Privacy Policy

Privacy Policy

PRIVACY POLICY

Outline

This Privacy Policy, which is subject to the Privacy Act and regulates how we collect, use and disclose personal information.

 

Amendment.
We may change, vary or modify all or part of this Privacy Policy at any time in our sole discretion. It is your responsibility to check this Privacy Policy periodically for changes. If we adopt a new Privacy Policy:

we will post the new Privacy Policy on the Platforms; and

it will then apply through your acceptance of it by subsequent or continued use of the website.

 

WHAT WE collect

Personal Information.
Personal information we collect about you may include identification information such as your name, position, address, email address, date of birth, gender, driver’s licence number, signature, mobile phone number, fax number, social media URLs, business references, details about your business (including but not limited to the name of your business, company data (financial ratios), company logo, subscriber employee names and titles), Australian Business Number, ANZSIC code, insurance details, rates and fees, your occupation, career history and references, employee hierarchy (including reporting lines), sales commentary (including about interaction with client), financial and payment information (including credit card and banking information) and such other information necessary or convenient for delivering our Products and Services. We also may collect additional information as part of our collection of Identity, Contact, Financial, Transaction, Technical, Marketing and Communications, Client and Profile information used for the Primary and Secondary Purposes.

 

Other information.
We may collect, and you consent to us collecting, information relating to you that is not personal information, such as data relating to your activity on our Platforms, including:

the Internet Protocol address and a component of the domain name used (e.g. .com or .net);

the type of browser and operating system you used;

the date and time you visited our Platforms;

the web pages or services you accessed at our Website;

the time spent on individual pages and our Website overall;

which files you downloaded; and

information about your computer and Internet connections using cookies.


Sensitive information.
Sensitive information is a special category of personal information and includes, but is not limited to, information about your health, race or ethnic origin, political or religious beliefs, membership of a trade union or association, or criminal record. Health information includes personal information collected from you in order to provide a health service. We also collect sensitive personal information about employees including but not limited to contracts of offer, salary details, the personal addresses of employees, customer documents uploaded by the subscriber (eg performance management letters). There are greater restrictions that apply to our collection, storage, use and disclosure of sensitive information under the Privacy Act.

We will only collect, hold, use or disclose your sensitive information with your consent or if you volunteer your sensitive information to us. If we collect or hold your sensitive information in accordance with this clause, we may disclose such sensitive information to our Related Bodies Corporate. However neither us nor our Related Bodies Corporate may use or disclose your sensitive information to any Third Party except as required or permitted by law.


HOW WE Collect

How we collect.
Your personal information may be collected:

  • when you complete an application, consent, purchase, account sign-up or similar form via our Platforms or otherwise;
  • when you register for an event or webinar or provide us with your business card;
  • when you contact us to submit a query or request (whether in writing, verbally, in hardcopy or electronic format);
  • when contact is made by either us or you by telephone, mail, email, fax or face-to-face;
  • when you post information or otherwise interact with the Platforms;
  • when you participate in one of our competitions or surveys;
  • from those who request our Products and Services on your behalf;
  • from publicly available sources of information;
  • from government regulators, law enforcement agencies and other government entities;
  • when you complete an application for, or commence, employment with us;
  • when negotiating or entering into a contracting relationship with us as an independent contractor or otherwise;
  • from business contacts, external service providers and suppliers;
  • when we purchase mailing lists;
  • when you are on our website and you chat with us via LiveChat; or
  • by other means reasonably necessary.

Third party collection.

Where possible, we collect your personal information directly from you. If we collect any personal information about you from someone other than you, to the extent not already set out in this Privacy Policy, we will inform you of the fact that we will collect, or have collected, such information and the circumstances of that collection before, at or as soon as reasonably practicable after we collect such personal information.

 

Authority.
If you provide us with the personal information of another individual, without limiting any other provision of this Privacy Policy, you acknowledge and agree that the other individual:

has authorised you to provide their personal information to us (and you have provided them with a copy of this Privacy Policy; and

consents to us using their personal information in order for us to provide our Products and Services.

 

Unsolicited information.
If we receive unsolicited personal information about you that we could not have collected in accordance with this Privacy Policy and the Privacy Act, we will, within a reasonable period, destroy or de-identify such information received.

Anonymity. We may collect information while individuals remain anonymous using social media survey instruments for the purposes of gaining data about consumer behaviour without direct attribution to the individual. If you would like to access any of our Products and Services on an anonymous or pseudonymous basis we will take reasonable steps to comply with your request, however:

you may be precluded from taking advantage of some or all of our Products and Services; and

we will require you to identify yourself if:

  • we are required by law to deal with individuals who have identified themselves; or
  • it is impracticable for us to deal with you if you do not identify yourself.
  • Destruction. Subject to a legal requirement to the contrary, we will destroy or de-identify your personal information if:
  • the purpose for which we collected the personal information from you no longer exists or applies; or
  • you request us to destroy your personal information,
  • and we are not required by law to retain your personal information.

 

Website and Google Analytics.
Information we collect may include:

  • the Internet Protocol address and a component of the domain name used (e.g. .com or .net);
  • the type of browser and operating system you used;
  • the date and time you visited our Platform(s);
  • the web pages or services you accessed on our Platform(s);
  • the time spent on individual pages and our Platform(s) overall;
  • which files you downloaded; and
  • information about your computer and Internet connections using cookies (see clause 8 below).

We have integrated Google Analytics into the Platforms (see http://www.google.com/analytics/ for details). We use Google Analytics Demographics and Interest Reports to obtain a more detailed understanding of our Platforms users and their potential needs. Data collected from such reports may be used to more accurately target marketing and advertising campaigns based on demographic information and more generally for the Primary Purposes and Secondary Purposes detailed in this Privacy Policy. We do not collect personal information about individuals by such methods; only aggregate data is collected and used for planning purposes.

 

We may use ‘cookie’ technology to assist us to determine in the aggregate the total number of visitors to the Platforms on an ongoing basis and the types of internet browsers and operating systems used by users of the Platforms. This information is used to enhance the usability and functionality of our Platforms and for marketing, advertising and analytic purposes.

 

USE

Primary use.

We will only use and disclose your personal information:

for purposes which are related to the Primary and Secondary Purposes; or

if we otherwise get your consent to do so,

in accordance with this Privacy Policy and the Privacy Act.

 

Reasonable uses.
We will not use your personal information for any purpose for which you would not reasonably expect us to use your personal information.

 

Third parties.
You consent to us providing your personal information (other than sensitive information) to commercial and technology partners as well as affiliates of repute and our Related Bodies Corporate. We may do so for profit or economic benefit and this may include (without limitation) licence arrangements and rights of use in relation to or in connection with direct marketing, analysis, data aggregation and anything else reasonably required or permitted by law. Data collected by us and/or them on our behalf may be used by those third parties for commercial, analytic, service provision and/or communication purposes (or otherwise on a basis contemplated by this document). The provision of such personal information to Third Parties and Related Bodies Corporate may be subject to the relevant privacy policies of such persons.


Direct marketing.
We may deliver direct marketing communications to you about our Products and Services and any other products or services you might be interested in. If you notify us that you do not want to receive these communications, we will comply with your instruction and will not use your personal information for this purpose.

 

Right to use.
Subject to any other term of this Privacy Policy, we will only use or disclose your personal information for the purposes of direct marketing if:

we collected the information from you;

it is reasonable in the circumstances to expect that we would use or disclose the information for direct marketing purposes;

we provide you with a simple means to ‘opt-out’ of direct marketing communications from us; and

you have not elected to ‘opt-out’ from receiving such direct marketing communications from us.

 

Opt-out.
You may opt-out of receiving direct marketing communications by:

checking the relevant box on the form used to collect your personal information;

clicking a link on the email communication sent to you; or

contacting us using our contact details set out at clause 10.

 

Disclosure

How we disclose. We may disclose personal information and you consent to us disclosing such personal information (other than sensitive information) for purposes which are related to the Primary and Secondary Purposes, or as otherwise set out in this Privacy Policy, including but not limited to:

  • Third Parties engaged by us to perform functions or provide Products or Services on our behalf;
  • Third Parties that engage us to provide Products or Services to them;
  • Third Parties who assist us with a number of our functions and services including but not limited to service providers of technology, data processing, contact centre, archival, delivery, banking, payments, market research, content production, mail-outs, marketing and advertising, but only for the purpose of fulfilling those services;
  • Third Parties engaged to provide online credit card account processing and related services. When you pay your accounts online, a secure server is used, such as SecurePay or Ezidebit (Payment Gateway). The Payment Gateway encrypts the information you send through our Website. For further information about SecurePay or Ezidebit and how they collect, use and disclose personal information, please use the link provided below. For further information about the encryption process, please use the link provided. We make no warranty in respect of the strength or effectiveness of that encryption and we are not responsible or liable for events arising from unauthorised access of the information you provide;
  • your referees and former employers (in relation to employment applications only);
  • credit agencies;
  • relevant regulatory bodies in the industry in which we or you operate;
  • our professional advisors, including our accountants, auditors and lawyers;
  • our Related Bodies Corporate;
  • persons authorised by you to receive information held by us, which for the avoidance of doubt includes but is not limited to our business partners and sponsors that we may have commercial arrangements with from time to time including Third Parties who we contract with for our independent commercial purposes;
  • a government authority, law enforcement agency, pursuant to a court order or as otherwise required by law;
  • a party to a transaction involving the sale of our business or its assets; or
  • parties you have consented to us disclosing your personal information to, or would otherwise reasonably expect us to disclose your personal information


Non-identifiable information.
We may share non-personally identifiable information publicly and with our partners (e.g. relevant Third Party suppliers or service providers, publishers, advertisers, sponsors, or connected sites). For example, we may share information publicly to show trends about the general use of our Products and/or Services.

 

Overseas disclosure.
We may in some circumstances as necessary send your personal information to overseas recipients to enable us provide our Products and Services to you. The countries in which likely overseas recipients of personal information are located includes: the People’s Republic of China and the USA.

 

Overseas recipients.
Overseas recipients that may handle or process your data include (but are not limited to) the server hosts of our email services, cloud storage services and the Platforms. For the purpose of the services we offer via Export Growth China services, we may from time to time send exporter information overseas to or receive information from our contractors and partners for the purpose of placing exports overseas or finding channel or distribution partners.

 

Reasonable protections.
If we send your personal information to overseas recipients, we will take reasonable measures to protect your personal information from misuse, interference, loss, unauthorised access or modification. However, you acknowledge and agree that if we disclose your personal information to overseas recipients, we are not obliged to take reasonable steps to ensure overseas recipients of your personal information comply with the Privacy Act and the APPs.

If we become aware that you are a citizen of, or are located within, the European Union at the time when we collect personal information about you, or at the time when we propose to transfer personal information about you overseas, we will take steps to ensure (to the extent relevant) that we comply with Articles 45 to 49 of the GDPR in relation to the transfer of your personal information overseas. However, you acknowledge that as we conduct our business from and predominantly within Australia, you are required to provide us with written notice of our need to comply with the GDPR in relation to your personal information if you wish for us to take steps that are not already set out in this Privacy Policy.

 

 

Access + Correction

Access. If you require access to your personal information, please contact us using our contact details set out at clause 10. You may be required to put your request in writing and provide proof of identity.

 

We are not obliged to allow access to your personal information if:

  • it would pose a serious threat to the life, health or safety of any individual or to the public;
  • it would have an unreasonable impact on the privacy of other individuals;
  • the request for access is frivolous or vexatious;
  • it relates to existing or anticipated legal proceedings between you and us and would not ordinarily be accessible by the discovery process in such proceedings;
  • it would reveal our intentions in relation to negotiations with you in a way that would prejudice those negotiations;
  • it would be unlawful;
  • denying access is required or authorised by or under an Australian law or a court/tribunal order;
  • we have reason to suspect that unlawful activity, or misconduct of a serious nature relating to our functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
  • it would likely prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body;
  • it would reveal commercially sensitive information; or
  • a relevant law provides that we are not obliged to allow access to your personal information (e.g. the GDPR).

Response to access request.
If you make a request for access to personal information, we will:

  • respond to your request within a reasonable period after the request is made; and
  • if reasonable and practicable, give access to the personal information as requested.


Refusal of access.
If we refuse to give access to the personal information, we will give you a written notice that sets out at a minimum:

  • our reasons for the refusal (to the extent it is reasonable to do so); and
  • the mechanisms available to complain about the refusal.

Correction.
We request that you keep your personal information as current as possible. If you feel that information about you is not accurate or your details have or are about to change, you can contact us using our contact details set out at clause 10.

Response to correction request.
If you make a request for us to correct your personal information, we will:

  • respond to your request within a reasonable period after the request is made; and
  • if reasonable and practicable, correct the information as requested.


Refusal to correct.
If we refuse a request to correct personal information, we will:

  • give you a written notice setting out the reasons for the refusal and how you may make a complaint; and
  • take reasonable steps to include a note with your personal information of the fact that we refused to correct it.

EU Restriction.
If you are a citizen of, or are located within, the European Union at the time at which we collect personal data about you, or at the time at which you make a relevant request, we will take steps to ensure that we comply with a request by you to restrict our use of your personal data pursuant to Article 18 of the GDPR. You acknowledge that, depending on the nature of the restriction you request, we may be unable to provide you with some or all of our Products or Services (or any part of any Product or Service) if we comply with your request. In such circumstances, we will advise you of our inability to provide or continue to provide you with the relevant Products or Services, and if you confirm that you would like us to comply with your request, we may terminate a relevant agreement or other document with you in relation to our Products or Services.

 

security + Protection

Reasonable protections.
In relation to all personal information, we will take all reasonable steps to:

  • ensure that the personal information we collect is accurate, up to date and complete;
  • ensure that the personal information we hold, use or disclose is, with regard to the relevant purpose, accurate, up to date, complete and relevant; and
  • protect personal information from misuse, loss or unauthorised access and disclosure.

We require staff and service providers to respect the confidentiality of personal information. We store your personal information on a secure server behind a firewall and use security software accessible only by authorised personnel and service providers to protect your personal information from unauthorized access, destruction, use, modification or disclosure.

 

Obligation to notify.
You must contact us immediately if you become aware of or suspect any misuse or loss of your personal information.

 

Complaints

If you have a complaint about how we collect, use, disclose, manage or protect your personal information, or consider that we have breached the Privacy Act or APPs, please contact us using our contact details set out at clause 10. We will respond to your complaint within 14 days of receiving the complaint.

 

Response and resolution.
Once the complaint has been received, we may resolve the matter in a number of ways:

  • Request for further information: We may request further information from you. Please provide us with as much information as possible, including details of any relevant dates and documentation. This will enable us to investigate the complaint and determine an appropriate solution.
  • Discuss options: We will discuss options for resolution with you and if you have suggestions about how the matter might be resolved you should raise these with our Privacy Officer.
  • Investigation: Where necessary, the complaint will be investigated. We will try to do so within a reasonable time frame. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.
  • Conduct of our employees: If your complaint involves the conduct of our employees we will raise the matter with the employees concerned and seek their comment and input in the resolution of the complaint.
  • Notice of decision. After investigating the complaint, we will give you a written notice about our decision.
  • You are free to lodge a complaint directly with the OAIC online, by mail, fax or email. For more information please visit the OAIC website at oaic.gov.au.

Contact

Correspondence in general regarding this Privacy Policy. Please forward all correspondence in respect of this Privacy Policy to:


Privacy Manager

Suite 11.03

213 Miller Street

North Sydney, NSW, 2060
1300 768 728

support@itnc.com.au