“Personal Information” under the Privacy Act is defined to mean information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can reasonably be ascertained, from the information or opinion.
Application to our website
What information we collect
The Personal Information we may collect about you includes:
• Personal Information: your name, occupation and location;
• Contact Information: your email address, telephone number and business address; and
• Other information which may assist us in conducting our business, and providing and marketing our products and services.
How we collect information
We collect Personal Information through our business relationships with our clients. However, we may also receive Personal Information from third-party sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff and our business partners.
We will generally collect Personal Information by way of forms filled out by people, face-to-face meetings, interviews, business cards, electronic communications and telephone conversations. In addition, we collect Personal Information from our social media web pages (e.g. Facebook, Twitter, Instagram, LinkedIn).
We may collect your Personal Information when you request or acquire a product or service from us, register with us as a subscriber to our newsletter, provide a product or service to us or when you communicate with us electronically (including email and facsimile), by telephone or in writing.
We may collect information using:
• Cookies (if relevant – an individual can adjust their browser’s settings to accept or reject cookies) or analytics services; and
• Pixel Tags, which enable us to contact or otherwise engage with users through a variety of media.
If, at any time, you provide personal Information or other information about someone other than yourself, you must have that person’s consent to provide such information for the purpose for which you provide it to us.
Why we collect information
The primary purpose for which we collect Personal Information about you is to conduct our business, provide and market our services.
How we use Personal Information
In addition to the primary purpose outlined above, we may use the Personal Information we collect, and you consent to us using your Personal Information:
• To provide you with news and information about our services;
• To manage and enhance our services;
• To communicate with you, including by email, mail or telephone;
• As part of any investigation in relation to you or your activity which we suspect to be a breach of any of our terms and conditions, serious misconduct or unlawful; and
• As required or permitted by any law or regulation (including without limitation the Privacy Act).
We never disclose Personal Information except as required by law or unless otherwise granted permission to do so.
We may share information with others as de-identified data in aggregated form.
We may need to provide your Personal Information to third parties who we engage to assist us to provide goods and services to you, such as:
• Service providers who we engage to assist us in providing services to you;
• Information technology service providers; and
• Payment processors.
Where your Personal Information is disclosed to these third parties, they will only be authorised to use your Personal Information for the purpose that we supplied it to them. If those third parties are located overseas, then your Personal Information may be transferred overseas.
How we hold Personal Information – security
We will take all reasonable steps to protect the Personal Information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure by means of secure premises, locked cabinets, firewalls, password access, secure servers and encryption of credit card transactions.
However, you acknowledge that the security of communications sent by electronic means or by post cannot be guaranteed. You provide Personal Information to us via the internet or by post at your own risk. We cannot accept responsibility for misuse, interference or loss, or unauthorised access, modification or disclosure in respect of your Personal Information where the security of the information is not within our control.
Personal Information collected by us will be stored and processed on servers located within [and outside of] Australia. To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
In other limited circumstances, we may need to send your Personal Information overseas. These circumstances include:
• Where we have a supplier assisting us with the provision of goods and services and our business functions; and
• Where a third-party application is being used in connection with our interactions with you.
If you suspect any misuse, interference or loss, or unauthorised access, modification or disclosure in respect of your Personal Information, or any other privacy breach please let us know immediately.
A notifiable data breach will occur if there has been unauthorised interference to your Personal Information, and that interference is likely to result in serious harm to you. If there is a notifiable data breach, we will determine if the data breach has caused or is likely to cause serious harm. If we determine that serious harm has or will be caused, we will notify you and the relevant reporting body of the data breach.
Retention and destruction
We will retain your personal information for the duration of your use of the website and our goods and services. When you cease use, we will retain your Personal Information for no longer than 7 years or for any such period that it is necessary for us to retain your Personal Information. We will make your personal Information available to you during this time if requested.
Once any retention period has lapsed (or earlier at our option), we will ensure the timely and secure destruction and/or disposal of your Personal Information, including both physical information and cyber information. If at any other time, you request we destroy and/or dispose of your Personal Information, we will comply with your request in a timely matter, to the extent that it does not interfere with the conduct of our business.
Cookies and data activity
We may use standard technology called ‘cookies’ and similar technologies on our website. Cookies are small data files that are stored on your computer when you visit a particular app or website, which allow your web browser to remember certain information.
Sometimes information that you upload is provided with associated metadata. If you do not want us to use the metadata you must remove it before uploading it onto our website.
Links to other applications and websites
Our website may contain links to other applications, websites and tools that are owned, controlled or operated by us. We are not responsible for the practices employed by applications linked to or from our website or the information or content contained on them.
Legal disclosure of Personal Information
We reserve the right to disclose any Personal Information which identifies you as required by law and when we believe that disclosure is necessary to protect our rights, or to comply with a judicial proceeding, court order, or legal process served on our website.
How to opt-out or access your Personal Information
• Want to find out what Personal Information we hold about you;
• Believe any of your Personal Information held by us is inaccurate, out of date, incomplete or it is not necessary for us to continue to hold it;
• Want to request not to receive direct marketing communications or that we do not provide your Personal Information to any of our third party providers in order for them to provide you with direct marketing communications; or
• Wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us,please contact us by emailing us at our contact email address at the end of this policy.
If you are not happy with our response, you may complain directly to the Australian Privacy Commissioner.
For any queries, complaints or requests regarding this policy or our handling or use of your Personal Information, please contact us at firstname.lastname@example.org.
Last updated on 30.04.21