Privacy Policy
1. Introduction
1.1 We are bound by the provisions of the Privacy Act 1988 (Cth), including the Australian Privacy Principles [“APPs”].
1.2 Nothing in this privacy policy is intended to derogate from any rights you might have under the APPs and any inconsistency in this policy with the APPs shall be read down to the extent of the inconsistency.
2. Your right to anonymity or pseudonymity
2.1 In all of your dealings with us you have the right to either:
a) not identify yourself;
b) remain anonymous; or
c) use a pseudonym –
in relation to a particular matter.
2.2 In some circumstances it will be impractical for us to provide services to you if you choose not to indentify yourself to us.
3. Kinds of personal information we collect
3.1 We may obtain and retain the following types of personal information:
a) your name, address and telephone numbers;
b) your email address(es), domain name(s) and/or IP address(es);
c) the type of browser you are using;
d) the date and time of contact with us; and/or
e) your buying, selling and/or website usage behaviour –
[collectively the “Information”].
3.2 We do not collect “sensitive information” about you (such as an individual’s medical or health information, racial origins, political or religious opinions and/or membership of political parties, trade unions, professional or religious organisations).
4. Methods of collection of Information
4.1 We may collect personal information when we come into contact with you such as through meetings, telephone conversations, via email and other written correspondence and from business cards supplied to us by you.
4.2 We also use data collection devices such as “cookies” on certain parts of our website. Cookies enable us to collect Information and are stored on your computer hard drive rather than on our website.
4.3 In some circumstances we also collect unsolicited personal information supplied to us by third parties. In this event, we will:
a) only retain such information once we have determined that we could have collected such personal information from you under items 4.1 or 4.2 above; and
b) as soon as practicable take reasonable steps to notify you of:
i. our collection of your personal information and the circumstances of that collection; and
ii. our Privacy Policy.
4.4 We do not purchase or collect unsolicited personal information in bulk format, such as distribution, contact or marketing lists.
5. Storage of personal information
5.1 We store personal information in the following locations:
a)on our fileserver located in our offices in Melbourne;
b) on external customer relationship management software hosted on fileservers located in Japan; and
c) on individual contact lists connected to our use of smart phones which are hosted on or backed up to fileservers located in the United States of America.
5.2 We shall take such steps as are reasonable in the circumstances to:
a) safeguard any personal information collected by or provided to us and we shall use reasonable endeavours to keep all personal information confidential; and
b) ensure that any third parties (including any overseas recipient hosting facilities on which data is stored on our behalf) does not breach the APPs other than APP1.
6. Use and disclosure of personal information
6.1 We shall not use or disclose the Information save to the extent:
a) indicated at the time of supply of the Information;
b) expressly permitted under any agreement with you;
c) necessarily required for the performance of services for you;
d) required for the ordinary operation of our website and/or our business (ie. as part of any explanation about our services);
e) required for dispute resolution;
f) required in order to identify fraud, solve problems and/or maintain a safe environment;
g) necessary to work for you, bill you, purchase from you, provide you with support and contacting you, improve our marketing and promotional efforts, analyse site traffic and usage, improve our website and/or send you information relevant to you and your interests;
h) required under compulsion of law or provided in co-operation with any governmental authority; and/or
i) that such Information is already publicly available or is disclosed by any party (including by us or by you) in a manner which does not readily permit identification of you or the Information.
6.2 We shall not use or disclose the Information other than in accordance with the primary purposes set out in item 6.1 above.
6.3 We will maintain written notes in relation to any disclosure of the Information to any enforcement body conducting enforcement-related activities.
6.4 We will not use or disclose the Information for the purpose of direct marketing other than in furtherance of the provision of our services as set out in item 6.1 above.
7. Quality of information
7.1 We shall take such steps as are reasonable in the circumstances to ensure that the Information is accurate, up-to-date and complete.
7.2 We shall take such steps as are reasonable in the circumstances to ensure that any Information disclosed by us under this Privacy Policy is accurate, up-to-date, complete and relevant having regard to the purpose of the intended use of such disclosure.
8. Security of information
8.1 We shall take such steps as are reasonable in the circumstances to protect the Information from:
a) misuse, interference or loss; and
b) unauthorised access, modification or disclosure.
8.2 We shall take such steps as are reasonable in the circumstances to ensure that we destroy any Information where:
a) we have formed the view that we no longer require the use of the Information for any purpose for which it may be used or disclosed; and
b) we are not obliged to retain the Information for the purposes of complying with any law or any Court or tribunal order.
8.3 We shall not be liable in any way in relation to any breach of security or unintended loss or disclosure of the Information due to our website being linked to the internet.
9. Access to Information
9.1 You may request access to any Information we hold about you at any time. We may charge you a fee where access is provided and/or refuse to provide access if permitted by law to do so.
9.2 We agree to respond to any request for access to the Information:
a) within a reasonable time period; and
b) in such manner as you request as long as it is reasonable and practicable to do so.
9.3 If we refuse to grant access to any Information or refuse to provide access in the manner requested by you we shall:
a) provide you with a written notice setting out the reasons for our refusal; and
b) the mechanisms available to complain about the refusal.
10. Corrections to Information
10.1 You may request corrections to any Information we hold about you at any time.
10.2 We may make corrections to any Information we hold about you at any time.
10.3 We agree to respond to any request for corrections to the Information within a reasonable time period.
10.4 If we refuse to make any correction to any Information requested by you we shall:
a) provide you with a written notice setting out the reasons for our refusal; and
b) the mechanisms available to complain about the refusal.
10.5 If:
a) we make a correction to Information which has been previously disclosed to another APP entity; and
b) if you request us to do so –
we shall take such steps as are reasonable in the circumstances to notify the other APP entity of the correction.
10.6 If:
a) we refuse to make a correction to Information requested by you; and
b) if you request us to do so –
we shall take such steps as are reasonable in the circumstances to associate the Information with a statement that the individual concerned believes that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
11. This privacy policy
11.1 This Privacy Policy is subject to amendment at any time by us.
11.2 Kindly direct all queries in relation to this Privacy Policy (including any request for access to information or any complaints) to:
The Privacy Officer
Hansen Partnership pty ltd
privacy@hansenpartnership.com.au