AV24-7 respects your rights to privacy under the Privacy Act 1988 (Cth) ('Privacy Act') and seeks to comply with all of the Act's requirements in respect of the collection, management and disclosure of personal information provided to us.
Purpose of the Policy
What personal information do we collect?
Personal information is any information that can be used to personally identify you. Some categories of personal information may include:
• Your name;
• Your email address;
• Your profession or occupation;
• Your identification card;
• Your address;
• Financial information; and
• Other relevant information.
If the information that we collect personally identifies you, or you are reasonably identifiable from it, then we will treat that information as personal information.
When you visit our website and its affiliates, or request any services or bookings from us, we may collect personal information such as your name, identification information, contact details such as telephone number and postal or email address, financial information and any other information relating to you which you may provide.
In some cases, we may collect sensitive information about you if it is relevant to the services that we provide to you.
How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. This information can include financial details. When collecting personal information from you, we may collect it in various ways, including:
• through your access to and use of our website;
• entry of all details online including payment details;
• when you register to receive any of our publications or attend any events, functions or meetings that we host or organise;
• through access to and use of affiliate websites and third-party data aggregators;
• during conversations between you and our employees or representatives; or
• when you communicate with us via email, telephone, post or fax.
We may also collect personal information about you from third parties, including from your authorised representatives or your other professional advisors to enable us to provide you with our service.
What happens if we can't collect your personal information?
In most cases, you will be required to identify yourself when you have any dealings with us, including when you use our services. In the event that you do not provide us with the personal information described above, some or all of the following may happen:
• we may not be able to accept you (or your associated company or other entity) as a client or provide our services to you or your associated company or other entity;
• we may not be able to provide you with our publications, brochures and updates; and
• we may be unable to tailor the content of our website to your preferences and your experience of our website may not be as relevant, enjoyable or useful as it could be.
For what purposes do we collect, hold, use and disclose your personal information?
We will normally hold your personal information in a database. We collect, hold, use and disclose your personal information for some or all of the following purposes:
• administering our relationship with you, including providing services, responding to enquiries and obtaining payment for our services;
• processing applications;
• business development including sending legal updates, publications, and details of events and tracking and recording your opening of our email communications and clicking on any links in our email communications;
• providing and administering legal services;
• meeting legal or other regulatory obligations imposed on us;
• auditing and managing the usage of our website;
• Marketing purposes;
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or other governmental authority.
Who do we disclose your information to?
We may disclose your personal information to:
• our employees, related entities, contractors or third party service providers in connection with the services that we are providing to you, including to our IT service providers;
• any third parties that we engage on your behalf or which you engage directly in connection with the services we are providing to you, including solicitors, auditors, accountants, third party experts and other consultants or advisors;
• our insurers and our professional advisors, including our accountants, business advisors and consultants;
• any regulatory body in any of the States and Territories that we operate in; and
• any other organisation or individual for any authorised purpose with your express consent.
Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to other third party suppliers and service providers located overseas for some of the purposes listed above.
In providing services to you, we may need to disclose your personal information to another entity in another country. This does not diminish your rights and we will take all reasonable steps necessary to ensure transferred information is kept secure as required by applicable data privacy laws. By submitting your personal information to us you agree that you do not object to any such transfer, processing or storage. If we merge, combine or divest a part of our business, we may also pass on your details to our new colleagues and the manager of any entity through which they operate unless
prohibited from doing so by law or applicable professional rules.
We may disclose your personal information outside of Australia as follows:
• to our data hosting and other service providers located internationally; and
• to any third party online purchasing terminals.
Relationship of this policy with other global policies
Under EU data protection law, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify the use of your personal data are:
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).
We note that the reasons for the usage of your data are all covered by reference to the above terms.
Business development and marketing
Occasionally we may use personal information to send you details of new services, legal updates, and invitations to seminars and events. However, we will only do this where you consent to being contacted in this way. These communications may be sent in various forms (including by post and by email) in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
If you prefer not to receive promotional material from us, please email us at firstname.lastname@example.org and put "unsubscribe" in the subject line together with the name of the publication you wish to unsubscribe from. Our email marketing communications will also include an "unsubscribe" link.
When you visit our website we may send a 'cookie' to your computer. This is a small data file stored by your computer to help improve functionality or tailor information to provide visitors to our website with more relevant pages. We may also analyse website traffic to identify what visitors find most interesting so we can tailor our website accordingly.
As our website is accessed via the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party website providers are responsible for informing you about their own privacy practices.
Security and data quality
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.
We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it.
How can you access and correct your personal information?
You may request access to any personal information that we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by posting or emailing it to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality or legal professional privilege. If that occurs, we will give you written reasons for our refusal.
If you believe that any personal information that we hold about you is incorrect, incomplete or inaccurate, then you may request that we correct it. We will consider if the information requires correction. If we do not agree that there are grounds for correction, then you may request that we add a note to the personal information stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and that your complaint is resolved within a reasonable time (and in any event within the time required by the Act, if applicable).
Our Privacy Officer can be contacted via:
9 Wurrook Circuit Caringbah, NSW
What if I wish to make a complaint to the Office of the Australian Information Commissioner?
If you are unhappy with our response to your privacy complaint or inquiry, you can make a formal complaint to the Office of the Australian Information Commissioner who oversees privacy and data compliance legislation.
The relevant information including the address of the Office of the Australian Information Commissioner can be accessed via their site at www.oaic.gov.au