1. Privacy Act

Allshelter Pty Ltd (ABN 55 163 288 355) and its Australian related bodies corporate (we, us, our) are organisations and “APP Entities” for the purposes of the Privacy Act (Act), and are bound by the Australian Privacy Principles contained in the Act.

We understand that your privacy is important and we are committed to safeguarding personal information about individuals that we handle.  This Privacy Policy describes generally how we manage this personal information and protect privacy, including how we comply with the Act and the Australian Privacy Principles.

This Privacy Policy is intended to provide a general overview of our policies in respect of the handling of your personal information.  “Personal information” is essentially information or an opinion about an identified or reasonably identifiable individual.

Other policies may override or complement this Privacy Policy in certain circumstances.  For example, when we collect personal information from you, we may advise a specific purpose for collecting that personal information, in which case we will handle your personal information in accordance with that purpose.

This Privacy Policy is intended to cover most personal information handled by us, but is not exhaustive.  If you have any queries about our handling of your personal information, please contact us for further information using the details below.

2. Collection of personal information

We may collect your personal information throughout the course of your interaction with us (for example, if you obtain products or services from us, subscribe to our mailing list, fill out an online contact form, engage with our online marketing or submit an enquiry to us).  The personal information that we may collect and hold about you depends on your dealings with us.  Generally, we may collect:

• your name and address, email address, telephone number and fax number;
• payment details;
• business details; and
• other personal information that we require or that you volunteer to us (such as your resume, details of your qualifications, skills, education provider, work history and residency status in the event that you apply for employment or a position with us).

Generally speaking, we collect personal information so that we can provide better services to you and ensure that you have convenient access to our services.

We will collect your personal information directly from you unless it is unreasonable or impracticable to do so.  If circumstances require, we may collect personal information about you from third parties (such as your employees, representatives or personal referees) or publicly available resources.  All personal information we collect is limited to that which is reasonably necessary for our functions or activities.

We receive any personal information that you provide to us from third parties (for example, an employee of your business or a referee) on the understanding that we have that individual’s consent for us to collect and handle their personal information in accordance with this Privacy Policy.

When collecting your personal information, we will take reasonable steps to make you aware of the purposes for which we are collecting it, the types of organisations to which we would usually disclose it, whether we are likely to disclose it to overseas recipients (and where practicable the countries in which they are located), whether there are laws or court/tribunal orders which require or authorise us to collect it, and the main consequences for you if you fail to provide it to us.  This Privacy Policy provides these details as they typically apply in most cases, however different details may apply depending on our specific interaction with you.  If we do not notify you of such other details, the information in this Privacy Policy applies.

If you fail to provide personal information requested by us, or if the personal information you supply is incorrect or incomplete, there may be a range of consequences, for example we may be unable to process or respond to your request.  There will not usually be Australian laws or court/tribunal orders which require or authorise us to collect your personal information.

We do not generally collect sensitive information.  If we do collect sensitive information about you  (which may include your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability), we will only do so with your consent and if the information is reasonably necessary for one of our functions or activities.  We will assume you have consented to us collecting, using and disclosing (in accordance with this Privacy Policy) all information that you provide to us, including any sensitive information, unless you tell us otherwise at the time of collection.

3. Use of personal information

We will generally only use your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.

We generally use personal information for the following purposes (as applicable in the circumstances):

• to provide products or services to you or for your benefit;
• to provide information that you request, to respond to your enquiries, or otherwise achieve the purpose for which you have contacted us;
• to handle payments;
• to assess your eligibility for credit terms;
• to provide you with marketing and promotional material regarding our products or services, including newsletters or other materials;
• to seek feedback from you and perform market research, so that we can gauge your satisfaction with our products or services;
• for our general business operations (such as maintenance of our business records and compliance with our legal and insurance obligations); and
• to engage in other activities where required or permitted by law.

By providing us with your personal information, you consent to us using your personal information for these purposes.

You agree that we may send you marketing or promotional communications by post or by electronic means (including email and SMS).  You may request not to receive such material from us by contacting us via the details below or by using the opt-out function provided for in those communications.  If you do not opt-out in either of these ways you will be taken to have consented to receiving such communications from us.

There are no consequences of opting-out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to re-join our marketing list at a later stage if you wish.

Where we propose to use your personal information for a purpose other than as outlined above, we will seek your permission (unless we are required or permitted by law to do so without seeking consent).

4. Storage of personal information

We take reasonable steps to protect your personal information from misuse, interference and loss as well as unauthorised access, modification or disclosure.

For example, information stored on our computer network is protected by security features and procedures.  We undertake regular monitoring of our practices and systems to ensure the effectiveness our security policies and identify and implement improvements where appropriate.

We make use of cloud-based services for our business systems.  Our data may be stored with these cloud providers in locations outside of Australia.

Generally, we will take reasonable steps to destroy or permanently de-identify your personal information as soon as it is no longer required by us.  We may retain your personal information where we are required or permitted to do so by law, such as for insurance, legal or corporate governance purposes and for the prevention of fraud.  Your personal information may also be retained in our IT system back-up records.

5. Disclosure of personal information

We will generally only disclose your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.

We may disclose your personal information to the following third parties (as applicable in the circumstances):

• certain suppliers that provide services to us (for example, subcontract product manufacturers, market research companies or other service providers). We generally ensure such organisations are contractually required to ensure that information we disclose is used only for the limited purposes for which we provide it;
• credit reporting bodies, in accordance with section 7 below;
• contractors that we engage as part of providing services to you; or
• members of our corporate group.

We are not generally likely to disclose personal information to overseas recipients, except with your consent or where we are required to or authorised to do so by law.

6. Access to and correction of personal information

You may contact us to request access to or correction of the personal information we hold about you.  We may refuse to allow access or to amend your personal information if we are legally required or entitled to do so.  If we do so, we will provide you with written reasons for the refusal (unless it is unreasonable to do so) together with information about the options available to complain about the refusal.

We may require you to pay certain costs in order to access your personal information held by us.  We will advise the amount payable (if any) once we have assessed your application for access.  We will not however charge a fee for you to lodge a request for access to or correction of your personal information.

If you lodge a request for access to your personal information, we may fulfil that request in any of a range of ways (for example, by supplying you with a copy of that personal information or providing you with the opportunity to inspect our records).  We may require you to comply with certain procedures before we allow access to or amendment of your personal information to ensure the integrity and security of information that we hold.  Depending on the nature of your request, this may include completing a personal information request form or otherwise verifying your identity to our satisfaction.

We will take reasonable steps to ensure that the personal information that we collect is accurate, up-to-date and complete and the personal information we use and disclose is accurate, up-to-date, complete and relevant.  If we are satisfied that any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will amend our records accordingly.

Please notify us if your personal details change so that we may keep our records current.

7. Credit information

If you are an individual we may disclose your personal information, including your credit eligibility information, to a credit reporting body in order to seek a copy of your consumer credit report.

We may disclose your credit eligibility information in order to:

• assess an application by you for consumer credit (including a request to defer payment for goods or services) or commercial credit (where you have consented to us obtaining your consumer credit report for that purpose);
• enable us to collect any overdue payments that relate to consumer credit provided by us;
• assess whether to accept you as a guarantor in relation to an application for credit made by someone else (where you have consented to us obtaining your consumer credit report for that purpose).

You consent to us and our agents making such enquiries as we deem necessary to investigate your credit worthiness from time to time including (without limitation) with other entities which in our opinion you may have had dealings with, your bankers, any credit provider or credit reporting body.

8. Online privacy

This section of our Privacy Policy sets how we handle your personal information in respect of online services provided by us (which includes any services provided by us via the Internet, such as our website, and also includes email communications between us).

8.1. Automatic server logs
Our servers automatically collect various details when you use our website, including:

• • your IP (Internet Protocol) address (generally, an identifier assigned to your computer when it is connected to the Internet);
  • the operating system and Internet browser software you are currently using; and
  • the data you access (such as web pages or other document files or software), and the time that you access it.

We do not attempt to identify individuals using this information, and only use it for statistical analysis, system administration, and similar related purposes.  This information is not disclosed to any other party.

8.2. Cookies
Our website uses “cookies”, which identify your computer to our servers when you visit our website.  Our website may store cookies on your computer in order to improve and customise your future visits to the website.  By using cookies, our site can provide customised content to you.  If you do not want information collected through the use of cookies, you may be able to configure your Internet browser to disable cookies.

We do not attempt to specifically identify and track individuals using cookies.

8.3. Google AdWords Remarketing
We use a Google AdWords advertising feature called Remarketing, as well as Google Analytics services.  These services make use of cookies and similar technologies, analytics and other identifiers to collect data about website traffic. For more information about Google Analytics and how it collects and processes data, see https://support.google.com/google-ads/answer/2453998.

These features also allow our advertisements to be displayed to individuals that access our website when they subsequently visit other websites across the Google Display Network, and allow us to better understand how individuals interact with those advertisements and our website generally.  For example, third-party vendors may use cookies to select advertisements based on an individual’s browsing history including previous visits to our website.  Our use of Google services (and in particular, Remarketing) assists us in identifying and providing services to current and potential customers.

Users can usually block cookies, or remove cookies, by editing the privacy and security settings of their web browser or mobile device.  Some features of our website may require cookies to function properly.  If cookies are disabled or deleted, then depending on the particular cookie that is deleted or disabled, users may not be able to use such features of our website, or previous opt-outs may be undone.

By using our website, individuals consent to the storing and accessing of cookies or other information on their device for the purposes of Google AdWords and Analytics, unless they have opted out.  It is possible to opt out of Google AdWords and Analytics advertising features, such as interest based advertising served by Google on its products or across the Google Display Network, as well as prevent the collection of certain data, by visiting the Google Ads Settings website or through other available means.  The Google opt-outs do not stop all advertising.  Google may still serve advertising that is not interest based, and the user may still receive interest based advertising that is not served by Google.

8.4. Email and messages
We may collect personal information from you (such as your name and email address, and any other personal information you volunteer) if you send us email.  We will use this to contact you to respond to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations.  We will not use or disclose any such personal information for any other purpose without your consent.

8.5. Storage and transmission of personal information online
If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).

8.6. Other online services
If any of our online services (including any email messages we send to you) contain links to other online services that are not maintained by us, or if other services link to our online services, we are not responsible for the privacy practices of the organisations that operate those other services, and by providing such links we do not endorse or approve the other services.  This Privacy Policy applies only in respect of our online services.

9. Data breach

If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals.  In such a situation we will comply with the requirements of the Act which may require notification to the Office of the Australian Information Commissioner (OAIC) and affected individuals.  Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk mitigation and notification activities as required.

10. Complaints

If you have a complaint about the way in which we handle your personal information, or you believe that a breach of your privacy has occurred, please contact us using the details below.

Your complaint will be considered and dealt with by our nominated representative, who may escalate the complaint internally within our organisation if the matter is serious or if necessary to resolve it.

Please allow us a reasonable time to respond to your compliant.  If you are not satisfied with our resolution, you may make a complaint to the OAIC whose contact details can be found at: http://www.oaic.gov.au/.

11. Changes to our Privacy Policy

We reserve the right to amend this Privacy Policy at any time.  We publish our current Privacy Policy on our website, and you may obtain a copy of our Privacy Policy from that website or by contacting us.

12. Contact details

If you would like further information about the ways we manage your personal information, please contact us by telephone on 1800 90 8888 or by email at sales@allshelter.com.au.