Privacy Policy
ABOUT OUR PRIVACY POLICY
Circle Solutions Group Pty Ltd (ACN 650 687 531) (“we”, “us” or “our”) recognises the importance of privacy and is committed to protecting the privacy of individuals when handling their personal information. We handle personal information about individuals for purposes relating to our [business] functions and activities including software development.
Our Privacy Policy outlines how we handle personal information about individuals in an open and transparent manner in accordance with the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988 (“Privacy Act”). Personal information includes any information about an identified individual or an individual who is reasonably identifiable.
By providing us with your personal information you consent to us handling it in accordance with our Privacy Policy. If you provide us with any personal information about another individual then we rely upon you to inform that individual of the details contained in our Privacy Policy.
WHY WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
We collect, hold, use and disclose personal information for purposes relating to our business functions and activities. By using our website, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from use. We do not use sensitive personal information in any direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature. For example, we may collect, hold, use or disclose your personal information for one or more of the following purposes:
- providing you with our products or services
- your attendance at or participation in our functions, activities or events
- managing our client relationship with you
- providing you with information about our products, services, functions, activities or events
- evaluating or improving our products, services, functions, activities or events
- marketing or promoting our products, services, functions, activities or events
- carrying out our business functions and activities
- complying with our legal or regulatory obligations
WHAT KINDS OF PERSONAL INFORMATION WE COLLECT
The kinds of personal information about you that we may collect and hold include your:
- personal details including name and contact details;
- payment information including bank account details and credit card details;
- product and service information including purchase history.
We will not collect any sensitive information about you without your consent unless we are required or authorised by law to collect the information.
If we are not provided with the personal information about you which we request then we may not be able to provide you with our products or services and you may not be able to attend or participate in our functions, activities or events.
WHAT KINDS OF WEBSITE VISITOR INFORMATION WE COLLECT
We use cookies and similar technologies to collect information about visitors to our website www.circlesolutions.com.au (“Website”). When you visit our Website the kinds of information that we collect and hold about your visit include your server address, domain name, operating system, browser type, pages accessed, documents downloaded, previous visits, referring website and visit date and time. We use this information for the purpose of maintaining and improving our Website and enhancing your experience browsing our Website. A cookie is a small text file which is stored on your computer or device by your web browser when you first visit our Website to enable your visits to be recognised. You may set your web browser to disable cookies if you do not wish us to collect information about your visits to our Website but some parts of our Website may not function properly if cookies are disabled. Our Website does not set tracking cookies if a Do Not Track request is received from your browser.
HOW WE COLLECT PERSONAL INFORMATION
We usually collect personal information directly from you in person or when you communicate with us by form, letter, telephone, facsimile, email or other means. For example, we may collect your personal information directly from you when:
- you request us to provide you with our products or services
- you request us to provide you with assistance or support for our products or services
- you attend or participate in our functions, activities or events
- you request us to provide you with information about our products, services, functions, activities or events
- you complete a survey or provide feedback in respect of our products, services, functions, activities or events
- you subscribe to receive news or other information about our products, services, functions, activities or events
- you enter our competitions or promotions
- we remote into your CircleScan system for support purposes (all information gathered during a support session is not retained and is discarded as soon as the support session is closed)
We may also collect your personal information from a third party for the purpose of carrying out our business functions and activities. For example, we may collect your personal information from:
- your authorised representatives in connection with providing you with our products or services or your attendance at or participation in our functions, activities or events
- our service providers that assist us to carry out our business functions and activities including our information technology providers and credit report providers
- government departments and agencies in connection with carrying out our business functions and activities
WHEN YOU WILL HAVE THE OPTION OF NOT IDENTIFYING YOURSELF
We will give you the option of not identifying yourself or using a pseudonym when dealing with us in relation to a particular matter except where it is impracticable or unlawful for us to do so. For example, you may not need to identify yourself when you request that we provide you with general information about our products, services, functions, activities or events.
HOW WE HANDLE UNSOLICITED PERSONAL INFORMATION
If we receive any of your personal information that we have not requested then we will determine within a reasonable time whether or not we could have collected the information. If we determine that we could not have collected the information then we will destroy or de-identify the information as soon as reasonably practicable but only if it is lawful and reasonable to do so.
HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information to third parties for the purpose of carrying out our business functions and activities. For example, we may disclose your personal information to:
- your authorised representatives in connection with providing you with our products or services or your attendance at or participation in our functions, activities or events
- our service providers that assist us to carry out our business functions and activities including our customer support providers, information technology providers, printing and mailing providers, sales and marketing providers, credit report providers, billing and debt recovery providers and professional advisers
- our related companies, agents, partners, affiliates and other trusted entities that assist us to carry out our business functions and activities
- government departments and agencies in connection with carrying out our business functions and activities
The third parties will only be located in Australia. We will not disclose your personal information to any other third parties without your consent except where required or authorised by law. For example, we will not sell, trade or rent your personal information to any third party for marketing purposes without your consent.
HOW WE USE PERSONAL INFORMATION FOR DIRECT MARKETING
We may use your personal information to provide you with news or other information about our products, services, functions, activities or events that may be of interest to you. In each such communication we will describe how you may at any time request not to receive any further such communications from us. We will give effect to your request not to receive any further such communications from us as soon as practicable.
HOW WE HOLD AND PROTECT PERSONAL INFORMATION
We hold personal information that we collect in both physical and electronic storage facilities including paper-based files, computer servers, desktop and laptop computers, tablets, mobile phones, cameras and other portable data storage devices.
We protect personal information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure using both physical and electronic security measures which include secure premises, physical access restrictions, locked cabinets, video surveillance, secure databases, password access, anti-virus software, data encryption and firewalls.
If we hold any personal information that we no longer need for any of our purposes then we will take reasonable steps to destroy or de-identify the information unless we are required by law to retain the information.
HOW TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION
You may request access to, and correction of, any of your personal information that we hold. You should promptly notify us if you become aware that any of your personal information that we hold is inaccurate or out-of-date.
We will respond within a reasonable time to a request by you for access to your personal information. We will give you access to your personal information in the manner that you request if it is reasonable and practicable to do so. If we decide not to give you access to your personal information then we will give you written reasons for our decision.
We will respond within a reasonable time to a request by you for the correction of your personal information. If we correct any of your personal information that we have previously disclosed to another organisation which is subject to the Australian Privacy Principles then you may request us to notify that other organisation of the correction. If we decide not to correct any of your personal information then we will give you written reasons for our decision and you may request us to associate with the information a statement apparent to users of the information that it is incorrect.
If you wish to access, correct or update any of your personal information that we hold, please contact our Privacy Officer using the contact details below. You will be required to verify your identity before you will be permitted to access, correct or update any of your personal information that we hold. We may charge a fee for giving you access to your personal information.
HOW TO MAKE AN ENQUIRY OR COMPLAINT
If you have an enquiry or complaint about our handling of your personal information, please contact our Privacy Officer using the contact details below. A complaint about our handling of your personal information should first be made in writing to our Privacy Officer setting out details of your complaint. Our Privacy Officer is responsible for dealing with all enquiries and complaints about our handling of personal information and will respond on our behalf within a reasonable time after receiving an enquiry or complaint.
If you are not satisfied with our response to your complaint then you may take your complaint to the Office of the Australian Information Commissioner which may be contacted using the following contact details:
Office of the Australian Information Commissioner
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Address: GPO Box 5218, Sydney, NSW 2001
HOW WE UPDATE OUR PRIVACY POLICY
We may update our Privacy Policy from time to time to take into account changes in our information handling practices by publishing an updated version of our Privacy Policy on our Website. You should regularly review the most recent version of our Privacy Policy available on our Website.
HOW TO CONTACT US
You may contact our Privacy Officer using the contact details below:
Circle Solutions Group Pty Ltd
Email: adrienne@circlesolutions.com.au
Telephone: 02 4342 9717