Policy last updated: April 2021
Purpose and nature
Personal information is information or an opinion about you from which you can be reasonably identified.Why does the Company collect personal information?
The Company collects personal information in connection with providing, administering, improving and personalising its products and services, marketing and to support its business functions.
If the Company does not collect your personal information, it may not be able to provide you with these products and services.What personal information does the Company collect?
The types of personal information collected by the Company vary depending on the nature of our interaction with you and may include:
- contact details (including address, email address, telephone number(s) and other contact details);
- dates of birth;
- payment information; and
- other information you provide to us.
Collecting information from you
If it is reasonable and practical to do so, the Company will collect personal information directly from you.
Depending on how you choose to interact with the Company, the Company may collect your personal information when you contact, or are contacted by, the Company or its service providers by telephone, by email, through the Company’s website, social media and other digital services or when you complete a form or document and provide it to the Company.
Collecting information from third parties
Collecting information from visits to the Company’s website
The Company may also collect information based on how you use its website, including through ‘cookies’, web beacons and other similar technologies.
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable the Company’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of the Company’s website may not function fully for users that disable cookies.
If the Company receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, the Company will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
How does the Company hold your personal information?
The security of your personal information is important to the Company. Accordingly, the Company takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. These steps include the implementation of various safeguards, including password protected databases, system firewalls and encrypted payment processing.
The Company will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.
- Security breach procedures
The Company’s data security practices have been adopted with a view to protecting the data held by the Company. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, the Company cannot guarantee any transmission will be completely secure.
How does the Company use your personal information?
The Company may hold, use or disclose your personal information so that it can provide any products and services that you request.
The Company may also hold, use or disclose your personal information to:
- consider any concern or complaint that you raise against the Company or to manage any legal action between you and the Company;
- prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or
- comply with any relevant laws, regulations, codes of practice and court orders.
- Direct Marketing
The Company may also use your personal information to identify and promote products or services that may be of interest to you.
At any time, you may opt out of receiving direct marketing communications from the Company. To do so, you may opt out via the link within email communications received from the Company or by contacting the Company directly in accordance with clause 11. Unless and until you opt out, your consent to receive direct marketing communications from the Company and to the handling of your personal information for this purpose will continue.How is personal information disclosed to others?
The Company does not sell, rent or trade personal information to, or with third parties.
The Company may disclose your personal information to third parties in limited circumstances, including to external providers that perform services on behalf of the Company (e.g. IT systems administrators, advertising agencies and marketing partners).
The Company’s website may contain certain links to other websites. The Company does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.
Some of the third party service providers to whom we send data are located outside of Australia or may store your data outside of Australia. Generally, we require that our service providers who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with applicable privacy laws. By providing your personal information to us, you consent to the transfer of that information to our third party providers and to the storage of your personal information by us or our third party providers.
How you may access or correct your personal information
You may contact the Company to request access to the personal information it holds about you at any time. You may also ask the Company to correct information about you that you may believe is inaccurate, incomplete or out of date.
Please contact the Company using the contact details set out in clause 11. The Company will need to verify your identity before giving you access to, or correcting, your personal information. The Company will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however the Company may charge a reasonable fee to cover the administrative costs of retrieving your personal information.
In certain circumstances, the Company may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, the Company will write to you to explain the reasons why this is the case.
How you may complain if you have concerns about how the Company has managed your personal information
If you have a complaint related to how the Company has managed your personal information, please contact the Company using the contact details set out in clause 11. The Company may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.
The Company will provide you with an estimated response timeframe in relation to your complaint. In any event, the Company will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.
How to contact us