CENTENARY LANDSCAPING SUPPLIES

1. INTRODUCTION

1.1 In the course of our business in Australia, there are circumstances where we collect personal information. This privacy policy has been developed to ensure that such information is handled appropriately.

1.2 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way in which personal information must be treated.

1.3 This privacy policy also incorporates our policy on managing credit information (see particularly section 8 onwards).

Who does the privacy policy apply to?

1.4 This policy applies to any individual for whom we currently hold, or may in the future collect, personal information.

What information does the privacy policy apply to?

1.5 This policy applies to personal information. In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified.

1.6 Information is not personal information where the information cannot be linked to an identifiable individual.

2. HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?

2.1 We manage the personal information we collect in numerous ways, such as by:

(a) implementing procedures for identifying and managing privacy risks at each stage of the information lifecycle, including collection, use, disclosure, storage, destruction or de-identification;

(b) implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure, and regularly reviewing those systems for ongoing compliance;

(c) regularly providing staff with training on privacy issues;

(d) appropriately supervising staff who regularly handle personal information;

(e) implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints;

(f) regularly discussing privacy issues and obligations at staff meetings;

(g) engaging specialists to ensure information is held and stored securely;

(h) regularly destroying or de-identifying personal information when it is no longer required;

(i) appointing a designated privacy officer within the business to monitor privacy compliance; and

(j) allowing individuals the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances.

2.2 We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.

2.3 In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us (e.g. for some cash sales or general enquiries). However, if you would like to order a product or service from us, we will need your personal information in most instances in order to supply you with the product or service.

3. WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?

Personal information

3.1 We may collect and hold personal information about you, which may include:

(a) sensitive information (see below);

(b) contact information;

(c) financial information;

(d) date and place of birth;

(e) gender;

(f) employment arrangements and history;

(g) trade qualifications;

(h) associated businesses and the details of those businesses;

(i) marketing preferences;

(j) credit information;

(k) banking and credit card details; and

(l) any other personal information required to provide you with the requested product or service.

Sensitive information

3.2 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.

3.3 The sensitive information we collect and hold about you may include any of the following:

(a) health information; and

(b) membership of professional or trade associations.

3.4 We will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.

4. HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?

4.1 Our usual approach to collecting personal information is to collect it directly from you.

4.2 We may also collect personal information in other ways, which may include:

(a) from government bodies (such as government licencing bodies);

(b) trade associations;

(c) through referrals from individuals or other entities;

(d) credit reporting bodies and credit providers;

(e) other publicly available sources of information;

(f) through trade and business events;

(g) from third party providers and suppliers; and

(h) from colleagues, associates or relatives of yours (where necessary, we will make reasonable enquiries to verify the information).

5. HOW DO WE HOLD PERSONAL INFORMATION?

5.1 Our usual approach to holding personal information includes:

(a) physically:

(i) at our premises (securely); and

(ii) off-site, by third party physical storage providers (securely);

(b) electronically:

(i) on secure online servers;

(ii) on a private cloud;

(iii) by a third party data storage provider; and

(iv) on our website.

5.2 We secure the personal information we hold in numerous ways, including:

(a) securely archiving paperwork until destruction;

(b) regularly destroying documents that are no longer needed;

(c) using secure servers to store personal information;

(d) using unique usernames, passwords and other protections on systems that can access personal information; and

(e) holding certain sensitive documents (such as credit applications) securely.

6. WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?

6.1 We are a landscaping supply business that provides landscaping products to businesses and consumers throughout Queensland.

6.2 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which we collect your personal information is generally to provide the landscaping products and services you have requested for you or your business.

6.3 In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.

6.4 Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection.

6.5 For example, we may collect and use your personal information:

(a) to keep record of transactions to assist in future enquiries and enhance our customer relationship with you;

(b) to inform you of new products, services and events;

(c) for marketing purposes;

(d) for delivery purposes; and

(e) to provide you with credit.

6.6 We may disclose personal information to:

(a) government bodies;

(b) to other service providers or contractors in order to provide the product or service for you, or to assist our functions or activities (such as debt collection agencies, suppliers or legal firms);

(c) to other third parties with your consent; and

(d) to our third party technology providers such as our data storage providers and website providers.

6.7 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.

7. WILL WE DISCLOSE PERSONAL INFORMATION OUTSIDE AUSTRALIA?

7.1 We do not disclose personal information outside of Australia, aside from our website host which is located in the United States.

8. HOW DO WE MANAGE YOUR CREDIT INFORMATION?

What kinds of credit information may we collect?

8.1 In the course of providing our products or services to you, we may collect and hold the following kinds of credit information:

(a) your identification information;

(b) information about any credit that has been provided to you;

(c) your repayment history;

(d) information about your overdue payments;

(e) if terms and conditions of your credit arrangements are varied;

(f) if any court proceedings are initiated against you in relation to your credit activities;

(g) information about any bankruptcy or debt agreements involving you;

(h) any publicly available information about your credit worthiness; and

(i) any information about you where you may have fraudulently or otherwise committed a serious credit infringement.

8.2 In some circumstances, we may collect credit information and personal information from credit reporting bodies (e.g. Veda). The kinds of information we collect may include any of those kinds of information outlined in sections 3.1 and 8.1 of this policy.

8.3 We may also collect personal information which may affect your credit worthiness from other credit providers (e.g. banks) that collect information from credit reporting bodies. The kinds of personal information we collect may include any of those kinds of personal information outlined in section 3.1 of this policy.

How and when do we collect credit information?

8.4 In most cases, we will collect credit information about you directly from you.

8.5 We may also collect credit information about you from:

(a) government bodies;

(b) credit reporting bodies;

(c) banks and other credit providers;

(d) other individuals and entities via referrals; and

(e) other suppliers and creditors.

How do we store and hold the credit information?

8.6 We store and hold credit information in the same manner as outlined in section 5 of this policy.

Why do we collect the credit information?

8.7 Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the requested product or service.

8.8 We may also collect the credit information:

(a) to process payments;

(b) to assess eligibility for credit; and

(c) for any other purpose that we consider necessary to best provide you with the landscaping product or service.

Overseas disclosure of the credit information

8.9 Apart from our website host, which is located in the United States of America, we will not disclose your credit information to entities without an Australian link unless you expressly request us to.

How can I access my credit information, correct errors or make a complaint?

8.10 You can access and correct your credit information, or complain about a breach of your privacy in the same manner as set out in section 9 of this policy.

9. HOW DO YOU MAKE COMPLAINTS AND ACCESS AND CORRECT YOUR PERSONAL INFORMATION OR CREDIT INFORMATION?

9.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.

Access to information and correcting personal information

9.1 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.

9.2 We will grant you access to your personal information as soon as possible, subject to the request circumstances.

9.3 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.

9.4 We may deny access to personal information if:

(a) the request is unreasonable;

(b) providing access would have an unreasonable impact on the privacy of another person;

(c) providing access would pose a serious and imminent threat to the life or health of any person;

(d) providing access would compromise any government or licencing obligations; or

(e) there are other legal grounds to deny the request.

9.5 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.

9.6 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.

Complaints

9.7 If you wish to complain about an alleged privacy breach, then you must follow the following process:

(a) The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.

(b) In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.

Who to contact

9.8 A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address or contact officer:

Contact: Privacy Officer

Postal Address: PO Box 686, Sumner Park Qld 4074

Telephone number: 07 3373 4900

Email address: privacyofficer@centland.com.au

10. CHANGES TO THE POLICY

10.1 We may update, modify or remove this policy at any time without prior notice. Any changes to the privacy policy will be published on our website.

10.2 This policy was last updated in March 2014. If you have any comments on the policy, please contact the privacy officer with the contact details in section 9 of this policy.

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