2 What is personal information?
Personal information is information or an opinion about you from which you can be reasonably identified.
3 Why does the Company collect personal information?
The Company collects personal information in connection with providing, administering, improving and personalising its products and services, for marketing and to support its business functions. If the Company does not collect your personal information, it may not
be able to provide you with these products and/or services.
4 What personal information does the Company collect?
The types of personal information collected by the Company include:
(b) Contact details
(including address, email address, telephone number(s) and other contact details);
(d) Passwords; and
(e) other information you provide to us.
5 How does the Company collect your personal information?
5.1 Collecting information from you
If it is reasonable and practical to do so, the Company will collect personal information directly from you. Depending on how you choose to interact with the Company, the Company may collect your personal information when you contact, or are contacted by, the Company or its service providers by telephone, by email, through the Company’s website, apps, social media and other digital services or when you complete a form or document and provide it to the Company.
5.2 Collecting information from third parties
5.3 Collecting information from visits to the Company’s website or using its apps
The Company may also collect information based on how you use its website or its apps, including through ‘cookies’, web beacons and other similar technologies. Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable the Company’s systems to recognise your browser and record nonpersonal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie
Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of the Company’s website may not function properly for users that disable cookies.
5.4 Unsolicited information
If the Company receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, the Company will take all lawful and reasonable steps (if any) to de-identify or destroy that
6 How does the Company hold your personal information?
The security of your personal information is of paramount importance to the Company. Accordingly, the Company takes all reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. These steps
include the implementation of the following safeguards:
(a) password protected databases;
(b) SSL secured websites & applications;
(c) Encrypted passwords;
The Company will take all reasonable steps to permanently de-identify or responsibly to destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.
6.1 Security breach procedures
The Company’s data security practices have been adopted with a view to protecting the data held by the Company. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other
mediums. Accordingly, the Company cannot guarantee any transmission will be completely secure.
7 How does the Company use your personal information?
The Company may hold, use or disclose your personal information so that it can [improve and tailor its products and services] and provide any products and/or services that you request.
The Company may also hold, use or disclose your personal information to:
(a) consider any concern or complaint that you raise against the Company or to manage any legal action between you and the Company;
(b) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or
(c) comply with any relevant laws, regulations, codes of practice and court orders.
7.2 Direct Marketing
The Company may also use your personal information to identify and promote products or services that may be of interest to you.
At any time, you may opt out of receiving direct marketing communications from the Company. To do so, select an opt out link within an email, or by contacting the person specified in clause 12. Unless and until you opt out, you consent to receive direct marketing
communications from the Company and to the handling of your personal information for this purpose.
8 How is personal information disclosed to others?
The Company does not sell, rent or trade personal information to, or with, third parties. The Company may disclose your personal information to third parties in limited circumstances, including without limitation to external providers that perform services on
behalf of the Company.
The Company’s website and apps may contain certain links to other websites. The Company does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.
8.2 Cross-border disclosure
If information is shared with overseas entities, The Company will take reasonable steps to ensure that any such overseas entity complies with the requirements under the Australian Privacy Principles (which are covered in this policy) and under the Privacy Act.
The Company may transfer your personal information to an entity which is in a foreign country to assist the Company in providing its product and services. Such foreign countries may include India, the USA, the United Kingdom, South Africa and New Zealand.
9 Change of control
If the Company sells, assigns or otherwise transfers part or the whole of its business, your personal information, which was collected by the Company through your use of the service and/or products, may be among the items transferred or sold to the extent that it is relevant to the Company’s business.
10 How you may access or correct your personal information
You may contact the Company to request access to the personal information it holds about you at any time. You may also ask the Company to correct information about you that you may believe is inaccurate, incomplete or out of date.
Please contact the Company using the contact details set out in clause 12. The Company will need to verify your identity before giving you access to, or correcting, your personal information. The Company will respond to the request within a reasonable period after the
request is made. There is no charge to make a request, however, the Company may charge a reasonable fee to cover the administrative costs of retrieving your personal information.
In certain circumstances, the Company may refuse or be unable to correct or provide you with access to your personal information. In these circumstances, the Company will write to you to explain the reasons why this is the case.
11 How you may complain if you have concerns about how the Company has managed your personal information
If you have a complaint related to how the Company has managed your personal information, please contact the Company using the contact details set out in clause 12. The Company may ask you to put your concerns in writing so that its [compliance] staff can fully
understand and investigate your complaint.
The Company will provide you with an estimated response timeframe in relation to your complaint. In any event, the Company will endeavour to respond to your complaint with  days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at to have the complaint heard and determined.
12 How to contact us
Attention: Nichalas Carayanis
Tel: +61 3 9462 1774
Mail: 26-28 Scammel Street, Cambellfield Vic. 3073