Personal information is any information or an opinion about an identified individual or an individual who is reasonably identifiable.
You may elect not to submit personal information to us but this may mean that we are unable to provide you with any information, products or services.
Collection and use of submitted information
We may collect and retain personal and other information about you (“submitted information”) when (a) you provide us with personal information in an email, letter, by telephone, during a meeting or by other means; or (b) you complete and submit an online form or (c) you access or use our services; or (d) a third party submits information about you to us.
Our customers may deliver information to us for processing which contain personal and other information about you. In these circumstances, it is our customer’s responsibility to ensure that they have the necessary consents from you with respect to our collection, use and disclosure of any submitted information relating to you.
We will only collect information by lawful and fair means.
As long as it is reasonable and practical to do so, we will endeavour to collect personal information about you from you rather than from a third party.
If you submit personal information to us, you warrant that you have obtained all necessary consents from the relevant persons to allow our collection, use and disclosure of that information in accordance with this policy.
If we receive unsolicited personal information that could have been lawfully collected by us as solicited information, we will treat that submitted information in the same way as we treat solicited information. If we receive unsolicited personal information that could not have been lawfully collected by us as solicited information, we will destroy or de-identify that information as soon as practicable.
The submitted information which we retain may include your name, address, email address, employer or business name and address, employment position or work/business role, phone number(s), purchases, product and service enquiries and other information where it is reasonably necessary for our functions or activities.
We may use the submitted information for our normal internal business purposes and to communicate with you regarding our products and services or the products and services of third parties or for any other reasonable purpose connected with the operation of our business. You may elect not to receive such communications from us, either at the time you submit the information or at a later time. If you elect to opt out of any direct marketing, we will comply with that election.
We will not sell submitted information to third parties or intentionally disclose submitted information to third parties except to the extent that you have consented to such disclosure.
We may use a third party to provide hosting or other services and as a result your submitted information may be collected and stored using physical infrastructure owned by third parties. In these circumstances (a) we will retain logical control of the submitted information; (b) the third party will not be permitted to access, use or disclose the submitted information except to the limited extent necessary to provide the services (e.g. creating data back-ups or performing maintenance services). You consent to this limited collection and use of the submitted information by third party hosting and service providers.
Submitted information may be sent to our contractors located in India or in the Philippines for processing. Our contractors are only permitted to use the submitted information to the extent necessary to perform the required processing services and they are not permitted to use the submitted information for any other purpose.
Except to the extent necessary for the operation of our business or as authorised by you or as required by law, we will not use or disclose submitted information for any other purpose.
It is not practicable for information submitted electronically to be provided to us anonymously or using a pseudonym and it is a requirement that you accurately complete any data fields that require insertion of your name and personal details. If you do not wish to provide any required personal information then you should not proceed with the completion of the relevant process. Where appropriate you may communicate with us by telephone on an anonymous basis.
We will take reasonable steps to implement and maintain security precautions and to protect personal information from misuse, interference, loss and unauthorised access, modification and disclosure. However, we are unable to guarantee that unauthorised access to submitted information will not occur, either during transmission of that information or after we receive that information.
If we no longer require your personal information, we will take reasonable steps to permanently destroy or de-identify that information. You acknowledge that our back-up procedures may make it impractical to locate and destroy or de-identify copies of your personal information which are stored off-line or in a form which does not readily permit location and modification of data and you consent to our continued retention of submitted information in these circumstances.
If you submit information to any other site accessed through a link from our Site, the privacy principles applying to any information you submit to that site are outside our control. You should check the privacy policies of any other site before submitting information to that site.
When you visit our Site, our servers may record a range of information relating to your access and use of the Site (collectively called “clickstream data”). We may examine clickstream data to determine the traffic through the server as well as access levels to specific pages. No attempt will be made to identify you or your browsing activities from clickstream data except in the circumstances specified below.
If we or any authority suspect that unauthorised access or use of the Site has occurred or may occur or be attempted, we may gather, use and disclose more extensive information than indicated above regarding access or attempted access to the Site for the purposes of prevention, detection, investigation or prosecution.
Notifiable Data Breaches
We will comply with the requirements of Australian privacy law and our internal policies and procedures with respect to our response to and our reporting of any notifiable data breaches.
Correction of errors and access to personal information
We will take reasonable measures to ensure all personal information held about you is accurate, complete, relevant and up-to-date.
We will provide you with access to your personal information on reasonable request and subject to your agreement to pay our access charges and adequate proof of your identity if (a) it is practicable for us to do so and we have no other reasonable grounds for refusing access, (b) the request is not frivolous or vexatious, (c) access will not have an unreasonable impact on the privacy of others, (d) the information does not relate to existing or anticipated legal proceedings (other than information accessible through the discovery process), (e) access will not reveal our intentions in relation to any negotiations with you, (f) access is not unlawful (g) denying access is not required or authorised by law, and (h) access will not prejudice any prevention, detection, investigation or prosecution of possible unlawful or improper activity.
You have the right to require us to correct errors in your personal information.
We will correct any errors in your personal information upon receipt of written evidence from you which satisfies us that a correction is required.
Privacy related complaints, concerns and questions