[COMPANY NAME] trading as [TRADING NAME] ([TRADING NAME], we, us, our) are committed to protecting your personal information in compliance with Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).
Kinds of personal information we collect and hold
We collect and hold personal information about customers and potential customers, contractors, people that subscribe for our products or services (whether directly through us or through one of our clients that provides products or services to you) and other people who come into contact with us (you).
The personal information we collect and hold is what is reasonably necessary for our business to operate. When we collect and hold personal information, it may be of the following kinds:
- Your name, address, email address and phone number;
- Your username and password for using our products or services;
- Whether you have opened or clicked on email new articles;
- Your debit or credit card details (stored securely by PayPal but not by us);
- Your geographic location;
- Opinions and feedback about our products and services;
- Any other information you provide to us when you use our website, products or services including which of our webpages, products or services you have used or visited.
How we collect your personal information
We will generally collect personal information about you directly by way of forms and other documents or information you submit to us or correspondence you provide to us. In some circumstances we may also collect personal information about you from third parties such as our clients or contractors that you use or are subscribed to our products or services through.
When we collect personal information about you, we do so by making a record of it.
We do this when:
- You register with us to become one of our clients;
- You communicate with us online;
- You subscribe to our email news;
- You take part in our promotions, competitions, testimonials, surveys and focus groups;
- You deal with us in other ways involving a need for personal information to be provided such as bring a claim against us;
- Our client (your service provider) provides us your name and email address for the purpose of using our news service to send you direct emails.
If we are unable to collect personal information relating to you, we may be unable to provide you with the products or services you require or continue our relationship with you.
What about our websites, applications, IP addresses and ‘cookies’?
Like almost every website on the internet, when you visit our sites, products or services our web servers record anonymous information such as the time, date and URL of the request. This information assists us to improve the structure of our websites and monitor their performance. Sometimes we also use third parties to analyse this information.
Sometimes cookies may collect and store personal information about you. We treat this information in the same way as any other personal information you provide. You can adjust your internet browser to disable cookies or to warn you when cookies are being used. However, if you disable cookies, you may not be able to access certain areas or experience the added features offered with the enablement of cookies.
We also collect and manage Internet Protocol (IP) addresses – the unique identifier on your computer or device. It’s used for the purpose of providing internet session management and to detect any misuse or fraudulent activities involving our websites.
We may use third parties to analyse usage statistics. Such analysis is performed using data collected from our websites. The technology is not intended to collect personally identifiable information, however in limited circumstances some personally identifiable information is collected, for example, an email address incorporated into a URL string. Personally identifiable information collected in this way is not used by the third party or Sensis for any purpose.
Digital advertising may be included on our site or other sites. To make this advertising more relevant to you, anonymous information about the previous web browsing activity on your computer’s or device’s internet browser on our sites is collected and used to associate your computer or device with one or more pre-defined interest categories.
Holding of personal information
Personal information we hold is stored in computer systems and generally by off-site cloud storage. These may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.
How we use your personal information
When we collect, hold and use your personal information, we may do so to for the following purposes:
- To personalise our communications with you;
- To sell and promote our products and services to you;
- To provide news articles and updates by electronic means directly to our clients and subscribers;
- To provide news articles and updates by electronic means directly to the subscribers of our clients;
- To provide you with access to product analytics through our service providers;
- To improve our website, services and product offerings;
- To provide you with a better service in supplying you (or others you use or subscribe to our products and services through) with our products and services;
- To assist in investigating your complaints, feedback and enquiries;
- For our internal management purposes to manage our relationship with you and to manage the payment and recovery of amounts payable to us by you or an entity related to you.
We may collect, hold, use and disclose your personal information for other purposes which are within reasonable expectations or where permitted by law.
Disclosure of your personal information
We may disclose personal information to the following kinds of entities for the relevant purposes:
- Our contractors, consultants, advisers, associates and related entities;
- Entities that provide services to us;
- Any industry body, tribunal, court or otherwise in connection with any complaint made by you about us;
- Other entities with your consents or as permitted or required by law.
Overseas disclosure and storage of personal data
It is our policy to require all of our overseas sharing of personal information to be done in a way which requires observance of strict privacy and security standards, both during transit and at the overseas destination.
We may allow your personal information to be stored and used with those who are in countries other than your own location. We do this where a service is delivered by a trusted service provider.
Direct marketing communications
When marketing to you, your personal information is only ever used or disclosed for our own purposes. You may opt out of our direct marketing to you. Our direct marketing materials will tell you how to do this or alternatively you may opt out of such materials by contacting our Privacy Officer using the contact details set out below.
We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law, for example where release of the information would have an unreasonable impact on the privacy of others). If you wish to access your personal information or have an enquiry about privacy, please contact our Privacy Officer using the contact details set out below.
Before we provide you with access to your personal information we may require some proof of identity or for you to verify your identity. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part.
Accuracy and completeness of personal information
While we will endeavour to ensure that the personal information collected from you is up to date accurate and complete, we will assume that any personal information provided by you is free from errors and omissions.
You may request that we update or vary personal information that we hold about you by contacting our Privacy Officer using the contact details set out below.
How to make a complaint about a breach of your privacy rights by us
If you are of the view we have breached the APPs, the Privacy Act, or any related privacy code in dealing with your personal information, you may make a complaint to our Privacy Officer using the contact details set out below. We may ask you to put your complaint in writing and to provide details about it.
We may discuss your complaint with our personnel and our service providers and others as appropriate.
Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way.
Our Privacy Officer will inform you in writing about the outcome of the investigation. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the Office of the Australian Information Commissioner by visiting the following website and following the steps: oaic.gov.au/privacy/privacy-complaints.
Anonymity and pseudonyms
You have the option of not identifying yourself or using a pseudonym when dealing with us in relation to privacy matters unless we are required by law or a court/tribunal to deal with individuals who have identified themselves or it is impractical for us to deal with you if you have not identified yourself in the circumstances.
This is a policy
More information about the Privacy Act and APPs is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at oaic.gov.au (email: email@example.com) (Australia).
Please direct all complaints and queries in relation to your privacy or this policy to:
Privacy Officer, [TRADING NAME]
Last update of this policy: [Date]