Intersect Australia Limited Privacy & Security Policy – November 2015
Intersect Australia Limited (Intersect) is committed to complying with applicable privacy laws [including the Privacy Act 1998 (Cth) (“the Act”) and the Australian Privacy Principals (APPs)] which set clear standards in relation to our collection, storage, use and disclosure of any personal information we obtain as part of our business operations.
Intersect recognises the importance of privacy and our respect for our customers’ and other individuals’ right to privacy of their personal information is paramount. Any personal information that you provide to us will be held in the strictest confidence and in accordance with the APPs and the requirements of the Act. As a result, we have implemented practices, procedures and systems to comply with our legal obligations to maintain the confidentiality and security of personal information we collect and hold and to manage our systems, practices and procedures in an open and transparent way.
This Policy sets out our approach to gathering personal information, and our approach to the use and dissemination of such information. We undertake to treat all customer and other personal information in our possession in accordance with the requirements of the Act.
By “personal information”, we mean information or an opinion about an identified individual, or corporate client, or about an individual, or corporate client, who is reasonably identifiable from the information.
1. USE OF PERSONAL INFORMATION
We only collect information about you that we need to process in the provision to you of our services, for purposes necessary or incidental to providing you with services we have agreed to provide you, the identification of relevant services, Metadata and operating data, to offer new products and services, and to satisfy legal requirements.
Metadata means the data providing information about one or more aspects of the data collected, such as the:
- means of creation of the data;
- purpose of the data;
- time and date of creation of the data;
- creator or author of the data;
- location on a computer network where the data was created; and
- standard used.
We may also use this information for purposes such as direct marketing, correspondence, site registration, collection of customer operating and performance data, assessing productivity and or to participate in online surveys, benchmarks, competitive assessments, or similar purposes.
2. WHAT KIND OF INFORMATION DO WE COLLECT?
The type of information we collect generally includes your name, address, telephone numbers, other contact details and details concerning the provision of our services, agreements with Intersect members, products, service requirements and performance, metadata collected as part of the provision of services to you and related information.
When you use our services we automatically collect and store certain information in digital logs. This can include:
- details of how you used our service, such as your query search terms.
- telephony log information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.
- World wide web Universal Resource Locations and cookies that may uniquely identify your browser or your account with us.
- Internet Protocol addresses, ports and transaction IDs.
- device event information such as error messages, memory core dumps, system activity, hardware settings, browser type, browser language, the date and time of your request and referring URL.
A number of our services allow you to share information with other parties. You should be aware that if you share information with other parties it may be indexable by search engines.
3. HOW WE COLLECT INFORMATION
We collect personal information directly from you, such as when you enter an agreement with us, make an enquiry or otherwise use our web sites or other products as part of the provision of services. We prefer to obtain any personal information we collect directly from you. In some cases, however it may be unreasonable or impractical to obtain personal information directly, and we may obtain information from someone else. If you are concerned about what personal information we may hold about you, please see below for information on how you can access and (if necessary) correct that information.
4. ACCESS TO PERSONAL INFORMATION
Should you request it, we will provide you with access to any information we have collected from you. We will also update your information if you let us know that it is inaccurate or non-current. You can contact us to access or discuss this information by sending an email to: firstname.lastname@example.org
We aim to protect information from wilful or accidental corruption or destruction. Accordingly, even after you have deleted information from our servers, it may be that we do not immediately delete residual copies from our active servers and we may not remove information from our backup systems, for practical or lawful reasons or purposes.
Where surety of deletion is required, you may explicitly request we expunge your data by emailing email@example.com. Where possible, we will comply, except in the case where such a request would compromise our legal, logistical or operational obligations. Depending on the complexity and resourcing required to enact your request, we may charge you at standard rates for time and materials incurred if necessary.
Should you have any complaints about our treatment of your personal information, please email firstname.lastname@example.org. We treat every complaint about a breach of privacy legislation or any relevant registered code seriously, and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.
6. CAN I INTERACT ANONYMOUSLY OR UNDER A PSEUDONYM?
In many cases, you will need to provide your real name interacting with us. You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products or services, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with information, we may not be able to provide you with our products or services, or respond adequately to you. For clarification on when you must identify yourself, please email email@example.com. You may use a pseudonym email account when making such an enquiry.
7. OPTING OUT
On occasions, Intersect uses an individual’s personal information for our own direct marketing purposes. Should you receive such material and do not want to receive it in the future, we will provide you with a simple “Unsubscribe” (Opt out) method in the direct marketing material.
You may also contact Intersect by emailing firstname.lastname@example.org about this or other routine enquiries.
8. DISCLOSURE OF PERSONAL INFORMATION TO OTHER PARTIES
Generally, all agreements, orders etc will be placed between you and Intersect. Information that you provide to Intersect will be held according to this policy.
We will share personal information with companies, organisations or individuals outside of Intersect if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable Terms including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of Intersect, our users or the public as required or permitted by law.
9. TRANSBORDER DATA FLOWS
There may be occasions when personal information is transferred outside of Australia. Generally this will occur in the provision of services to you and the transfer of this information outside of Australia will have been disclosed to or authorised by you as part of the agreements entered by you with Intersect or related to the products or services provided. Where the international transfer of personal information outside is to countries whose privacy laws may be considered not to provide the same level of protection as Australia, our commitment to safeguard your privacy will not change and remains subject to existing obligations and this Policy.
11. CONTACTING US ABOUT PRIVACY ISSUES
Email: email@example.com for any privacy issues, including in relation to:
- How we are dealing with your personal information; or
- How it is being held.
You can also refer to our Attribution Policy here.