Taggle Systems Pty Ltd and its related bodies corporate (Taggle, we, our) recognize the importance of protecting and respecting the privacy and rights of individuals in relation to their personal information.
In preparing this policy we have had regard to our obligations under the Privacy Act (Cth) (Privacy Act), the 13 Australia Privacy Principles, (which deal with the collection, management and disclosure of your personal information), the Privacy Act’s notifiable data breach scheme and, indeed, the various requirements of state privacy legislation.
- What is file personal information?
Personal information has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
- What personal information do we collect and hold?
We may collect the following types of personal information:
- Mail, email and street addresses;
- Telephone and facsimile numbers;
- Profession, occupation and job title;
- Organisation’s bank details;
- Photos and videos;
- Details of the products and services you have purchased from us, or which you have enquired about, together with any additional information necessary to deliver those products and services, respond to your enquiries and generally to complete any commercial transaction between us;
- Details of the products and services that we may purchase, have purchased or enquired about from you, together with any additional information necessary for us to respond to your enquiries and generally to complete any commercial transaction between us;
- Any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise;
- Information you provide to us through our customer surveys and/or visits by, or telephone calls or emails from, our representatives from time to time; and
- Data and information that we collect in the process, and as a result, of us licensing to you our software applications and providing you and your customers with access to the software applications. (Customer Data).
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
- For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and provide the best possible quality of customer service.
We collect, hold, use and disclose your personal information for purposes including:
- To provide products and services to you and to send communications requested by you;
- To license software applications to you and to provide you and your customers with access to our software applications;
- To answer your enquiries and provide information or advice about existing and new products or services;
- To provide you with access to protected areas of our website;
- For our administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes (and those of our suppliers and contractors);
- To update our records and keep your contact details up to date;
- To process and respond to any complaint made by you;
- To contact and/or pay you for or in connection with products or services you provide us; or
- To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any government authority of any country.
- What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
- We may not be able to provide the requested products or services to you, either to the same standard or at all;
- We may not be able to license software applications to you and to provide you and your customers with access to our software applications;
- We may not be able to provide you with information about products and services that you want;
- We may be unable to tailor the content of our website to your preferences and your experience of our websites may not be as useful;
- We may be unable to contact and/or pay you in respect of products or services you provide to us; or
- We may not be able to purchase goods and/or services from you.
- How do we collect your personal information?
We collect your personal information directly from you where it is reasonable or practicable to do so, such as, for example, in ways including:
- Through your access to and use of our website;
- During conversations between you and our representatives;
- When you complete an application, purchase order, agreement or related paperwork;
- Through your participation in our procurement processes;
- From our software applications’ analysis of the data it receives and processes.
We may also collect your personal information from third parties including, for example, from credit reporting agencies, business data providers, professional and/or industry associations, law enforcement agencies and other government entities.
When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to:
- recognize your computer and greet you each time you visit our website without bothering you with a request to register;
- keep track of products or services you view so that, if you consent, we can send you information about those products and services;
- measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate;
- research our users’ habits so that we can improve our online products and services; and
- when you are logged into our data portals, recognize your computer without bothering you to login when you move from screen to screen.
If you do not wish to receive cookies, you can set the browser so that your computer does not accept them.
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users’ movements and gather broad demographic information.
We also keep audit logs on our servers to record your activity on our portals.
- To whom may we disclose your information?
We may disclose your personal information (other than Customer Data) to:
- Our employees, related bodies corporate, contractors or suppliers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry suppliers, electronic network administrators, regulators and other government authorities (eg the various state environment protection and work health and safety agencies) and professional advisors such as accountants, solicitors, business advisers and consultants;
- Our clients, in response to their requests for details about the products and/or services we have purchased from you.
- Suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
- Any organization for any authorized purpose with your express consent.
We disclose to you and your customers, and we manage and protect, Customer Data strictly in accordance with our ‘software as a service’ contractual obligations to you and we require you similarly to comply with your privacy law related contractual obligations.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.
- Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers located overseas for some of the purposes listed above.
We do not disclose Customer Data to anyone outside Australia.
- Direct marketing materials
We may send you direct marketing communications and information about our products and services that we consider may be of use to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavor to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
We don’t send direct marketing material to our customers’ customers.
We take reasonable steps to ensure that your personal information is protected from misuse and loss and from unauthorized access, modification or disclosure. We may hold your information in either electronic or hard copy form.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee the information you supply will not be intercepted while being transmitted over the internet. Therefore, any personal information or other information which you transmit to us online is transmitted at your own risk.
Notwithstanding this, in respect of Customer Data and the software applications that we license to you and provide you and your customers with access to via the internet, we provide the highest levels of privacy protection practicable, including, amongst things, protected servers, authentication using string passwords and encrypted data transfer channels.
Our website may contain links to websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy principles.
- Related policies
- (b) credit information held by us. For information about our practices relating to credit information, please view our separate credit policy, a copy of which is available at taggle.com.au.
- How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see contact details below).
When we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing it to you). Generally, we will not charge you a fee to cover our administrative and other reasonable costs in providing the information to you, however, where we anticipate that such costs may be considerable, and where we have your prior consent to charge a pre-agreed fee, we may do so. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information about you we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If this happens we will give you written reasons for any refusal. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we doe not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
- What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate.
- Contacting us
Privacy Officer, Taggle Systems Pty Ltd
Post: Level 1, 101 Sussex Street, Sydney NSW 2000
Tel: +61 2 8999 1919
In most cases we will ask that you put your request in writing to us. We will investigate your complaint and use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint within 30 days of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you have the right, depending on the jurisdiction, to make a complaint to the applicable regulator.
- What happens if, contrary to the above policy statements personal information is released?
If our investigations show a data breach, then we will:
- take steps to contain the breach and minimize resulting damage (eg. recover the personal information or change access codes or passwords);
- evaluate the type of data involved in the breach and the associated risks of the breach and determine the next steps, such as, for example:
- who is affected by the breach;
- what was the cause of the breach; and
- what is the foreseeable harm to the affected individual/organization;
- determine whether it is appropriate to notify and/or to apologies to the individual/organization affected to mitigate possible harm. Where the breach is serious seek legal advice as to the appropriate course of action and/or notification to, for example, the Australian Information Commissioner; and
- put into action preventative measures, based on the type and seriousness of the breach.
We operate in a dynamic business environment and, overtime, aspects of our business may change as we respond to changing market conditions. This may require our policies to be reviewed and revised. We reserve the right to change this policy at any time. This policy is made on 16 December 2019.