1.1 Protecting the security and privacy of your personal information is important to FLENDER Pty Ltd [Australia] (FLENDER). This policy sets out how FLENDER manages personal information in compliance with applicable laws on privacy, data protection and data security.
1.3 In general, our policy is that we only collect and hold personal information for the purpose that was specifically or reasonably apparent at the time of collection.
2.1 All relevant Personal data. “Personal data" means any personally identifiable information or data. The personal data we collect includes but is not limited to, name, identity card number, passport number, telephone number, physical or email address, any other contact details and copy of any document which may contain the personal data of the customers, such as utilities bills etc.
3.1 Australian Privacy Principles (APPs)
4. HOW WE COLLECT AND HOLD PERSONAL INFORMATION
4.1 When visiting FLENDER’ websites, applications or online tools (each a “FLENDER Online Offering”), FLENDER may collect and process the following personal information about you:
- Personal information that you actively and voluntarily provide via the FLENDER Online Offering (e.g., when registering, contacting us with your inquiries or participating in surveys, applying for a job, etc.), including name, e-mail address, telephone number, information submitted as part of a support request, comments or forum posts, etc.; and
- Information that is automatically sent to us by your web browser or device, such as your IP-address, device type, browser type, referring site, sites accessed during your visit, the date and time of each visitor request.
4.2 To protect your personal information against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access, FLENDER uses technical and organizational security measures.
4.3 FLENDER may store your personal information in hardcopy documents or electronically. In most cases, we use password protected electronic databases maintained at our own sites, or that of a service provider, possibly involving a cloud hosting service. Backups of electronic information may be stored offsite. Hard copy information is generally stored in our offices, which are secured to prevent entry by unauthorized people. Your personal information may be stored indefinitely until you advise you would like it removed or destroyed, however we may de-identify or destroy it earlier as required by law.
4.4 Over time, data is archived and may be stored by a third party secure storage provider. Where personal information is stored with a third party, we have arrangements in place requiring those third parties to comply with privacy laws. We take reasonable steps to protect the privacy and security of that information, but we are not liable for any unauthorized access, disclosure or use.
4.5 We collect, hold, use and disclose your personal information for the following purposes:
- To provide the FLENDER Online Offering’s services and functions and to administer your use of the FLENDER Online Offering;
- To verify your identity (if you registered for a FLENDER Online Offering);
- To answer and fulfill your specific requests;
- To send you marketing information or to contact you in the context of customer satisfaction surveys as further explained in Section 3; and
4.6 Generally, the legitimate interest pursued by FLENDER in relation to our use of your personal information is the efficient performance or management of your use of the FLENDER Online Offerings.
4.8 In order to offer you certain location-based functions, some FLENDER Online Offerings may use “Google Maps” (e.g. to let you obtain directions to your local FLENDER point of contact). When you use Google Maps, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“) will process personal data which may include, inter alia, your device’s IP address and your location. Location data can only be processed if you granted permission to access, or actively provided your location data within the relevant FLENDER Online Offering. The data controller responsible for the processing of your personal data in connection with Google Maps is Google; Google’s privacy notice can be found at https://www.google.com/policies/privacy.
4.9 This Privacy Notice applies only to FLENDER Online Offerings and not to other websites or applications operated by third parties. We may provide links to other websites and applications which we believe may be of interest to you. FLENDER is not responsible for the privacy practices of such other websites or applications.
4.10 Some applications of FLENDER that you can download to your mobile device (“Mobile Apps”) have their own Privacy Notices. These Privacy Notices are made available to you in the respective App Store before you download the Mobile App and within the respective Mobile Application itself. The Privacy Notices for FLENDER’s Mobile Apps are also published here.
4.11 In some cases, you might provide personal information to us by entering it into our cloud based solutions because you want us to host that information for you or your information may be disclosed to us by an organisation with whom you interact and to which we provide a cloud based service.
5. INTEGRITY AND SECURITY OF YOUR INFORMATION
5.1 Our obligation is to ensure that information about you that we collect, use and disclose is secure, accurate, up-to-date and complete. We employ a number of different strategies to protect personal information. These include, depending on the service and the nature of the personal information held in the relevant system:
- Firewalls and Intrusion Detection Systems
- Virus protection systems
- Encryption technologies
- Restricted access
- Security Policies and Staff Training
5.2 We will do our best to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure, however data transmission over the Internet cannot be guaranteed to be 100% secure because risks do change over time.
5.3 Where you are required to log in to access one of our products or services, we recommend that you always log out after each session and close the browser when finished; particularly when accessing the product or service from a public terminal. For obvious reasons, please do not send credit card information through unsecured electronic mail or share your passwords with anyone else.
5.4 If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it; we will take reasonable steps to destroy, de-identify or securely delete your personal information.
6. DISCLOSURE TO THIRD PARTIES AND OVERSEAS
6.1 In some cases we engage other companies within the FLENDER or FLENDER Group or we contract with a third party to perform services on our behalf. Further information about these types of services is detailed below. When we do this, we will only provide them with such information about you as they need to perform those services and we will make it clear how they should handle your personal information. They will not be permitted to use information about you for any purpose except to perform the services we have specifically asked them to provide.
6.2 Examples of Services provided by Third Parties on our behalf:
- technical support and development
- website monitoring and operations
- security audits and penetration testing
- data hosting
- financial services
- editorial and production services
- sending mail, faxes and emails
- processing orders
- providing marketing support and research
6.3 When we disclose personal information outside of Australia we will take reasonable steps to require the overseas recipient to comply with Australian Privacy Principles unless the recipient is subject to laws that would protect your information in a substantially similar way to the Australian Privacy Principles. For example, if that country has laws that enable you to take action to enforce your rights in a similar way.
6.4 By providing your personal information to us, or to the third party with whom we contract, you consent to the transfer of that information to our third party service providers who are located outside of Australia for that purpose.
6.5 Such third party service providers may store and process information provided by you on servers located outside of Australia.
7.1 We may share information about you with other business units across the FLENDER Group so that they can tell you about other products and services offered. This may involve providing your personal information to FLENDER companies and Partners within and outside of Australia. We will require these companies to agree to strict conditions governing how this information will be used. By providing your personal information you consent to the transfer of that information to entities in the FLENDER Group of companies and Partners located outside of Australia. We do not share your personal information with third party organisations to market products and services to you unless you have provided your express consent.
7.2 You will always be able to opt-out our Direct Marketing Communication
8. LINKS TO THIRD PARTIES
9. CONSENT AND WITHDRAWAL OF CONSENT
9.1 By using FLENDER Online Offerings, you consent to the collection, processing and use of personal information by FLENDER. You have the right to withdraw the consent at any time with future effect – i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If the consent is withdrawn, FLENDER may only further process the personal data where there is another legal ground for the processing.
10. ACCESS TO INFORMATION WE HOLD ABOUT YOU
10.1 By using FLENDER Online Offerings, you consent to the collection, processing and use of personal information by FLENDER. You have the right to withdraw the consent at any time with future effect – i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If the consent is withdrawn, FLENDER may only further process the personal data where there is another legal ground for the processing.
10.2 You are entitled to request access to your personal information we have on record at any time. If you believe that the information we have is inaccurate, incomplete or out of date, please contact us to correction of your records.
10.3 You can send requests for information to email@example.com
10.4 Sometimes we cannot provide access, for example if:
- It would pose a serious threat to life, health or safety or unreasonably impact the privacy of another individual;
- your request is not serious or in good faith;
- information relates to existing or anticipated legal proceedings between us;
- giving access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
- denying access is required or authorised under Australian law or a court or tribunal order;
- giving access would reveal information generated by us in connection with a commercially sensitive decision making process; or
- providing access would be unlawful or would be likely to prejudice an enforcement related activity conducted by, or on behalf of, an enforcement body.
10.5 If we refuse to provide access because of an exception listed above, or to give you information in the manner you requested, we will take reasonable steps to give access in a way that meets our needs and your needs and we will give you written notice setting out the reasons for refusal (unless it is unreasonable to do so) and the mechanisms available to you to complain about the refusal.
10.6 If we correct personal information that we previously disclosed to other entities, and you request that we notify those entities of the correction, we will take reasonable steps to notify those entities unless it is impracticable or unlawful to do so.
10.7 If we refuse to comply with your request for amendment of your details, we will give you written notice setting out the reasons for refusal (unless it is unreasonable to do so) and the mechanisms available to you to complain about the refusal.
11. DATA PRIVACY CONTACT
11.1 FLENDER will always use best efforts to address and settle any requests or complaints about your Data Privacy you bring to its attention. FLENDER Australia may be contacted at: firstname.lastname@example.org
11.2 Besides contacting FLENDER, you always have the right to approach the local privacy authority with your request or complaint: the Office of the Australian Information Commissioner (OAIC) https://www.oaic.gov.au