Treothamacknowledges its obligations to manage your personal information appropriately and securely, including:
• complying with the Australian Privacy Principles ("APPs");
• ensuring that your personal information is managed openly and transparently;
• only collecting personal information which is reasonably necessary;
• informing you how your personal information can be used;
• advising you if your personal information needs to be disclosed to anyone else (including anyone overseas) and when this might occur;
• securing the retention of your personal information;
• providing fast responses to any request by you not to receive direct marketing material;
• ensuring the accuracy and currency of your personal information and the appropriate disposal of personal information no longer required; and
• ensuring you are able to access and correct your personal information in appropriate circumstances.
Purpose of this Policy
It is intended to clearly explain some of the key processes and procedures that we have implemented to manage your personal information, to protect your privacy and to comply with the Privacy Act 1988("Act") and the Australian Privacy Principles ("APPs").
References to "our", "us" and "we" in this policy are references to Treotham, to its website treotham.com.au and to all other social media in which we participate from time to time,and to our related entities.
Collection of Personal Information
We will only collect information that is necessary and relevant to our relationship with you andthat we reasonably require in order to satisfactorily perform the services that you require from us.
Depending on the nature of our relationship with you, we may request that you provide some or all of the following information:
• information that we may require to initially identify you, including your name, home address and your date of birth;
• information that we can use to contact you, including your telephone number, mobile number, email address, work address, mailing address;
• information we may require to confirm your identity, including your driver's licence number, passport details, business name, Medicare card;
• information that may assist us to confirm your financial position or credit history when you are considering a finance or credit arrangement, including your credit card details, bank details, purchase history or transaction details and loan and credit information where finance arrangements apply.
The Act places restrictions on us collecting sensitive information about you (which includes information about your religion, political views, ethnicity, criminal records and sexual preferences). Generally we will not collect this type of information, however we may need to collect some sensitive information if you are applying for a job with us, and you have provided us with your consent to do so.
Purpose and Type of Personal Information Collection
There are various reasons why we might need to collect, hold, use or disclose your personal information and this will depend on the specific services that we are providing to you.
We may also use your personal information for other reasons, including:
• to contact you in relation to an event, special offer or product that you might be interested in;
• preventing fraud and other criminal activities;
• to assist us to run our business and to improve our services and performance, including staff training, accounting, risk management, record keeping, archiving, systems development, developing new products and services and undertaking planning, research and statistical analysis; and
• to comply with our legal obligations.
Where necessary we collect personally identifiable information on certain areas of our website, for example, if you become a member or enter a competition. The personally identifiable information collected may consist of contact information, such as your name, email address and location.
From time to time we may invite you to answer survey questions and provide certain demographic information, such as your age, gender or location of connection (eg home or work). Your response to these types of surveys is entirely voluntary and you should feel no obligation to participate.
There is no obligation for you to provide us with any of your personal information but if you choose not to provide us with your personal information, we may not be able to provide the information, goods or services that you require.
Method of collection of personal information
The means by which we collect your personal information will depend on the nature of the service that we are providing to you.
We may collect your personal information:
(a) directly from you, either in person or over the phone;
(b) when you place an order via our Website;
(c) when you interact with ourWebsite; or
(d) from other sources.
We will always collect your personal information directly from you unless it is impracticable to do so. This would usually be done through ourWebsite when you elect to disclose your personal information to us for a particular purpose.
Where we are collecting your personal information, we will remind you of the following at the time of collecting your personal information:
(i) our details, including our contact details;
(ii) that we are collecting your information and the reasons why we are collecting your information;
(iii) if the collection is required or authorised by law, the details of the law, court or tribunal order;
(iv) what happens if we cannot collect your personal information;
(v) any third parties to whom we may disclose the personal information;
(vi) how you can access and correct your personal information;
(vii) how you can complain about any breach of the APPs and how we will handle any such complaints; and
(viii) whether your personal information is likely to be disclosed to anyone overseas and if practicable, the countries in which those recipients are located.
Collection and Disclosure of personal information about other persons
Wherever possible, we will collect personal information directly from the relevant individual to whom that information relates.
You represent and warrant to us that where you provide personal information to us about another person:
(a) you are authorised to provide that information to us;
(b) you have obtained the express consent of the individual to disclose their personal information to us for its relevant use, including for use in our business and to provide our services;
(c) you have complied with the APPs in collecting that personal information, including by making all relevant notifications required under APP 5; and
Provisions regarding unsolicited personal information
Use and disclosure of your personal information
We may use and disclose your personal information for the purposes for which it was collected or for a related purpose such as:
(a) to set up and activate your account with us;
(b) to consider your request for a product or service;
(c) to enable us to provide a product or a service to you;
(d) to coordinate delivery of your goods;
(e) to facilitate and process your orders and payments;
(f) to carry out or respond to your queries or requests;
(g) to provide information to you that you have requested;
(h) to provide additional information to you as requested by you and to respond to your queries about our products
(i) to any third party suppliers of our goods or services, including third party application owners or licensors;
(j) to any third party credit provider to facilitate the provision of credit to you as required;
(k) to our third party service providers to assist us in providing and improving our services to you, and to analyse trends in sales and better understand your needs or to develop, improve and market our products and services to you;
(l) for regulatory reporting and compliance with our legal obligations;
(m) to relevant third parties to undertake fraud checks;
(n) to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes;
(o) to perform administrative and operational tasks (including risk management, systems development and testing, staff training and collecting debts);
(p) to facilitate product reviews and to seek your feedback in relation to particular products, customer satisfaction and our relationship with you and to manage any customer complaints;
(q) for use in direct marketing of promotions, products and services that we think might be of interest to you, including to add to a database compiled by us for this purpose;
(r) to our third party service providers, for use in direct marketing of promotions, products and services that our third party service providers think may be of interest to you, including to add to a database complied for this purpose;
(s) to monitor or improve the quality and standard of service that we provide to you;
(t) to consider any concerns or complaints you may raise against us;
(u) to our agents, successors and/or assigns;
(v) to notify you of offers that may be of interest to you; and
(w) to better understand your preferences.
Your participation on our website
Sharing of your personal information.
Wherever possible, we will limit the information provided to independent third parties to that information required for those third parties to properly perform their functions. Further, our contracts with these third parties will always require the third parties to comply with the APPs (or equivalent standards).
Use your personal information for marketing related purposes
As part of the services that we provide to you, we may:
(a) use personal information that we have collected about you to identify a product or service that may benefit you;
(b) contact you from time to time to let you know about a product or service that we believe you might be interested in; and
(c)disclose your personal information to our related entities, any one or more of the Recipient Parties or to our business partners (including third party facilitators) to enable them to tell you about a product or service that you might be interested in.
You may make a request that we do not disclose your personal information to facilitate direct marketing by another organisation and you may request that we provide you with the source of any personal information we use for direct marketing purposes. Any such requests will be actioned within a reasonable period and there will be no charges to you for making, or to you from us actioning, such requests.
Storage of your personal information
We have implemented appropriate processes and techniques (including physical security and computer and network security) to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure. In addition, access to your personal information is limited to those who specifically need it to conduct their responsibilities.
We and our third party service providers take all necessary steps to destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.
While care is taken to protect your personal information on our Website, unfortunately no data transmission over the Internet is guaranteed to be as secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email as we have no way of protecting that information until it reaches us. Once we receive your personal information, we are required to protect it in accordance with the Act.
Maintenance of your personal information
We take reasonable steps to ensure that:
(a) the information that we collect about you is accurate, complete and up-to-date at the time of collection;
(b) when we use your personal information, it is accurate, up-to-date, complete and accurate at the time of use; and
(c) if we disclose your personal information, it is accurate, up-to-date, complete and accurate at the time of disclosure.
Disclosure of your personal information to overseas parties
There may be circumstances where we need to disclose personal information that we hold about you to a third party overseas ("Overseas Recipients"). This may occur, for example, where we have a database or server hosted outside Australia or where you are interacting with an application which is based overseas.
Prior to us disclosing your personal information to an Overseas Recipient, we have an obligation under APP 8.1 to take reasonable steps to ensure that the Overseas Recipient does not breach the APPs in relation to your personal information, as well as an obligation under APP 6 to only disclose your personal information to an Overseas Recipient for the primary purpose for which that personal information was collected (the "Overseas Disclosure Obligations").
We will take all reasonable steps to satisfy our Overseas Disclosure Obligations.
Access to your personal information
Usually we will be able to provide you with access to your personal information upon receipt of your written request, either by email sent to email@example.com or by post sent to 14 Sydenham Road, Brookvale NSW 2100, and confirmation of your identity.
There are some limited circumstances in which we may not be able to provide you with access to your personal information when requested. Such circumstances might include where access would pose a serious threat to the life, health or safety of another person or where such access would unreasonably impact on the privacy of others.
Where you request access to your personal information, we will respond to any such request within a reasonable period after the request is made and if possible, we will provide you with access to your information in the manner requested by you, if specified. In any event, we will take all reasonable steps to give you access to your information in a way that meets your needs.
If we deny you access to your personal information for any reason, or if we are unable to provide you with access to your information in the manner requested by you, then we will provide you with a written notice confirming:
(a) the reason for such refusal; and
(b) the procedure to complain about the refusal.
We may recover from you our reasonable costs of supplying you with access to your personal information but we will not charge you for any request you might make to access your information.
Correction of your personal information
We do what we can to ensure that the information we hold about you is accurate, complete, up-to-date, relevant and not misleading. To assist us to do this, please ensure that you provide us with correct information at the time you provide it to us and immediately inform us if your details change at any time. If we are concerned that any of your information is inaccurate, incomplete, out-of-date, irrelevant or misleading, or if you request that we correct any of your information, then we will take all reasonable steps to correct the information to ensure that it is accurate, complete, up-to-date, relevant and not misleading in the context of the purpose for which it is held.
If we correct any of your personal information and that information has previously been disclosed to another entity that is required to comply with the APPs, then, upon your request to do so, we will take reasonable steps to notify that other entity of the correction unless such notification is impracticable or unlawful.
If we refuse to correct your personal information following a request by you to do so, then we will provide you with a written notice confirming:
(a) the reason for such refusal; and
(b) the procedure to complain about the refusal.
If we refuse to correct your personal information following a request by you to do so and you request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading then we will take reasonable steps to associate the statement with the information so that the statement is apparent to users of the information.
We will respond to any requests regarding the correction of your personal information within a reasonable period after the request is made.We will not charge you for any request to correct your personal information, nor will we pass on to you any costs incurred by us in correcting your personal information or for associating a statement with your personal information.
Making complaints about some aspect of our privacy procedures
We are committed to maintaining and protecting your privacy but it is possible that in limited circumstances, mistakes might be made. If you are concerned with the way your personal information has been handled then you are entitled to make a complaint. If you would like to lodge a complaint, please contact us through Mikael Paltoft, whose details are set out below.
Mikael Paltoft, 14 Sydenham Road, Brookvale NSW 2100, firstname.lastname@example.org, 02 9907 1788
If your personal information has not been handled in an appropriate way, we will do our best to remedy your concerns as quickly as possible, including by acknowledging receipt of your complaint within 48 hours and trying to resolve the complaint within 10 working days. Where this is not possible, we will contact you within this period to let you know an anticipated time frame within which your complaint will be resolved.
If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner ("OAIC") to have the complaint heard and determined.
Protection of your identity
Wherever it is practicable, we will always provide you with the option not to identify yourself when dealing with us. Alternatively, you may elect to use a pseudonym to protect your identity.
Links to other websites
Our Website may contain links to websites which are owned or operated by other parties. You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, such websites.
Please find below our contact details. Please do not hesitate to contact us in relation to any privacy-related concerns and we will use our best endeavours to address any such concerns thoroughly and in a timely manner.
If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.
Treotham Automation Pty Ltd, 14 Sydenham Road, Brookvale NSW 2100, email@example.com, 02 9907 1788
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