1.Introduction

1.1    We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, “we”, “us” and “our” refer to the owners of our website.

2.The personal data that we collect

2.1    In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2    We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

2.3    We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“).

2.4    We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.5    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.6    Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.Purposes of processing and legal bases

3.1    In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2    Operations – We may process your personal data for the purposes of operating our website and putting website users in contact with relevant services providers. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

3.3    Personalisation – We may process enquiry data, account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is consent.

3.4    Research and analysis – We may process enquiry data, usage data and/or communication data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.5    Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.6    Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.7    Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.8    Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4.Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2    We may disclose contact data along with any other personal data contained in enquiries made through our website or services to one or more of those selected third party suppliers of goods and/or services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services.

4.3    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.International transfers of your personal data

5.1    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)    enquiry data will be retained for a minimum period of 1 month following the date of the enquiry, and for a maximum period of 5 years following that date;

(b)    communication data will be retained for a minimum period of 1 month following the date of the communication in question, and for a maximum period of 5 years following that date; and

(c)    usage data will be retained for 7 years following the date of collection.

6.4    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.Your rights

7.1    In this Section 7, we have listed the rights that you have under data protection law.

7.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)    the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting the Australian Information Commissioner.

7.4    You may exercise any of your rights in relation to your personal data by written notice to us, using the contact form on our website..

8.Third party websites

8.1    Our website may include hyperlinks to, and details of, third party websites.

8.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

9.About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie is stored by a web browser and remains valid until its expiry date, unless it is deleted by the user before the expiry date. A session cookie will expire at the end of the user session once the web browser has been closed.

9.3    Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

10.Cookies that we use

10.1    We may use cookies for the following purposes:

(a)    authentication and status – to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b)    personalisation – to store information about your preferences and to personalise the website for you;

(c)    advertising – to help us to display advertisements that will be relevant to you; and

(d)    analysis – to help us to analyse the use and performance of our website and services.

11.Cookies used by our service providers

11.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2    We may use Google Analytics or other analytics software. Google Analytics and other analytics software gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. Visit Google to review their use of your information and to review Google’s privacy policy.

11.3    We may publish Google Ads on our website. The advertisements may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies. The cookies are used to track your previous visits to our website and your visits to other websites. You can opt out of Google’s personalised advertising and you can opt out of the use of third party cookies for personalised advertising. You can review Google’s privacy policy.

11.4    We may use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy and the Facebook privacy policy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements.

12.Managing cookies

12.1    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You will find up-to-date information about blocking and deleting cookies within your browser’s settings.

12.2    Blocking all cookies will have a negative impact upon the usability of many websites.