We are committed to protecting the privacy of the personal information it collects and receives. We are bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth).
- the kinds of personal information that we collect and hold;
- how we collect and hold your personal information;
- why we collect, hold, use and disclose your personal information;
- how you may access and seek the correction of your personal information as held by us;
- how you may complain about a breach of the APPs or a registered APP code (if any) that we are bound by, and how we will deal with such a complaint; and
- if we are likely to disclose your personal information to overseas recipients and the countries in which such recipients are likely to be located (if it is practicable to specify those countries in this policy).
2. Your Personal Information
We only collect personal information (being information that identifies or could reasonably identify an individual) where we consider it to be reasonably necessary for our functions and activities.
We collect personal information to service the needs of our customers including:
- acquiring our products and services;
- facilitating use of our products and services;
- subscribing to our mailing list;
- using our websites;
- addressing requests for information about us;
- collecting our survey information;
- distributing our loyalty programs and/or
- participating in our promotional activities or events.
The types of information we collect includes:
- contact details (including phone, fax and e-mail);
- information about use of our products and services;
- name, age, address, e-mail address;
- your interests, opinions and background information so we can better interact with you in the future and better understand your needs as a customer; and
- billing information.
3. Your Sensitive Information
Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
It is our policy to only collect your sensitive information where it is reasonably necessary for our functions or activities and either you have consented or we are required or authorised under law to do so.
4. How we collect your personal information
We will solicit your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so. We will collect directly personal information:
- by email;
- over the telephone;
- by written correspondence (such as letters, faxes);
- on hard copy forms (including registration forms, warranty documentation, competition entry forms and surveys);
- in person (at job interviews, seminars or events);
- through our websites (online purchases, web form submission or participate in a live chat);
- electronic systems such as applications and social media;
- through our security surveillance cameras; or
- via our loyalty programs and promotional activities.
We may collect your personal information from third parties including:
- your legal representatives;
- authorised agents and dealers;
- direct marketing database providers;
- Australian Tax Office (ATO) or Australian Securities and Investment Commission (ASIC); or
- public sources (phone directories, membership lists, professional and trade associations, ASIC, bankruptcy or court registry searches).
5. Unsolicited personal information
Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as a job application sent to us by an individual on their own initiative, rather than in response to an advertisement).
We may keep records of unsolicited personal information if the information is reasonably necessary for one or more of our functions or activities. If not, it is our policy to destroy the unsolicited information or ensure that the information is de-identified, provided it is lawful and reasonable to do so.
6. Using your personal information
The main purposes for which we collect, hold, use and disclose personal information are to provide services and benefits to customers, and to maintain, extend and grow our customer base and network of dealers.
We collect information to service your requirements. We can use your information to:
- ensure your purchase of our products or services is correctly recorded and maintained;
- manage your product warranty;
- advise you if a product recall is required;
- keep you up to date with developments relating to our products and services;
- make you aware of special offers;
- enhance the quality of our products and services;
- assessing your application (if you are applying for a position with us);
- addressing any inquiries you may have;
- improve your browsing experience on our websites;
- manage and run our websites;
- deliver our products and services;
- maintain contact with you about us; and/or
- any other purpose directly related to our work and for which you have provided consent (where it is reasonably required by law).
Our websites require subscriptions or registrations to use certain services, functions or content.
You will know what information is being collected via these processes when you complete the relevant forms and provide the required details prior to submitting the application. We will collect data relating to any transactions you carry out through our websites and the fulfilment of your order.
We may also use your data to monitor for any unauthorised use of our websites, social media, content or subscriptions to our products and services.
7. Purpose of collection
If we collect personal information for a purpose (the primary purpose), we will not use or disclose the information for any other purpose (the secondary purpose) unless:
- you would have consented to the use or disclosure of the your personal information; or
- in relation to the use or disclosure of your information:
- you would reasonably expect us to use or disclose your information for the secondary purpose and the secondary purpose is directly related to the primary purpose (sensitive information) or related to the primary purpose (not sensitive information);
- use or disclosure is required or authorised under Australian law or a court/tribunal;
- a permitted situation exists in relation to our use or disclosure of the information;
- a permitted health situation exists in relation to use or disclosure of the information; or
- we reasonably believe that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
If we use or disclose your personal information because we reasonably believe that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, we will make a written note of the use or disclosure.
8. Do you have to provide personal information?
You can refuse to provide personal information. However a refusal may mean that the product or service you requested is not provided.
9. Sharing your personal information
We may use and disclose personal information for related purposes to third parties. Types of organisations to whom we may disclose your personal information includes:
- government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority and the police or courts (as required by law);
- our dealer network;
- our contracted service providers including:
- market researchers;
- information technology service providers;
- marketing and communications agencies;
- mailing houses, freight and courier services;
- external advisers (recruiters, auditors and lawyers);
- credit providers and agencies;
- printers and distributors of marketing material; and
- professional or government agencies.
We do not provide, rent, sell or exchange your information to third parties without your prior approval.
10. Government Identifiers
We do not adopt, use or disclose government related identifiers (such as a Medicare number or driver’s licence number) as our own identifier for you unless:
- it’s required/authorised by law or court/tribunal order;
- it’s reasonably necessary for us to verify your identity;
- it’s reasonably necessary to fulfil our obligations; or
- we believe it is reasonably necessary for one or more enforcement related activities.
To improve our services, we sometimes collect de-identified information from web users. Although the information collected does not identify an individual, it does provide us with useful statistics that permits us to analyse and improve its web services.
When you visit our websites, a record of your visit is logged and the following data is supplied by your browser:
- your IP address and/or domain name;
- your operating system (type of browser and platform);
- the date, time and length of your visit; and
- the resources you accessed or downloaded.
We use this information to customise information for website visitors and to collect aggregated data for the purposes of analysis, quality control, administering and improving the websites.
Aggregated data may be shared with third parties. You can stop your browser from accepting new cookies or disable cookies altogether by changing your browser preferences.
12. Links to other websites
13. Direct Marketing
If we hold your personal information, we may use or disclose that information (other than sensitive information) for direct marketing if:
- we collected the information from you; and
- you would reasonably expect us to use or disclose the information for that purpose; and
- we provided you with a simple way to opt out of receiving direct marketing from us; and
- you have not made an opt out request to us.
We may also use or disclose your information (other than sensitive information) for direct marketing if:
- we collected the information from you and you would reasonably expect us to use or disclose the information for that purpose or someone other than you; and
- you have consented to the use or disclosure of the information for that purpose; or
- it is impracticable to obtain that consent; and
- we provided you with a simple way to opt out of receiving direct marketing from us; and
- in each direct marketing communication with you:
- we includes a prominent statement that you can request to opt out; or
- we otherwise draw your attention to the fact that you can request to opt out; and
- you have not made such a request to us.
We can use or disclose your sensitive information for the purpose of direct marketing if you have consented to the use or disclosure of that information for direct marketing.
We may also use or disclose your personal information for direct marketing if:
- we are a contracted service provider for a Commonwealth contract; and
- we collected your information in order to meet an obligation under that contract; and
- the use or disclosure is necessary to meet (directly or indirectly) such an obligation.
If we have collected the personal information that we used to send you direct marketing material from a third party, you can ask us to notify you of its source of information. It is our policy is to do so unless it is unreasonable or impracticable.
14. How to opt out of direct marketing
If we use or disclose your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from us.
If we use or disclose your personal information for the purpose of facilitating direct marketing by other organisations, you may request that we do not use or disclose your information for this purpose.
We will give effect to your request not to receive direct marketing free of charge within a reasonable time after the request is made.
15. Collection Notices
At or before the time of collection of personal information from you, or as soon as practicable afterwards, we will take reasonable steps to notify you or to otherwise ensure that you are aware of:
- our contact details;
- the fact that we collect, or have collected, your personal information and the circumstances of that collection (if collected from someone other than you);
- if the collection is required by law or an order;
- why the information was collected by us;
- the consequences to you if we do not collect all or some of your personal information;
- any other entity, body or person, or the types of any other entities, bodies or persons, to which we usually disclose personal information;
- if we are likely to disclose your personal information to overseas recipients and if so, the countries in which such recipients are likely to be located (if it is practicable to specify those countries or to otherwise make the individual aware of them); and
- you may access personal information held by us and seek correction of the information;
- you may complain about a breach of the APPs, or a registered APP code (if any) that we are bound by and how we will deal with a complaint.
We will generally include these matters in a privacy collection notice. For example, where personal information is collected on a paper or website form, we will include a collection notice, or a clear link to it, on the form.
16. Protecting your personal information
We store information in different ways, including paper and electronic form. We take reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure.
We can’t guarantee information will be protected from unauthorized access or misuse and doesn’t accept any liability for improper actions of unauthorised third parties.
We will retain your information for as long as necessary to fulfil our obligations to you, to protect our legal interests, to comply with the law or as otherwise stated when we collected your information.
Once we are no longer required to retain your information, we will take reasonable steps to destroy your personal information or to ensure that it is de-identified.
17. Disclosing your personal information overseas
We may disclose your personal information to other third party service providers operating outside Australia who work with us or one of our suppliers, agents, or partners.
We may also store your personal information on servers based overseas or in the “cloud” or other types of networked or electronic storage.
Before disclosing your personal information to an overseas third party, we will first take reasonable steps to ensure that the overseas recipient:
- does not breach the Australian Privacy Principles in relation to your personal information; or
- the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting your personal information in a way that is substantially similar to the way in which the Australian Privacy Principles protect the information.
Personal information may be disclosed by us to other entities and third parties in jurisdictions including: United States of America and Netherlands. The European Commission has recognized each of these countries as providing adequate protection of personal information.
You acknowledge that by providing consent:
- we will not be required to take steps as are reasonable in the circumstances to ensure that such third parties comply with the APPs;
- if the overseas recipient handles your personal information in breach of the APPs, we will not be liable under the Act and you will not be able to seek redress under Act.
- the overseas recipient may not be subject to any privacy law or principles similar to the APPs;
- you may be unable to seek redress overseas; and
- the overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
If you withdraw consent, wewill not rely on this consent when dealing with your information going forward.
You have the option of not identifying yourself or using a pseudonym when dealing with us provided that is it lawful and practicable.
We will try to accommodate a request for anonymity if possible. However, your right to anonymity does not apply in relation to a matter if we are required or authorised by or by law or a court/tribunal order to deal with individuals who have identified themselves or it is impracticable for us to deal with individuals who have not identified themselves.
It is our policy to enable you to access our websites and make general phone queries without having to identify yourself and to enable you to respond to our surveys anonymously.
In some cases however, if you don’t provide us with your information when requested, we may not be able to respond to your request or provide you with the requested service.
19. Accessing to your personal information
You have the right, upon request, to access any of our records containing your personal information.
To request access to your personal information please contact our privacy officer. We will respond to your request to access your personal information within a reasonable period of time.
Where reasonable and practicable, we will give you access to the information requested.
If we refuse your request to access personal information, we will provide a written notice setting out the reasons for the refusal and how you can complain about the refusal.
Reasons for a refusal may include if it:
- poses a serious threat to the life, health or safety;
- would have an unreasonable impact on others’ privacy;
- is frivolous or vexatious or unlawful
- relates to legal proceedings;
- would reveal our intentions or prejudice any negotiations;
- is required or authorised by law or court/tribunal order;
- would be likely to prejudice one or more enforcement related activities; or
- relates to commercially sensitive decision making.
When you request to access information, we will require you to provide some form of identification to verify that you are the person to whom the information relates.
20. Keep your personal information accurate
We will take reasonable steps to ensure our records are accurate, up to date and complete. However, the accuracy of information depends on the information you provide. If you do not give us all the personal information we require, or the personal information provided is inaccurate or incomplete, the information we provide may be affected.
If you think there is something wrong with the information we hold about you please contact our Privacy Officer to let us know if there are any errors and keep us up-to-date with any changes and we will try to correct your information.
We will respond to your request to correct your information free of charge and in a reasonable period of time. If we refuse your request, we will provide you with a written notice setting out the reasons for the refusal and mechanisms available to complain about the refusal.
If we refuse to correct your personal information, you may request that we associate your information with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take reasonable steps to make the statement visible to users of your information.
If we do correct your information and we have previously disclosed your information to a third party, upon your request, we will notify that third party of the correction unless it is impracticable or unlawful to do so.
21. Dealing with SPAM
We will not send you any commercial electronic messages (SMS or emails) unless it is permitted by the Spam Act. Any commercial electronic message that we send will identify us as the sender and will include relevant contact details and an unsubscribe facility.
If you do not wish to receive commercial electronic messages from us, please contact the privacy officer.
22. Do not call register
We will not call you on a number listed on the Do Not Call Register unless it is permitted under the Do Not Call Register Act and related instruments (for example, if we have your express or inferred consent to do so).
If you do not wish us to call you on a particular number, please contact the privacy officer.
23. Resolving your privacy issues
If you have any issues you wish to discuss with us or if you’re concerned about how we have collected or managed your personal information please contact the privacy officer.
For information about privacy or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
26. Our privacy officer
Our privacy officer can be contacted at:
Telephone: (03) 9721 1500
Fax: (03) 9720 4144
Post: 64 Canterbury Rd, Bayswater Vic 3153.