We only collect information that is reasonably necessary for the proper performance of our activities or functions. In the occasions upon which we will require your personal information, we will ask you for it. That information will normally be collected when you seek to enquire about or purchase our products and services.
We may collect the following types of information from you:
(Identity Information) name, location, website address, date of birth, nationality, employment details and third-party usernames;
(Contact Information) email address, social media profiles, telephone & fax number, third-party usernames, residential, business and postal addresses;
(Behaviour Information) habits, movements, trends, decisions, webpage views, online activity, associations, memberships, finances, purchases;
(Internet Data) Internet Protocol or "IP address", referring web site addresses, browser type, operating system, domain name, access times and other data typically collected by analytics services like Google Analytics; and
(Business Information) business or project, if it is run in your personal capacity, including information on professional affiliations or services offered.
(Other) any other information you may provide to us e.g. information that is necessary to deliver our services and respond to your queries, details of services we have provided to you or you have enquired about, information provided in customer surveys, information provided directly or indirectly through the use of our services.
If you are a customer, potential customer or a user of our website either with or seeking to enquire about our products and services, we will collect most of your personal information from you at the time you seek to make a purchase or enquire about our products and services, as the case may be. We will collect that information when you enter it into our website.
We may also collect personal information about you from time to time when we are providing our products or services to you, including at any stage of our proprietary end to end process, “the Flow”.
You can delete cookies on your browser and change its settings to disable them altogether if you wish.
When we hold your personal information, we take reasonable steps to protect it as required by the APPs, which include protecting it from misuse, interference and loss, unauthorised access, unauthorised modification or unauthorised disclosure.
We hold and store personal information using:
(Storage Services) third party data storage services that professionally manage information technology infrastructure;
(Software Services) third party application providers, where we use an application for the purposes of our business and store data in association with that application on infrastructure provided by those third party application providers;
(Business Devices) devices operated by employees of our business; and
(Paper Files) printed paper files.
We secure personal information that we collect by:
(Credentials) using authentication credentials for each portion of the data storage infrastructure that we control in accordance with best practice;
(Passwords) using specialized software to generate passwords that are less vulnerable to “brute force” attacks;
(Encryption) using specialized encryption software to store the passwords that we generate; and
(Reputable Vendors) ensuring that the third party providers holding data and information on our behalf are reputable vendors taking reasonable steps to secure the information.
We use, collect and hold your personal information to have a better understanding of your and/or your business needs and to provide you with better service.
We also use, collect, hold and disclose your personal information in order to:
(Identify) identify individuals for the purpose of providing our products and services;
(Communicate) communicate you for the purpose of providing our products and services, including communications about our goods and services; marketing and promotions; and competitions, surveys and questionnaires;
(Provide Services) provide our products and services to you; and
(Transact) transact with you for the purpose of providing our products and services.
We may disclose your personal information for any of the purposes for which we collected it, and those purposes will be reasonably apparent when we collect it from you.
For example, as part of our products and services, we may need to disclose personal information such as your phone number or email address in order to promote your business on the internet.
As part of our products and services, we may also disclose personal information to companies that we work with to provide us with administration and data processing services in order to make our products and services more affordable for you.
We may also disclose your personal information if we are under a legal duty to do so, but will otherwise only disclose it as permitted under the APPs and the Privacy Act generally.
In the course of providing you with our products and services, it is likely that we will disclose your personal information to overseas recipients.
Your personal information that we collect may be stored, processed and accessed in the Philippines, the United States and the United Kingdom.
By providing us with your personal information, you consent to the transfer of your personal information outside of Australia.
We take all reasonable steps to ensure that your personal information will not be held, used or disclosed by the recipient inconsistently with the APPs.
We will allow you to access personal information we hold about you to the extent required under the APPs and the Privacy Act. You will be entitled to access that information on most occasions.
However, the APPs and the Act do set out some exceptions that may apply. If we refuse you access for any of those reasons we will let you know why at the time.
If you wish to obtain access to your personal information that we hold, you should contact us.
Once we have verified who you are, we will let you know what to do next. A fee may be involved for that access in certain circumstances.
Sometimes it can take some time to consider and act on your request for access depending upon what you seek access to, how and where it is stored and any related information or circumstances. However, we will generally respond to you within 30 days.
If personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it. We will then take reasonable steps to correct that information and otherwise to ensure that the information is accurate, up to date, complete, relevant and not misleading.
If we have disclosed personal information about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to notify the third parties to whom we made the disclosure and we will then take reasonable steps to do so unless it is impracticable or unlawful.
It can take some time to consider and act on your request for correction depending upon what you seek to correct, to whom we have disclosed it, any third parties involved and any related information or circumstances. However, we will generally be able to make any corrections within 30 – 60 days.
If you wish to make a complaint about our handling of your personal information, you should first make that complaint to us in writing. You can also make complaints to the Office of the Australian Information Commissioner (OAIC).
When we receive your complaint, we will:
- within 14 days of receipt, review the nature of the complaint and seek to verify your identity; and
- if we determine that the complaint is a bona fide complaint (and not automated, for example), we will:
- respond to you acknowledging the complaint within 14 days;
- consider the complaint on its merits;
- seek legal or any other relevant advice if necessary;
- if we have taken longer than 30 days since first receipt, notify you of our progress;
- respond to you in relation to the merits of your claim as soon as possible, and we will endeavour to do that within 30 – 60 days of receipt of the complaint.
If the complaint cannot be resolved via the above process, or you are unsatisfied with our response, you can submit your complaint to the OAIC for their consideration. In fact, you can submit your complaint to the OAIC at any time, but they would normally ask you if you first attempted to resolve the matter with us, which is why we recommend the above steps first.