookies and website monitoring

NobleOak may use cookies/ tracking pixels to collect online traffic data, including data from third parties such as Google,  Facebook and other social and digital platforms, to enhance the online experience for our site visitors, digital advertisement targeting and for researching our markets.

A cookie is a small text file that our site may place on your computer as a tool to remember website search preferences. A tracking pixel is a piece of code generated by a third party that is placed on NobleOak’s website to collection information about your activity. No sensitive information is collected via cookies or tracking pixels.

You may refuse the use of cookies/tracking pixels by selecting the appropriate settings on your browser; however, this may affect the functionality of our website.

NobleOak may use reports provided by Google Analytics and other service providers to help us understand website traffic and webpage usage. We analyse user activity on the website, such as pages visited, search terms and time spent on the site to help us gain insights about how we can improve the functionality and experience of the website for our site visitors. We also use information provided by third parties such as Google, including Google Analytics Remarketing cookies, for remarketing activities and to improve user experience.

By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, use the opt-out service provided by Google or change your Google account privacy settings.

12. The Use of Artificial Intelligence (AI) Tools

NobleOak may use Artificial Intelligence (AI) tools to improve the efficiency, quality, and speed of our processes and to:

• Provide you with insurance or wealth advisory services;
• Process and underwrite your application;
• Administering our products and services (including responding to information requests, complaints and assessing and managing claims); and
• Develop and improve our products and services (this may include training our staff, systems development, and testing).

NobleOak acknowledges that the Privacy Act and the APPs apply to the collection, use and disclosure of personal information to all uses of AI that involve personal information.

Where an AI tool uses personal information, where possible, this information will be de-identified and used within our internal technology environment. Where AI tools are used outside the NobleOak technology environment personal information is redacted.

13. EU General Data Protection Regulation (GDPR)

NobleOak’s products and services are available to Australian residents in Australia only.

Where a NobleOak client advises us that they are also a citizen of an EU country subject to the General Data Protection Regulation (GDPR) NobleOak will record the client’s EU citizenship status and have regard to the specific requirements of OAIC Guidelines in respect of the applicability of GDPR  to Australian businesses.  Further details may be obtained from the NobleOak Privacy Officer at [email protected].

14. Contacting NobleOak

General privacy enquiries should be directed to the NobleOak Privacy Officer at: [email protected].

15. If you have a Privacy complaint

We aim to manage any privacy related complaints promptly and fairly. NobleOak has an internal dispute resolution process in place, and we are a member of external dispute resolution bodies. NobleOak’s Complaints Handling Policy & Procedure is intended to ensure that complaints are dealt with fairly, professionally, consistently, and promptly.

Upon receipt of a privacy complaint, the complaint will be escalated to NobleOak staff with the appropriate knowledge of the Privacy Act. We will then issue you with a timely response that, if appropriate, will outline the measures that NobleOak will take to resolve the complaint.

You may make a privacy complaint directly to NobleOak via:

• Email– [email protected]
• Phone– 1300 551 044 during 8:30am – 5:00pm Sydney time
• Mail – GPO Box 4793, Sydney NSW 2001

NobleOak’s objective in all cases will be to resolve your complaint promptly.

However, if you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Australian Government’s Office of the Australian Information Commissioner (OAIC) via the following channels:

Online: www.oaic.gov.au/privacy/privacy-complaints

In writing: GPO Box 5288 Sydney NSW 2001

By phone: 1300 363 992.

16. Changes to this Policy

NobleOak may update this Privacy Policy at any time to ensure that this Privacy Policy continues to accord with our business operations and Australian Privacy laws. We encourage any person that discloses personal (including sensitive) information to NobleOak, to visit this page periodically.

17. Shareholder Privacy Policy

This Privacy Policy applies to NobleOak’s insurance operations in respect of its customers and other stakeholders transacting personal information with NobleOak during NobleOak’s insurance operations. NobleOak has issued a separate Privacy Policy applicable for its shareholders relevant to their relationship with NobleOak which is available at https://www.nobleoak.com.au/corporate-governance/.