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(Cth). and where we obtain Personal Information from a citizen of a member state of the European Union, the European Union General Data Protection Regulation (Regulation (EU) 2016/679) (the EU GDPR
- Collection of Personal Information
We collect Personal Information when you:
- make contact via the phone, in person, email or via forms submitted on our Website / App and you provide us your details;
- purchase or subscribe to our products or services;
- subscribe to our mailing list;
- enter our competitions or promotions; or
- make contact with us for employment/contractor reasons;
- download our App.
We collect Personal Information to:
- improve our products and services;
- provide our product or service to you;
- communicate with you;
- offer you promotional product or market our product that you are interested in;
- keep our customer database;
- to investigate any complaints that you make;
- to investigate whether you are in breach of our terms and conditions;
- verify your identity;
- to notify you of vacant positions if you applied for jobs at our Business;
- comply with the law or to use your information as permitted under the law; and
- use your information for purposes that are related to the above.
We collect and hold following types of Personal Information:
- your contact details that may include, but are not limited to, your name, business name, position title, postal address, email address, fax number and phone number; and
- optional Personal Information that you consent to provide.
We will only collect your Personal Information using fair and lawful means.
In the event of credit card dealings, we do not store credit card details as we use payment gateways and/or third party processor.
If we receive unsolicited Personal Information, we may destroy it or ensure that it is de-identified if it is lawful and reasonable to do so.
You understand and acknowledge that the consent you are to provide when submitting Personal Information is required in order for us to provide you with our products and/or services. Failing to provide consent may result in failure to issue you with the products and/or services.
Withdrawal of Consent
Consent may be withdrawn by contacting us in accordance with clause 12 of this policy.
After having received, reviewed and actioned your request, subject to clause 9, your withdrawal of consent will be noted on our system.
We will use our best commercial endeavours to action your request as soon as possible. However, we note that during the time between receiving your request to processing the withdrawal of your Personal Information, you will not hold us liable for the use of your Personal Data during this processing time.
Personal Information will be marked as ‘restricted’ between the time of processing your request to withdraw until the actual time of the withdrawal being actioned.
- Right to be Forgotten
In addition to the withdrawal of your consent, you may also contact us to erase your Personal Information.
You may contact us in accordance with clause 12, to have your Personal Data erased and we will use our reasonable discretion to erase same if:
- the Personal Information provided is no longer necessary in relation to the purpose of having obtained your Personal Information;
- you have withdrawn your consent for us to hold your Personal Information;
- the legal retention period for holding your Personal Information has expired;
- you object to the use of your Personal Information; or
- the processing of your Personal Information was not in accordance with the EU GDPR.
- Anonymity and Pseudonymity
You may interact anonymously or by using a pseudonym with us and you may refuse to give your details.
You must provide your Personal Information when you:
- purchase goods that require delivery;
- register for membership;
- sign up for mailing list;
- lodge a complaint; and
- are required to provide Personal Information under the law.
- Disclosure of Personal Information
We only disclose your Personal Information for purposes that are reasonably related to our Business.
We will not disclose your Personal Information to third parties for payment, profit or advantage.
We may disclose your Personal Information to third parties, from time to time, to assist us in conducting our Business, including:
- technology service providers including internet service providers or cloud service providers;
- couriers such as Australia Post;
- data processors that analyse our Website / App traffic or usage for us;
- agents that perform functions on our behalf, such as mailouts, debt collection, marketing or advertising;
- our related bodies corporate; and
- to persons, entities or courts as required under the law.
We may disclose your Personal Information to third parties:
- to provide the service you wish to use;
- to improve our Business, services, products and Website/App;
- to customise and promote our services which may be of interest to you;
- to comply with or as permitted under the law; or
- with your consent.
You understand the Personal Information provided to us may be held offshore by entities that assist us to carry on the Business. By providing such information, you consent to the disclosure of such information. We will use reasonable endeavours to ensure they are subject to similar privacy legislation when handling such information.
We use our every and best endeavours to ensure each third party we directly contract with, in the dealings of Personal Information, are aware of their processor liability provisions under the EU GDPR and also are aware of privacy obligations in the dealings with Personal Information.
We may, from time to time, use ‘cookies’ which are small data files placed on your machine or device to store information.
- authentication cookies;
- session cookies that allow you to remain logged in and keep track of your activities until the browser / App shuts down; and
- persistent cookies that help us monitor our services by recording your browser activities and they do not expire upon browser shut down.
- improve the performance by reporting any errors that occur;
- provide statistics about how the Website / App is used;
- remember settings that you used on our Website / App;
- identify that you are logged into the Website / App;
- link to social networks like Facebook and Twitter; and
- provide ads that are tailored to you.
Please note that although cookies do not generally store Personal Information, they may contain your IP address. However you are effectively anonymous to us as this this information cannot be linked to the Personal Information supplied.
We have obtained your consent to the use of particular types of cookies which may deal with Personal Information. The types of cookies the Website uses include, but are not limited to:
- Session identifier cookies which are necessary to provide you with our services. To the best of our knowledge, do not store Personal Information and cannot be used to track your behaviour across sites. They contain a session identifier which is used to maintain sessions between page loads.
- Third party Analytics cookies and/or other tracking cookies. We understand these types of cookies to be able to track your behaviour across sites.
We use a database management system to store Personal Information received and it contains security features, such as encryption, network-based firewall and anti-virus, to ensure the protection and integrity of all data.
- Retention of Personal Information
Personal Information held by us is securely retained after the collection of your Personal Information.
Personal Information is deleted after it is no longer required/necessary to be held.
- Direct Marketing to You
We will not send you unsolicited commercial electronic messages in contravention of the Spam Act 2003
We may use the non-sensitive information you gave us for the purpose of promoting and marketing our Business to you if we:
- use the information that you reasonably expected us to use for promoting and marketing our Business to you; and
- provide you a simple method to opt-out.
- Personal Information Breach
In the unlikely event of a breach of privacy:
- we employ practices to notify the relevant bodies under the Privacy Act 1988 (Cth) and the EU GDPR within the required timeframes.
- we will notify you without undue delay, should it be found the breach places your rights and freedoms at a high risk.
- Accessing and Correcting Your Personal Information