Scope of Policy
"Personal Information" under the Privacy Act 1988 (Cth) 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.
"Sensitive Information" under the Privacy Act 1988 (Cth) means: (a) information or an opinion about an individual’s (i) racial or ethnic origin; (ii) political opinions; (iii) membership of a political association; (iv) religious beliefs or affiliations; (v) philosophical beliefs; (vi) membership of a professional or trade association; (vii) membership of a trade union; (viii) sexual orientation or practices; or (ix) criminal record, that (b) is also: (i) personal information; (ii) health information about an individual; (iii) genetic information about an individual that is not otherwise health information; (iv) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or (v) biometric templates.
Collection of Personal Information
Why do we collect Personal Information?
We collect and hold Personal Information that is reasonably necessary for the products and services we provide.
How do we collect Personal Information?
We will generally collect Personal information from: (i) you directly through your engagement of our services or purchase of our products; (ii) the course of providing our services or products to you; (iii) third parties; (iv) publicly available sources; (v) anyone authorised to act on your behalf; or (vi) when you use our Website including when you visit, access, submit a query or online form, subscribe to, or use other services or products provided on our Website.
We may also collect Personal Information in person, through applications, hard copy or electronic forms, email or written communication with you, or through a telephone conversation with you.
What form of Personal Information do we collect?
We may collect and hold the following types of Personal Information: (i) Your name; (ii) Your date of birth; (iii) Age range (iv) Your gender; (v) Your phone number; (vi) Your occupation or profession; (vii) Your email address; (viii) Your mailing address and delivery address; (ix) Payment details; (x) Information about your personal affairs; (xi) Information about your business or company; (xii) Information provided by you when you use or request other services or products in communications with us or on our Website, including behavioural information about your interactions with the Website; and (xiii) Information provided by you when you post or make comments on the Website, whether solicited or unsolicited.
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.
How do we collect Sensitive Information?
We may collect and hold Sensitive Information: (i) Where you voluntarily provide Sensitive Information to us; (ii) Where it is necessary to collect and hold Sensitive Information in connection with the provision of our products and services; and (iii) Where Sensitive Information is provided to us in connection with an individual seeking employment, work experience or similar, whether solicited or unsolicited.
How we use your Personal Information
We collect, use and disclose Personal Information for purposes associated with the provision of our products and services, conducting our business activities, providing the products and services you requested, marketing and promotional efforts and to improve our content, product and service offerings, including: (i) Facilitating transactions between you and us; (ii) Facilitating transactions between you and other people, suppliers and organisations who are accessible via our Website; (iii) Processing your payment for goods and services; (iv) Monitoring the use of our Website; (v) Improving the quality of our service; (vi) Administrative purposes; (vii) Record keeping for compliance purposes; (viii) Statistical analysis of the usage of our services and Website; (ix) Where disclosure of such information is necessary for the furtherance of your matter or claim; and (x) Complying with the law, including privacy legislation and where disclosure of such information may be compelled by law.
Occasionally, we may also use the Personal Information we collect to notify you about important changes to our services or Website, new services, and special offers we think you will find valuable. You may notify us at any time if you do not wish to receive these offers by emailing us at the link provided on notifications or by contacting us at email@example.com.
We will only use Sensitive Information for the purposes for which it was collected by or provided to us.
If you have given us your express consent to: (i) Provide you with direct marketing communications; or (ii) Provide your Personal Information to third party individuals and organisations who offer goods and services on our Website, we may collect, hold, use and disclose Personal Information in accordance with that consent to enable us (or as the case may be those third-party individuals and organisations) to provide you information about, and offer you, goods and services.
If you give us consent to provide you with direct marketing communications, you can later request not to receive direct marketing communications. You may also request 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.
Such information may be shared with others as de-identified data in aggregated form.
Personally identifiable information or business information will not be shared with third parties except as required by law or where you have given us your express consent to do so.
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: (i) Information technology service providers; and (ii) 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.
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 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 and other applications and tools.
Data Security and Storage
Personal Information collected by us will be stored and processed on servers located within 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: (i) Where we have a supplier assisting us with the provision of goods and services and our business functions, such as Google Analytics (as an illustrative example); (ii) Where our payment processor’s servers are located; and (iii) Where a third-party application is being used in connection with our interactions with you (e.g. for processing of payments or security checks).
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.
EU General Data Protection Regulation (GDPR)
We are only subject to the GDPR, to the extent the jurisdiction of the GDPR lawfully applies to us. Where your personal data is protected by the GDPR, we will process that data in accordance with the GDPR.
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
If you: (i) Want to find out what Personal Information we hold about you; (ii) 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; (iii) 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 (iv) 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 firstname.lastname@example.org.
If you are not happy with our response, you may complain directly to the Australian Privacy Commissioner.