1. About this policy
Protecta Group Australia Pty Ltd, ABN 55 607 874 260 and its related entities (herein referred to as “Protecta”) are committed to protecting the privacy of your personal information in accordance with Australian privacy laws.
When you engage us to provide you with any goods or services, apply or complete a Customer Account Application and an application for commercial credit, communicate with us through email, by telephone, in writing, participate in any of our promotional activities, or use any of our other services, including our website, you agree to the use and disclosure of your personal information in the manner described in this policy. This policy is also relevant and applies to other individuals we deal with in connection with commercial credit we provide, such as guarantors and directors.
2. Types of personal information we collect
The kinds of personal information we may collect from you will depend on what type of interaction you have with us. Personal information we may collect from you includes, among other things:
- identity particulars – such as your name, mailing and/or physical address, delivery address, telephone numbers and e-mail address;
- personal information we collect from you when you complete a Customer Account Application Form;
- personal information we collect from you when assessing, processing and managing an application by you for commercial credit;
- Personal information you provide to us when you participate in a promotion, promotional activity, survey, market research, subscribe to our mailing list;
- Your bank, credit or debit account details when you make a purchase;
- Your records of communication with us;
- If you visit our website, your website usage information such as your IP address.
3. The purpose for collecting your personal information
We will generally only collect and use your personal information for the primary purposes of:
- Our general business operations;
- Effectively providing you with our goods and services;
- Where applicable, assessing and processing an application for commercial credit, and for administrative purposes in relation to the ongoing management of your commercial credit arrangement;
- Communicating with you;
- Responding to your inquiries or complaints;
- Meeting our legal and regulatory obligations;
- Conducting, improving and developing a relationship with you;
- Direct marketing (such as providing you with information about our products and promotional notices and offers); and
- Conducting business on our website, and improving our website.
- Your personal information is only collected by lawful and fair means and where practicable, only from you or from a person acting or authorised to act on your behalf. Where you have applied for commercial credit account with us, we may also make enquiries in respect of commercial credit with third parties with your consent. This could include persons nominated by you as trade references, credit reporting bodies and your bankers.
We will take reasonable steps to ensure that you are aware of:
- The likely use of the information;
- The right of access to the information;
- The identity and contact details of our employee/representative collecting your personal information;
- Any law requiring collection of the information; and
- The main consequences of failure to provide your personal information.
4. How we may use and disclose your personal information
We may use your personal information for:
- The primary purposes for which it was collected, such as those described above;
- Assessing and processing an application for, or administrative and management of, a commercial credit account with us;
- Administering and responding to your enquiry or feedback about our products and/or services;
- Conducting, and allowing you to participate in, a promotion, promotional activity, survey, market research or customer behavioural activity;
- Promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing);
- Improving the use and operation of our website.
We do not disclose personal information to third parties unless we are permitted to do so by law or you have given us your consent to do so. Third parties we may disclose personal information to include:
- other companies in Protecta;
- our advisers (including our accountants, auditors and lawyers);
- our service providers, including IT service providers, web-hosting organisations, delivery companies, mail houses, third party fulfilment centres, market researchers, billing and debt recovery providers and other companies who are responsible for parts of our product or service delivery;
- suppliers and manufacturers;
- payment system operators and financial institutions;
- government agencies; and
- third parties if required by law or legal process.
We may occasionally disclose your personal information to organisations located overseas, for example where:
- we use service providers, cloud computing solutions or data storage based overseas;
- we, or our related companies, have offices overseas;
- you have requested a product or service that involves an international element;
- we need to comply with foreign legal or regulatory requirements; or
- an international payment has been made.
We require overseas recipients of your information to use personal information only for the purpose provided and to implement strict confidentiality and data protection arrangements.
We do not disclose your personal information for any secondary purposes unless your consent has been given or as required by law, and we will not sell or license any personal information that we collect from you.
5. How your personal information is stored and secured
We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.
If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable.
We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if we no longer need to retain it. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.
6. Using our Website and Cookies
As with most websites, when you visit our websites or use an application on our websites, we may record anonymous information such as IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.
We also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website, but the website may be limited in the use of some of the features.
7. Marketing and Opting-Out
We may use your personal information for:
- Promoting and marketing of our current and future products and services;
- Informing you of upcoming events and special promotions and offers; and
- Analysing our products and services so as to improve and develop new products and services.
We may exchange your personal information between our related entities and so they can also assist in the marketing of our products and services to you.
We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you.
If you do not wish to receive these communications you can opt-out by contacting us at the address shown below.
8. Cross border disclosure
We will not disclose or transfer your personal information to any party located outside of Australia.
However, in the event that your personal information is required to be processed by, or disclosed to employees, representatives, or other third parties operating outside of Australia engaged by us for the purposes of our business functions and activities, we will take reasonable steps, in the circumstances, before your personal information is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach privacy laws in relation to your personal information (‘the reasonable steps’).
The reasonable steps may not apply if you consent to the disclosure of your personal information to an overseas recipient and we reasonably believe that the overseas receipt is subject to laws that are suitability similar to privacy laws in Australia.
If you consent to the disclosure of your personal information to an overseas recipient, the overseas recipient may not be accountable under the Privacy Act, and you will not be able to seek redress for breaches under the Privacy Act.
9. Accurate and up-to-date information
We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating its records whenever true and correct changes to the data come to its attention.
If you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting our Privacy Officer. To contact our Privacy Officer please see contact details below in paragraph 16.
We will correct information we hold about you if we discover, or you are able to show to a reasonable standard, the information is incorrect. If you seek correction and we disagree that the information is incorrect, we will provide you with its reasons for taking that view.
We disregard information that seems likely to be inaccurate or out-of-date by reason of the time that has elapsed since it was collected or by reason of any other information in our possession.
10. Access to your personal information
We acknowledge that you have a general right of access to information concerning you, and to have inaccurate information corrected. You are able to access the personal information we hold about you by contacting our Privacy Officer. If access is refused to your personal information for reasons permitted by the Privacy Act, we will give you a notice explaining our decision to the extent practicable and your options.
To contact our Privacy Officer please see contact details below. If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons. We may charge a reasonable administration fee to cover the costs of meeting your request. We will reply to your request for access within 30 days of notification by you.
11. Dealing with unsolicited information
We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately.
12. Anonymity when dealing with us
Only where it practicable to do so, we may allow you the option not to identify yourself when dealing with us.
13. Collecting sensitive information
14. Government identifiers
We do not use government identifiers (e.g. tax file numbers or Medicare numbers) to identify individuals.
15. Complaints and disputes
We will ensure your compliant is handled by our Privacy Officer in an appropriate and reasonable manner. Where necessary we may consult with our related entities and partners in order to deal with your complaint. A written notice of our decision regarding your complaint will be provided to you. If you are not satisfied with the outcome, then you may contact the Office of the Australian Privacy Commissioner:
Office of the Australian Information Commissioner Website: www.oaic.gov.au
Phone: 1300 363 992.
16. Who should you contact for further information?
13 Rachael Close
Silverwater, NSW, 2128AUSTRALIA
Telephone: +612 9334 2999
Email: [email protected]