Privacy

This Privacy Policy describes the manner in which Premier Contact Point Pty Ltd and its related entities (referred to as PCP, we or our) collects, holds and uses Personal Information that is covered by the Privacy Act. It is not intended to cover categories of Personal Information that are not covered by the Privacy Act. If you wish to make any inquiries regarding this Privacy Policy, you should contact PCP in any of the ways specified in clause 13.

PCP may, from time to time, review and update this Privacy Policy including to take into account new laws, regulations and technology. All Personal Information held by PCP will be governed by our most recent Privacy Policy, posted on our website (premiercontactpoint.com) (Website). Our most recent Privacy Policy will apply to our collection, use and disclosure of Personal Information.

1. What is “Personal Information”?

“Personal Information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.

2. What Personal Information do we collect and hold?

PCP may collect and hold Personal Information such as your name, gender, date of birth, contact details (including your address, phone numbers and emails, whether personal or for work), financial information, payment details, bank account details, and/or  your preferences about our products and services.

3. Why do we collect Personal Information?
   • PCP collects Personal Information from customers, employees, contractors and other individuals that is reasonably necessary for one of more of our functions or activities, including: in order to allow us to conduct our business functions, to meet any regulatory requirements which apply to our business, to market and sell our products and services and to conduct employee related activities.
   • You have the option to deal with us anonymously or by using a pseudonym. However, you acknowledge that where this is impractical (for example when you contract with us) or where the law or a court order provides otherwise, we are not required to provide these options to you.
   • If you choose not to provide your Personal Information to PCP, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.

4. When and how do we collect Personal Information?
   • PCP collects Personal Information when you: become an employee of PCP, visit our Website, supply or buy products or services, request information about us or our products or services, provide feedback, respond to a survey, change your content or email preferences, contract with us, fill in a form on our Website, or contact us by telephone, facsimile, email, post or in person.
   • PCP may also collect Personal Information about you via third parties including from our suppliers and merchants.
   • In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.

5. Information collected via our Website
   • PCP will not collect any Personal Information about users of our Website except when it is obvious that Personal Information is being collected or as otherwise described below. For example, PCP may collect Personal Information from users of the Website when they:
     • complete an online form; and/or
     • otherwise correspond with PCP.

Click Stream Data

• When you visit and browse our Website, our Website host may collect Personal Information for statistical, reporting and maintenance purposes. Subject to clause 4, the Personal Information collected by our Website host will not be used to identify you. The information may include:
  • the number of users visiting our Website and the number of pages viewed;
  • the date, time and duration of a visit;
  • the IP address of your computer; or
  • the path taken through our Website.
• PCP’s Website host uses this information to administer and improve the performance of our Website.

Cookies

• Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns.
• If you access our Website, a cookie is downloaded onto your computer’s hard drive when you first log on to our Website. You can adjust your internet browser to disable cookies, however PCP may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.

Web Beacons

• Web beacons are images that originate from a third party site to track visitor activities. PCP may use web beacons to collect aggregate data and provides this information to our Website host to administer and improve the performance of our Website.

Advertising

• We may use Google and/or other third-party service providers to serve ads on our behalf across the Internet and sometimes on our Website. They may collect anonymous information about your visits to our Website (not including your name, address, email address or telephone number), and your interaction with our products and services. They may also use information about your visits to the Website and other websites to target advertisements for goods and services in order to provide more relevant advertisements about goods and services of interest to you.

6. How PCP uses the Personal Information it collects about you
   • PCP uses the Personal Information it collects about you for our business functions and activities, which may include the following:
     • to provide you with information, products or services you have requested;
     • to promote and market our products and services to you;
     • to personalise and customise your experiences on our Website;
     • to help PCP research the needs of its customers;
     • to conduct research for the purposes of improving existing products or services or creating new products or services;
     • to provide you with ongoing information about PCP and its activities;
     • to allow us to provide third party information and offers in which we believe you may be interested;
     • to comply with regulatory or other legal requirements;
     • for purposes related to the employment of our personnel and providing internal services to our staff; and
     • for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
   • PCP may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes in clause 1, if we have your consent, or if otherwise permitted under the Privacy Act.
   • PCP may use your Personal Information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about PCP or the products or services offered by PCP.
   • You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 13.

7. Who do we disclose your Personal Information to?
   • Depending on the nature of your relationship with PCP, we may disclose your Personal Information to shareholders, officers and employees of PCP, other businesses within our group of companies, service providers who assist us in our business operations, parties involved in the purchase or sale of any of our businesses, other third parties, or otherwise as required by law.
   • PCP may also disclose your Personal Information to our Website host or service providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner. To the extent that we do share your Personal Information with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this Privacy Policy.
   • We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.
   • Unless otherwise specified in this Privacy Policy, PCP or PCP’s Website host will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Privacy Act.

8. Employee Records

Employee records are not generally subject to the Privacy Act. As such, this Privacy Policy may not apply to the handling of employee related information. Please contact us directly for information about our employee record-handling practices.

9. Storage and security of Personal Information held by PCP

PCP will take reasonable steps to protect your Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include adherence to PCP’s Information Security policy and include restricting physical access to our offices, implementing firewalls and secure databases, implementing rights management processes and complying with relevant data security standards.

10. Updating and correcting your Personal Information

We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. If you want to correct any of the information that we hold about you, please contact us in any of the ways specified in clause 13. PCP welcomes any changes to your Personal Information so as to keep our records accurate, up-to-date, and complete.

11. How long will PCP keep your Personal Information?
    • We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law.
    • Where we no longer need to keep your Personal Information in accordance with clause 1, we will take reasonable steps to destroy or de-identify your Personal Information.
    • If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).

12. Finding out what Personal Information PCP holds about you
    • You are entitled to access most of the Personal Information that PCP holds about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others, or is otherwise not required by the Australian Privacy Principles or law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
    • A request for access can be made by contacting PCP in any of the ways specified in clause 13.

13. How to contact us and more information
    • If you want to complain about a breach of the Australian Privacy Principles by PCP, please contact us in any of the ways listed below. PCP’s Privacy Officer will investigate the complaint and communicate the result of that investigation to you as soon as reasonably possible.
    • You may contact PCP for any privacy-related matters in the following ways:
      • email: privacy@premiercontactpoint.com
      • write to: Att: Privacy Officer
        Level 11, 501 Swanston Street, Melbourne, Victoria 3000 Australia
    • You can find out more information about the Privacy Act and the Australian Privacy Principles from the Australian Information Commissioner. The Information Commissioner may be contacted at oaic.gov.au (email – enquiries@oaic.gov.au).

Last updated: September 2018