The Australian Privacy Principles
We will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Cth) (‘Privacy Act’). The Privacy Act lays down 13 key principles in relation to the collection and treatment of personal information, which are called the ‘Australian Privacy Principles’.
What is ‘personal information’?
Personal information held by the Company may include your:
- Residential and business postal addresses, telephone/mobile/fax numbers and email addresses.
- Bank account and/or credit card details for agreed billing purposes.
- Any information that you provided to us by you during your account creation process or added to your user profile.
- Preferences and password for using this site and your computer and connection information.
- Any information that you otherwise share with us.
Personal Information we Collect
We may collect personal information that you provide to us about yourself when you use this site, including (without limitation) when you:
- Create a user account, including your name, address, date of birth, contact details and other personal details.
- Add information to your user profile.
- Financial information that you may submit through the application or site.
- Contact and identification details of any third party whom you have authorised to negotiate or provide your personal information on your behalf (including any agents or attorneys appointed by you under a power of attorney).
- Purchase any products and/or services through this site.
- Complete any forms on the site.
- Register for access to premium content or request certain premium features.
- Complete an online contact form to contact us or any third-party supplier.
- Provide information to us by telephone or through marketing or competition application forms.
- Send us an email or other communication.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as ‘Device Information’.
This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes. The Company may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.
If you do not give personal information to us, it may affect our ability to provide you with products and/or services.
Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you however we will provide you with an opportunity to opt–out of receiving communications about that matter within each of those communications.
Collection of Device Information
We collect Device Information using the following technologies:
Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- Remember your preferences for using this site.
- Manage the signup process when you create an account with us.
- Recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page.
- Facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process.
- Show relevant notifications to you (e.g. notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services).
- Remember details of data that you choose to submit to us (e.g. through online contact forms).
Many of these cookies are removed or cleared when you log out but some may remain so that your preferences are remembered for future sessions.
In some cases, third parties may place cookies through this site. For example:
Log Files track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
‘Web beacons’, ‘tags’, and ‘pixels’ are electronic files used to record information about how you browse the Site.
Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including limited credit card info and bank account details), email address, and phone number. We refer to this information as ‘Order Information’.
Information from Third-Parties
We may also receive information about you from third parties in relation to other websites. For example, you may choose to participate in a third party application or feature as part of our services (such as logging in through Facebook Connect or otherwise linking to the services from another website or interactive service) or on a third party website or service (such as a Facebook application or a similar application or feature) through which you allow us to collect (or the third party to share) information about you, including personal information. When you choose to participate, you may be opting to link your activity on our site with the services of that third party website or service, which may then collect information about your visits to our site and may publish that activity as you request to your ‘profile’ or similar feature with that third party (such as if you choose to share content you find on our site with your ‘connections’ on the third party’s website or service).
How Do We Use Your Personal Information?
We use the Personal Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Personal Information to:
Communicate with you, screen our orders for potential risk or fraud and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
Send you notifications of sales, promotions and other marketing material that we feel would be of interest to you. These notifications (email marketing) can be sent directly from the site, or through a third-party mail service.
Your personal information may also be used in order to:
- Verify your identity.
- Assist you to place orders through this site.
- process any purchases of products and/or services that you may make through this site, including charging, billing and collecting debts.
- Make changes to your account.
- Respond to any queries or feedback that you may have.
- Notify you about important changes or developments to our functions, activities, services of the site.
- Carry out any other activities which relate to or arise out of any investments or requests made by you.
- If you lodge a complaint with us – process and respond to your complaint.
- Conduct appropriate checks for credit-worthiness and for fraud.
- Prevent and detect any misuse of, or fraudulent activities involving, this site.
- Conduct research and development in respect of our products and/or services.
- Gain an understanding of your information and communication needs or obtain your feedback or views about our products and/or services in order for us to improve them.
- Maintain and develop our business systems and infrastructure, including testing and upgrading of these systems, and for any other purpose reasonably considered necessary or desirable by the Company in relation to the operation of our business.
It may take some time to put an opt-out or an unsubscribe in effect so you may still receive communications from us for several weeks after your request is received.
We use any Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.
Information provided to PayPal, American Express, MasterCard and VISA
Purchases which are made through this site may be processed securely and externally by PayPal, American Express, MasterCard and VISA. Unless you expressly consent otherwise, we do not see or have access to any personal information that you may provide to these providers, other than information that is required in order to process your order and deliver your purchased items to you (e.g., your name, email address and billing address).
Redirection to PayPal, American Express, MasterCard and VISA
In particular, when you submit an order to us, you may be automatically redirected to PayPal, American Express, MasterCard or VISA in order to complete the required payment. The payment page that is provided by these payment providers is not part of this site. As noted above, we are not privy to any of the bank account, credit card or other personal information that you may provide to payment providers, other than information that is required in order to process your order and deliver your purchased items to you (e.g. your name, email address and billing address). We recommend that you refer to payment providers’ privacy statement if you would like more information about how the payment providers collects and handles your personal information.
Sharing Your Personal Information
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.
You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (NAI) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising here:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Do Not Track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
When we may disclose your personal information
In order to deliver the products/services you require or for the purposes set out above, the Company may disclose your personal information to organisations outside the Company. Your personal information disclosed to these organisations in relation to this site and to on sell your personal information to order for those service providers to market their services to you, and the Company takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These organisations may carry out or provide:
- Customer/client enquiries.
- Mailing systems.
- Billing and debt-recovery functions.
- Information technology services.
- Marketing, telemarketing and sales services.
- Our business partners and service providers (such as contractors who provide website, IT, marketing, administration and other services to support us).
- Suppliers we engage for data processing and other administrative and support functions.
- Our professional advisers (for example, our insurers, auditors, lawyers, accountants and consultants).
- Financial institutions (for payment processing)
- Any entity to whom we are required or authorised by law to disclose your personal information.
- Market research.
- Website usage analysis.
In addition, we may disclose your personal information to:
- Your authorised representatives or legal advisers (when requested by you to do so).
- Credit-reporting and fraud-checking agencies.
- Credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing).
- Our professional advisers, including our accountants, auditors and lawyers.
- government and regulatory authorities and other organisations, as required or authorised by law.
- Organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions.
- The police or other appropriate persons where your communication suggests possible illegal activity or harm to others.
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements. At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning). In some circumstances, you can ask us to delete your data.
Access to your personal information
In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.
In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:
- Be unlawful (e.g. where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
- Have an unreasonable impact on another person’s privacy
- Prejudice an investigation of unlawful activity
We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.
If we refuse to give you access, we will provide you with reasons for our refusal.
Correcting your personal information
We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.
To ensure that your personal information is accurate and up to date, please promptly advise us of any changes to your information by contacting us via email or by post.
Storage and security of your personal information
We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, protect all of our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.
This may happen if our service providers are located overseas, or if transactions, information, services or products have an overseas connection. Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act (Cth) 1988 in relation to how those parties treat your personal information.
Third party websites
The Company welcomes the General Data Protection Regulation (GDPR) of the European Union (EU) as an important step forward in streamlining data protection globally. Although we do not operate an establishment within the EU and do not target any offering of services towards customers/clients in the EU specifically, we intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.
The requirements of the GDRP are broadly similar to those set out in the Privacy Act and include the following rights:
you are entitled to request details of the information that we hold about you and how we process it. For EU residents, we will provide this information for no fee.
You may also have a right to:
- Have that information rectified or deleted.
- Restrict our processing of that information.
- Stop unauthorised transfers of your personal information to a third party.
- In some circumstances, have that information transferred to another organisation.
- Lodge a complaint in relation to our processing of your personal information with a local supervisory authority.
Where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, please be aware that:
such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other customers/clients subject to appropriate confidentiality protections; and
even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:
- To pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests.
- In exercising and defending our legal rights and meeting our legal and regulatory obligations.
Storage and Processing by Third Parties
Data that we collect about you may be stored or otherwise processed by third party services with data centres based outside the EU, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc. and online relationship management tools. We consider that the collection and such processing of this information is necessary to pursue our legitimate interests in a way that might reasonably be expected (e.g. to analyse how our customers/clients use our services, develop our services and grow our business) and which does not materially impact your rights, freedom or interests.
The Company requires that all third parties that act as ‘data processors’ for us provide sufficient guarantees and implement appropriate technical and organisational measures to secure your data, only process personal data for specified purposes and have committed themselves to confidentiality.
Lodging a Complaint
If you have a complaint about how we handle your personal information (including how we dealt with any requests to correct or access your personal information), please contact us using the contact details below.
Please note that we may ask you to lodge your complaint in writing.
We will acknowledge receipt of your complaint as soon as possible after receiving your complaint in writing. We will investigate your complaint and provide you with a response within a reasonable timeframe.
If you are not satisfied with how your complaint is handled by us, you can lodge a formal complaint with the Office of the Australian Information Commissioner.
Changes to this Policy
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org or by mail using the details provided below:
PO Box 193, Georges Hall NSW 2198, Australia.
If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Australian Information Commissioner’s website (see https://www.oaic.gov.au).