Echidna International Pty Ltd ACN 112 649 546 (we, us or our) is covered by the 13 Australian Privacy Principles (APPs). The APPs apply to the collection and use of Personal Information as set out in the Privacy Act 1988 (Act) (as amended from time to time). For the purpose of this Policy:
“Personal Information” means information, including financial information, or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is in a material form or not.
“Sensitive Information” means information or an opinion (that is also Personal Information) about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual practices, criminal record or health information.
We recognise the importance of protecting your Personal Information. We will take reasonable steps to ensure all Personal Information held by us is secure and all Personal Information collected, used or disclosed by us is accurate, complete and up to date.
This Policy is published on our website and may be updated from time to time at our discretion. By continuing to use our website, or otherwise continuing to deal with us, you accept this Policy as it applies from time to time.
Types of Personal Information
Depending on the particular circumstances, we may collect and hold a range of different Personal Information about you. This may include, but is not limited to, your name, date of birth, contact details (including address, email address and telephone number), driver’s licence number, credit history, internet protocol address, server address, domain name and payment, transaction and financial information (such as credit card or bank account numbers).
Sources of Personal Information
Where possible, we will collect Personal Information directly from you. In some instances, we may collect Personal Information from other sources such as third parties, publically available sources, press reports or other publications, in which case, we will endeavour to verify such details with the person concerned.
We acknowledge that there is no obligation for you to provide us with Personal Information except as required by law. However, if you choose not to provide us with certain necessary details, we may not be able to provide you with our full range of services or employment.
We collect Personal Information in a number of ways, including but not limited to, via video surveillance at our sites and directly from you when you order or purchase goods or services from us, set up an account with us, when you use one of our services to process a transaction, when you enter one of our trade promotions or competitions and when you browse our website.
Purpose for Use and Disclosure
The purpose for which we use and disclose Personal Information will depend on the circumstances in which it is collected. Generally, we may use or disclose Personal Information:
- for the purposes for which it was collected;
- for a related secondary purpose, if the use or disclosure could be reasonably expected;
- for other purposes to which you have consented; and
- as otherwise authorised or required by law (for example, to comply with occupational health and safety, industrial relations and taxation laws.
Specific purposes for which we may use or disclose Personal Information include the purposes of providing you with products and/or services, dealing with customer care related activities, marketing and developing our products and services, for our internal management purposes including (without limitation) to assist us in assessing and improving our capabilities, operating procedures and efficiencies and to assess and display our capabilities (although all details will be used anonymously where they will form part of capability or similar statements or advertisements), the operation and administration of accounts, carrying out certain checks (for example, in relation to credit), administering trade promotions or competitions, interacting with companies or organisations with whom we have a business relationship, complying with our obligations under agreements with third parties and carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution. We may also use such Personal Information to apply customer satisfaction surveys and events such as “loyalty” programs.
In the event we collect Sensitive Information about you, you consent to us collecting, using and disclosing the Sensitive Information for the purpose for which it was disclosed and as permitted by the Act and other relevant laws.
It is not likely that we will disclose Personal Information that we collect and hold about you to any overseas recipients (as defined in the Act).
Anonymity and Pseudonymity
You can deal with us anonymously (without identifying yourself) or under a pseudonym (fictitious name) unless you are applying for credit from us, dealing with us in relation to the provision of goods or services or in any other situation where it is impractical or unlawful to deal with you anonymously or under a pseudonym.
Storage of Personal Information
All Personal Information collected by us will be retained as part of our business records, which will be securely monitored and maintained. We hold Personal Information in a number of ways, including:
- as part of customer records and other electronic documents on which Personal Information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business; and
- by securely storing hard copy documents on which Personal Information is contained, at our various premises and using third party document management and archiving services.
Retention of Personal Information
If we receive Personal Information where we have not taken any steps to collect such information, then within a reasonable time we will decide whether we could, under the APPs, have solicited that Personal Information ourselves. If we determine that we would not, under the APPs, have been permitted to solicit the Personal Information, we will as soon as practical (where lawful and reasonable to do so) destroy or de-identify that unsolicited Personal Information. If we could, under the APPs, have solicited the Personal Information then we may use and disclose the Personal Information for the purpose for which it was disclosed and as permitted by the Act and other relevant laws.
Where Personal Information held by us is no longer required to be held, and its retention is not required by law, then we will destroy such Personal Information by a secure means.
Access to Personal Information
You can gain access to your Personal Information, subject to certain exceptions contained in the Act. To request access to your Personal Information, or to update or correct that Personal Information, please send a written request to either 66 Greenhill Road, Wayville SA 5034 or firstname.lastname@example.org. We will check the identity of individuals making requests to determine within 14 days whether the request will be met.
We may send you marketing communications in line with your previously expressed marketing preferences or as otherwise permitted under the Act and other relevant laws. If you do not wish to receive such communications, please contact us via the Contact Address or follow the opt-out instructions contained in each marketing communication.
If you are concerned that the way in which we collect, hold, use or disclose your Personal Information may be in breach of the APPs, please send written details of your complaint to the Contact Address.
After receiving a complaint, we will conduct internal discussions and evaluate whether we believe that such collection, holding, use or disclosure of your Personal Information was in breach of the APPs. We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex issues or requires extensive investigation, it may not be possible to respond within this timeframe. If the conclusion of our investigation is that our collection, holding, use or disclosure of your Personal Information was in breach of the APPs, we will take steps to remedy the breach as soon as reasonably practicable. If after dealing with us you are still not satisfied, you are entitled to make a complaint to the Office of the Australian Information Commissioner.