Privacy Policy

What is personal information and what we collect and hold?

In this Privacy Policy, personal information refers to information or an opinion about an identified individual, or an individual who is reasonably identifiable, regardless of the format in which it is recorded and whether the information or opinion is true.

For ease of reference, throughout this Privacy Policy, we refer to personal information as data. The kinds of data we may collect, hold and process about you depends on how you interact with us. For example, we may collect and hold data which includes, but is not limited to:

• your name, phone number, street address, postal address, email address, date of birth, gender, signature and occupation;
• financial information (for example, your credit information and bank account details);
• government related identifiers (for example, Australian driver's licence numbers and passport numbers);
• the location of your computer's IP address and the computer system you are using;
• details of how you interact with us, including via the Website;
• employment history and educational or training qualifications, and with your consent, other reasonable or potentially sensitive information required to onboard you and/or process an application for employment if you are a prospective employee and/or otherwise required or permitted by law. The inability by us to collect or validate certain information may result in us being unable to properly onboard you or proceed with an application for employment;
• photographs, video or CCTV footage in which your image appears or voice is recorded;
• other data required for us to provide a Product or Service or respond to your information requests, including trading and/or transactional history; and
• any other data about you or third parties that you provide to us directly.

How do we collect your data?

We collect data directly from you when providing our Products and Services, during the course of commercial trading and marketing activities, and when onboarding a new employee or as part of our recruitment process. This may occur when we contact you via email, over the phone, in person, or during your interactions with our Website or social media pages.

We may also collect data from publicly available sources or third parties whom you have authorised us to deal with, to enable our provision of the Products and Services.

Why do we collect your data?

We collect your data for a number of reasons, including:

• security and verification of identity purposes;
• operating, developing, improving or refining our Products and Services, including tailoring them to provide a customised experience;
• providing our Products and Services or information about them, and driving engagement with our business;
• responding to enquiries and providing requested information;
• complying with legal obligations and quality assurance purposes;
• assessing the employability of job applicants;
• enabling third-party service providers to support delivery of our Products and Services;
• cooperating with law enforcement bodies and government agencies where required by law; and
• updating our records and keeping data accurate and current.

Our use of your data may extend beyond the purposes described above but will remain restricted to activities related to our business functions.

Who do we share your data with?

We may disclose your data to:

• service providers and contractors that store data, verify identity, or process payments on our behalf;
• professional advisers and commercial partners such as accountants, credit agencies, consultants, financial institutions, and lawyers;
• merchants or financial institutions to facilitate transactions or investigate disputes; and
• law enforcement or government agencies as required by law, including AUSTRAC.

How do we hold and secure your data?

We store electronic copies of data and generally avoid retaining hard copy documentation wherever practicable. Electronic data is secured using password-protected systems, databases, and multi-factor authentication. Our physical premises are secured with locks, alarms, and CCTV.

Where data is no longer required by law or for the purposes outlined in this Privacy Policy, it is securely destroyed.

Do we send your data overseas?

We are based in South Australia, Australia. Some service providers (such as IT or software providers) may store data outside Australia.

Do we use your data for direct marketing?

We may use your data for direct marketing, including newsletters, event invitations, promotions, and information about our Products, Services, and operations.

Cookies and Google Analytics

Our Website uses cookies to recognise returning visitors and store preferences. Cookies do not collect personally identifiable information such as email addresses.

You can disable cookies via your browser settings; however, some Website features may not function correctly.

We may use Google Analytics to analyse Website traffic. You can opt out via https://tools.google.com/dlpage/gaoptout .

How can you access or correct data we hold about you?

Contact our Compliance Officer:

Requests may be refused where they are frivolous, vexatious, legally restricted, or identity cannot be verified.

How can you make a complaint or contact us?

Complaints may be directed to the Compliance Officer using the contact details above. If unresolved, complaints may be escalated to the Office of the Australian Information Commissioner at www.oaic.gov.au .