| Data ownership policy | 1.0 What personal information do we collect?
1.1 The types of personal information we collect will depend on the circumstances in which the information is collected. However, the types of personal information we collect and hold about you may include:
- contact information, such as your address, email address and telephone/mobile number;
- financial information, such as bank account or other payment details;
- for our employees, employee records that may contain personal information including safety
information (e.g. location information, emergency contacts) and travel and right to work
information (e.g. copies of passports, visas and drivers licences);
- for employees, personal information captured in our records when using Trust Codes systems
and devices for personal use (e.g. transaction history);
- usernames and passwords that you create when registering for an account with us;
- your organisation and position, where your organisation has business dealing with us;
- information about your occupation and employer organisation;
- details of any products or services we provide to your organisation;
- information about how you use the products or services we provide to you;
- data from cookies
- personally identifiable data
- records of our communications with you, such as telephone, email, SMS, online and in- person
communications;
- images of you which may be captured on CCTV in Trust Codes offices, including in Australia,
the United States, United Kingdom and New Zealand;
- other information that you provide us during the course of business; and
- other information that is capable of identifying you.
Trust Codes Limited Privacy Policy August 2019
For Internal and External Release © Trust Codes Limited 2019
Page 1
1.2 If you choose not to supply us with this information, we may not be able to allow you to access or use our products or services (or all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.
1.3 You are always welcome to provide us with comments, queries and feedback in relation to our products and services. We may record and monitor telephone calls and other communications between you and us for training, quality control and compliance purposes.
1.4 When you communicate with us, we may collect additional information including the languages you speak, how best to manage communications with you, and information about your dealings with us.
1.5 If you participate in a survey or competition, or respond to a feedback request, we will collect the information that you provide in doing so, and associated information such as when and how you submitted the response.
1.6 We collect information about people who invest in us.
1.7 We collect information about people who are our employees, contractors, suppliers and business partners, or who are employed by our contractors, suppliers and business partners. The information we collect is what we need to conduct business with that individual or party.
1.8 When you do business with us, we may collect information about you from others, such as from referees or from others who do business with you.
1.9 Our website may contain links to other websites. We are not responsible for the privacy practices or the content of those other websites. The privacy practices applicable to those other websites may differ substantially from ours, so we advise you to read the privacy policy of those other websites before using them.
1.10 When using our products and services (including our website), we will collect information about you and about your use of our products and services, such as which services you use and how you use them. We will collect information such as:
- user name and password;
- device information, such as the model and ID of the device you use, operating system,
- telephone number and mobile phone network;
- server log information, such as details of how you used the products or service (including our
website), IP address, hardware settings, browser type, browser language, the date and time of
your use and referral URL;
- your browser or your account using cookies (see below); and
- real-time location information.
1.11 Our products and services (including our website) may also detect and use your IP address or domain name for internal traffic monitoring and capacity management purposes or to otherwise administer the products and services. The patterns of usage of visitors to the online services may be tracked for the purposes of providing improved service and content based on aggregate or statistical review of user traffic patterns.
1.12 Our websites may use third party services, such as Google services (e.g. Google Analytics). For more about how Google collects and processes data, please see Google's Privacy Policy, Google Terms of Service and their information on how Google uses your data.
Trust Codes Limited Privacy Policy Page 2 August 2019
For Internal and External Release
© Trust Codes Limited 2019 1.13 We may also collect sensitive information about you such as information about your health, racial or ethnic origin, religious beliefs and criminal record if you provide your explicit consent or if we are otherwise allowed or required by law.
1.14 If we provide you with access to an environment where you can store and process personal information, such personal information is not collected, stored, used, processed, modified or disclosed by us (except to the extent required by permitted Trust Codes employees who may access customer environments for system configuration, maintenance and account administration purposes or as otherwise required by law).
1.15 Access to the data or information contained within any of these environments is controlled directly by you. It is your responsibility to obtain consent from individuals before their personal information is collected, stored, used, processed, modified or disclosed by you using any Trust Codes environment. You should familiarise yourself with the available Complementary User Entity Controls that enhance the security and privacy of our services to you.
2 How do we collect personal information?
2.1 We may collect personal information about you in the following ways:
- when you order products or services from us;
- when you use our online services, and other products and services (including our website);
- when you visit our sites or offices;
- when we visit your sites or offices;
- when you submit a query or request to us;
- when you respond to a survey that we run or fill in forms on our website;
- by tracking your use of our products and services (including our website);
- from third parties who are entitled to disclose that information to us;
- from publicly available sources;
- from online sources (including social media platforms and providers (e.g. LinkedIn);
- suppliers of information products and services (e.g. companies that consolidate data from
multiple public sources);
- when you apply for a job with us; or
- other lawful means.
2.2 From time to time, we may use third-party online services to collect personal information such as your name and email address or telephone number to administer online competitions, customer feedback and surveys.
2.3 If you provide us with personal information about someone else, you must only do so if that person has consented to you doing so and to us collecting, holding, using and disclosing their information in accordance with this privacy policy.
2.4 We may also collect personal information about you and your use of our website, products and services using cookies. We use cookies to monitor and observe your use of our website, products and services, compile aggregate data about that use, and customise parts of our products and services or our website based on your preferences and past activities.
2.5 Cookies are small, usually randomly encoded, text files that help your browser navigate through a particular website. The cookie file is generated by the website you are browsing and is accepted and processed by your computer's browser software. The cookie file is stored in your browser's folder or subfolder. For more information, see: http://www.allaboutcookies.org/
Trust Codes Limited Privacy Policy Page 3 August 2019
For Internal and External Release
© Trust Codes Limited 2019 2.6
2.7
3 3.1
Permanent, persistent or stored cookies are stored on your device in between your use of our website which allows your preferences or actions to be remembered. When using our website, we also allow the use of some third party cookies which are set by a domain other than our website (for example, Google may set a cookie on your browser).
Modern internet browsers have a facility that will allow you to disable cookies altogether and you can refer to your browser’s help menu to find out how to do this. While you will still be able to browse our website with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly, and our ability to deliver our service to you may be limited. It also may degrade the user experience.
How do we use personal information?
We use personal information that we collect about you to:
- verify your identity when you are dealing with us;
- determine your eligibility for any of our products or services;
- augment and maintain our relationship with you or assist our customers to maintain their
relationship with you;
- enable us to provide you or your organisation with our products and services on our behalf,
or our customers’ behalf;
- answer your queries and requests;
- comply with our legal and regulatory obligations;
- carry out market analysis and research;
- monitor use of our products and services on our behalf and if required, on our customer’s
behalf;
- assess, operate, maintain, upgrade and improve our marketing, products and services;
- provide better products, services and information to our customers and to the community;
- carry out education and training programs for our employees;
- manage and resolve any legal or commercial complaints or issues (including debt recovery);
- meet our obligations and perform our functions under applicable laws and agreements;
- maintain and update our records or our customers’ records;
- use in accordance with any request or instructions from you;
- carry out planning and forecasting activities and other internal business processes;
- keep you informed about our and/or our customers’ activities and notify you of changes to
our products or services;
- use as otherwise required, or authorised by law or government agency.
We may also use your personal information for any other purpose as authorised by you.
We may use and disclose your personal information for marketing purposes (but we will not sell your personal information to any third party). Either we and/or our customers may contact you about our or their products and services, the products and services of other people (including customers), or related special offers from our business partners, that we think may be of interest to you.
We may use and disclose your personal information to carry out consumer and market research, compile demographics and perform other research and analysis so that we can develop and implement initiatives to improve our services, improve the design, construction and operation of our products and identify people likely to be interested in our products and services.
3.2 3.3
3.4
Trust Codes Limited Privacy Policy Page 4 August 2019
For Internal and External Release
© Trust Codes Limited 2019 3.6
3.7
We may de-identify information about you so that the information can no longer be used to identify you. We may use and disclose de-identified personal information in the course of our business (including in any promotional or marketing material).
We may aggregate information on the use of our products and services (including our website) in such a way that the information can no longer be related to the identifiable individuals. We may use and disclose aggregated information in the course of our business (including in any promotional or marketing material).
4 Who do we disclose personal information to? 4.1 We may disclose your personal information to:
- representatives, advisers and others you have authorised to interact with us on your behalf;
- related entities within our corporate group;
- our customers
- our employees and third parties including business partners, consultants, contractors,
suppliers, service providers, professional advisers and agents who need the information to
assist us with conducting our business activities;
- prospective purchasers of all or part of our business or shares in our company or a related
entity;
- government agencies or authorities, regulators, law enforcement agencies and other parties
where authorised or required by law who ask us to disclose that information and to which we
are legally required to disclose your personal information;
- parties identified at the time of collecting your personal information or as otherwise
authorised by you. |
|---|
