Effective Date: 25 May 2018
YOUR PRIVACY IS IMPORTANT TO US
PanLogica Pty Ltd (ACN 097 909 147) (‘PanLogica’, ‘we’, ‘us’ or ‘our’) respects your privacy and the trust you place in us by providing us with your personal information.
This document also describes how we may process (collect, use and disclose) the information that we obtain about you directly or indirectly, and how we protect that information in accordance with applicable data privacy laws. This document also outlines the choices you have about how your information is used.
Should you have any questions about this policy or our privacy practices, please email us at firstname.lastname@example.org or write to us at: PanLogica Pty Ltd, Po Box 778, Sandy Bay, TAS 7006.
WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT
- Information Provided by You
PanLogica will collect information that identifies you (Personal Information) when you voluntarily provide it to us through the use of any of our services. For example, when you subscribe to our newsletter and blog we may ask you to provide personal information, such as your name and email address.
We collect information that you provide to us, including when you communicate with us via email or other channels, when you sign up for or request that we send you newsletters, alerts, or other materials or when you respond to our communications or requests for information. We may collect Personal Information about your other dealings with us, including any contact we have with you in person, by telephone, email or online.
You may deal with us on an anonymous basis or using a pseudonym when making inquires to PanLogica. However, we may require certain contact details or other information from you to respond to these inquiries.
- Unsolicited Personal Information
We may also gather information about your general internet usage. This non-personal information is not connected to any Personal Information you provide us and it cannot be used to identify you. We use it for statistical reasons only. For example, we may use it to analyse broad audience profiles - like what region you are from. This statistical data is anonymous and aggregated. Through this process we do not gather or disclose any of your Personal Information.
The cookies we use remain on your device for differing times. Some expire at the end of each session and some remain for longer so that when you return to our use our services, you will have a better user experience.
Most browsers are initially set to accept cookies, however you can adjust the settings on your browser to block any or all cookies if you wish. This can easily be done by activating the browser settings on your computer or handheld device and selecting reject cookies. Please be aware though that if you disable cookies, you may not be able to access certain features on our website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which includes information on how to manage your settings for the major browser providers.
LEGAL BASIS FOR USAGE OF YOUR PERSONAL INFORMATION
Where we intend to use, or process, your Personal Information, we rely on the following legal grounds:
Performance of a Contract: We may need to collect and use your Personal Information to enter into a contract with you or to perform a contract that you have with us.
In Our or a Third Party’s Legitimate Interest: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your Personal Information, which may include:
- for our own direct marketing or continued communication;
- the prevention of fraud;
- our own internal administrative purposes;
- personalisation of the service(s) we provide to you;
- ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and
- reporting possible criminal acts or threats to public security to a competent authority.
Compliance with a Legal Obligation: We may be required to process your information due to legal requirements and other regulatory provisions.
WHAT WE DO WITH YOUR PERSONAL INFORMATION AND WHY WE COLLECT IT
- Internal Uses
We may use your Personal Information within the Company:
- to provide you with the services and products you request;
- to assist with your questions about our services, billing (where relevant), payment methods (where relevant) or use of our website;
- to carry out our obligations arising from any contracts entered into between us;
- to maintain and develop our relationship with you;
- to evaluate our services and products and to conduct customer surveys;
- to improve our services via internal research and development;
- to maintain and update our records including our database of contacts;
- for our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
- as we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or to protect your, our, or others’ rights; and
- for direct marketing purposes as set out in section B below.
- Direct Marketing
We may use your personal information to send you marketing material including our newsletter and notifications about updates to our blog if we have your permission or a legitimate interest as described above.
For our legitimate interests, in order to support the services, we provide to you, we may provide you with information and services on an ongoing basis, including an occasional newsletter and alerts about updates to the PanLogica blog, as well as other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us.
If you don’t want to receive emails from us, you can follow the ‘unsubscribe’ instructions that appear at the bottom of all emails we send. Otherwise, you can always contact us at email@example.com to update your contact preferences.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We will not give, sell, rent, loan or otherwise disclose any Personal Information to any third party, unless:
- you have authorised us to do so;
- it is for direct marketing purposes as set out above;
- such sharing is provided for under contract, including our terms and conditions for any particular product or service that we may provide to you;
- we are legally required to do so, for example, in response to a subpoena, court order or other legal process;
- we need to enforce or apply our terms and conditions to which you have agreed (or other terms that have been agreed to apply to our relationship with you);
- it is necessary to protect the rights and interests, property, or safety of PanLogica, our clients or others;
- our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions;
- all, or most, of the assets of PanLogica or any single business unit within the Company are merged with or acquired by a third party, or we expand or re-organise our business, in which case your Personal Information may form part of the transferred or merged assets.
DISCLOSURE OF PERSONAL INFORMATION OUTSIDE AUSTRALIA
Where you are submitting Personal Information from within Australia, such information may be transferred outside Australia. If we transfer your information to third parties outside Australia, we will take steps to ensure that your privacy rights continue to be protected and ensure that these third parties are either covered by data privacy laws substantially similar to those in Australia or the relevant third party adheres to data privacy standards substantially similar to the Australian Privacy Principles.
HOW WE PROTECT YOUR PERSONAL INFORMATION
All personal information is collected via HTTPS secure communication and is kept in a secure database that is not subject to any unauthorized usage. We employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure.
In addition, we have procedures that limit the Company's employees and contractors access to personal information. Only those employees and contractors with a business reason to know have access to such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and internal policies on data privacy and corporate integrity. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
YOUR OPTIONS IN RELATION TO YOUR PERSONAL INFORMATION
Where you have consented to our processing of certain Personal Information, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products and services (or part of them) either at the point such information is collected, or, where you do not wish us to continue to use your information in this way, by following the relevant instructions on any communications sent to you.
You may also request:
- access to the Personal Information we hold about you;
- corrections or updates to your details;
- the erasure/deletion of your Personal Information;
You may also object to, or request the restriction of, our use of your Personal Information.
If you would like to exercise any of the options set out in this section, please contact us at firstname.lastname@example.org. We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws.
RETENTION OF YOUR PERSONAL INFORMATION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
REQUESTING FURTHER INFORMATION AND MAKING A COMPLAINT
We can confirm what information we hold about you and how it is used at you request. If you have any questions please contact us by email at email@example.com or write to us at: : PanLogica Pty Ltd, Po Box 778, Sandy Bay TAS 7006.
If you think the Company has breached any of its privacy obligations, or you wish to make a complaint about the way your Personal Information has been handled, you can contact us by email at firstname.lastname@example.org. So that the Company can respond to you, please clearly describe your complaint and include your name, email address and/or telephone number for our reply. Your complaint will be considered by our management team, and an acknowledgement and response to your complaint will be provided to you within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, you may refer the matter to the Office of the Australian Information Commissioner:
Mail: GPO Box 5218, Sydney, NSW 2001
Phone: 1300 363 992