Effective starting: 1 January 2021
- how and why we collect personal information about you;
- how we use this information;
- how we store this information;
- how we disclose this information; and
- how you can exercise your privacy rights.
In the interest of protecting our employee’s health and discharging our duty of care to invitees to our premises, JJR may, during the COVID-19 Pandemic, collect and use additional sensitive personal information from our employees and visitors [to be specified if possible, e.g. such as whether they have flu-like symptoms, have been in contact with anyone infected with COVID-19, or travelled to a high-risk area]. Only the minimum necessary personal information reasonably necessary in order to prevent or manage COVID-19 in the workplace will be collected, used or disclosed. It will be managed in accordance with this policy and it will only be disclosed to the persons who need to have access to such personal information for the performance of their duties. The primary purpose for collection of that additional information is to ensure that necessary precautions are adopted in relation to that individual and any other individuals. Under most jurisdictions an exemption from any requirement for consent to collect and use is permitted in circumstances of serious threat to health or safety of an individual. JJR will comply with a specific COVID-19 guidance issued by a relevant regulator.
1. Personal Information We Collect
a) The types of personal information we may collect include:
- your name;
- your contact details, including email address, mailing address, street address and/or telephone number;
- your credit card details;
- your demographic information, such as postcode;
- your preferences and/or opinions;
- information you provide to us through customer surveys;
- details of products and services we have provided to you and/or that you have enquired about, and our response to you;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
- any other personal information requested by us and/or provided by you or a third party.
b) We may collect these types of personal information directly from you or from third parties.
2. Collection and Use of Personal Information
a) We may collect, hold, use and disclose personal information for the following purposes:
- to enable you to access and use our Site, associated applications and associated social media platforms;
- to enable us to provide services to you or our clients;
- to contact and communicate with you;
- for internal record keeping and administrative purposes;
- for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
- to run competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
- to comply with our legal obligations and resolve any disputes that we may have; and
- to consider your employment application.
3. Disclosure of Personal Information to Third Parties
a) We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- our existing or potential agents or business partners;
- sponsors or promoters of any competition we run;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia;
- third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia.
b) By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
4. Direct Marketing
a) We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
- The personal information does not include sensitive information;
- You would reasonably expect us to use or disclose the information for the purpose of direct marketing;
- We provide a simple way of opting out of direct marketing; and
- You have not requested to opt out of receiving direct marketing from us.
b) If you wish to opt out of receiving direct marketing, contact us.
c) If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent). You can easily request not to receive direct marketing communications from us by contacting us. We will draw your attention to the fact you may make such a request in our direct marketing communications.
d) You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We will give effect to the request within a reasonable time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
5. How we treat personal information that is also sensitive information
a) Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles.
b) Sensitive information means information relating to:
- an individual’s racial or ethnic origin;
- health information;
- political opinions;
- membership of a political association;
- professional or trade association or trade union;
- religious beliefs or affiliations;
- philosophical beliefs;
- sexual orientation or practices;
- criminal record;
- genetic information; or
- biometric information that is to be used for certain purposes, and biometric templates.
6. Your rights and controlling your personal information
c) Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
d) Access: You may request details of the personal information that we hold about you. Subject to exceptions in the Privacy Act, you can access the personal information that we hold about you by contacting the Privacy Officer. We will generally provide access within 30 days of your request. If we refuse to provide you with access to the information, we will provide reasons for the refusal. We will require identity verification and specific particulars of what information is required and may charge an administrative fee for searching and photocopying our records.
e) Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
f) Complaints: If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
g) Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
7. Unsolicited information
a) If we receive unsolicited personal information about you, we will destroy or de-identify this information unless it is relevant to the purposes for which we collect personal information.
8. Storage and Security
a) We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
c) We use TLS encryption and authentication and we store all of our data on servers in a secure facility. We utilise hosting and DDOS protection from DigitalPacific. We implement systematic processes and procedures for securing and storing data.
d) This site has been issued certificates from Let’s Encrypt, which are used for web services and email authentication. These certificates use a high standard of authentication and were specifically utilised to boost and maintain customer confidence in ecommerce through a rigorous verification process. You can identify this certificate by the green lock in the address bar. These certificates incorporate some of the highest standards for identity assurance to establish our legitimacy.
e) We will retain the information we collect from you for a period of 7 years, as required by law, even if you cancel your membership with us.
9. Cookies and web beacons
- We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
10. Links to other websites
- Our Site may contain links to other websites.
- JJ Ryan Consulting Pty Ltd ABN [69 145 797 726]
- Email: email@example.com
If you are not satisfied with a response, dependent on your location, you may have an option to refer your complaint to a relevant privacy regulator. We will provide you details of any relevant regulator on request.
Last updated: 18 February 2021