USM Pty Ltd (ACN 166 162 296) (we, us, our) is committed to providing quality services to you. This policy explains how we manage your Personal Information.
We are bound by the Australian Privacy Principles (Privacy Principles) contained in the Privacy Act 1988 (Cth) (the Privacy Act).
The Privacy Principles govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Privacy Principles can be obtained from the website of The Office of the Australian Information Commissioner, located at www.privacy.gov.au.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual.
We collect your Personal Information for the primary purpose of providing our services to you and our other clients, providing information to you and our clients generally, and marketing (unless you advise us that you do not want to receive marketing material from us). We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
As a general rule, we only process Personal Information for purposes that would be considered relevant and reasonable in the circumstances, including providing you with our goods and services.
How we collect your Personal Information
We will collect and hold your Personal Information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your Personal Information directly from you. We may collect the Personal Information you directly give us through some of the following means:
- where you provide this in person, for example, if you visit our booth at a trade exhibition we are appearing at;
- when you make an inquiry through the Website, or use other features of it;
- when you register as a user of our Apps;
- when you sign up to receive our email newsletter;
- when you enter a contest or another promotion with us;
- in administering and performing any contracts;
- when you contact us via telephone or facsimile;
- from correspondence (whether in writing or electronically);
- through any devices or mobile applications, including but not limited to the Apps, provided by our organisation;
- while conducting customer satisfaction and market research surveys;
- when administering any of our services; and
- as otherwise required to manage our business.
However, in certain cases we may collect Personal Information from publically available sources or from other third parties, such as suppliers, recruitment agencies, contractors, our clients and business partners.
When we collect Personal Information from you, we will take such steps (if any) as are reasonable in the circumstances to notify you or ensure you are aware:
- of our identity and contact details;
- that we have collected your Personal Information, and whether that collection is required or authorised by law;
- of the purposes of collection;
- of the consequences if Personal Information is not collected (such as if this will affect our ability to provide products or services to you);
- of the manner in which we may disclose Personal Information of the kind collected;
- whether we are likely to disclose Personal Information to overseas recipients, and if practicable, the relevant countries in which they are located.
If we collect Personal Information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
Types of Personal Information we collect
The kinds of Personal Information we may collect and hold, such as when you engage us to provide you with goods or services, or use our Apps, can include (but are not limited to):
- your name;
- your date of birth;
- your contact information, including postal and residential addresses, telephone and facsimile numbers, and email addresses;
- billing information, including credit card information; and
- location data.
We may also collect and hold Sensitive Information about you, including:
(a) health information, including heart rate and body temperature information;
(b) your racial or ethnic origin;
(c) your sexual orientation;
(d) your religious beliefs or affiliations;
(e) genetic information;
(f) your membership of any trade unions, professional or trade associations, or political parties;
(g) biometric information or biometric templates.
We only collect Sensitive Information about you with your consent, or otherwise in accordance with the Privacy Act. Sensitive information will be used by us only:
(a) for the primary purpose for which it was obtained;
(b) for a secondary purpose that is directly related to the primary purpose;
(c) with your consent; or where required or authorised by law.
You may visit our Website or use our Apps anonymously. However, where you do not wish to provide us with your Personal Information, we may not be able to provide you with requested goods or services, and in the case of our Apps, you may not be able to experience their full functionality.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Using our Goods and Services (including our Apps) through an Employer or other associated Organisation
You may have access to our goods or services, including our Apps, because you are associated with (for example as an employee, contractor or visitor) an organisation that has been licensed to use certain proprietary technology of Universal Site Monitoring, specifically, our Universal Data Interface (UDI).
Using our goods and services, including the Apps if you permit the App to have access to such data via your device, may result in certain Personal Information and/or Sensitive Information about you being collected as set out above.
Your use of our goods and services, including the Apps, is linked to your associated organisation’s use of the UDI, and any Personal Information or Sensitive Information about you that it is collected via your use of the GAM Apps is user data that may be sent directly to your associated organisation or stored by us for access by your associated organisation. We will handle any such information stored by us in accordance with this document.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
- third parties, where you consent to the use or disclosure; and
- where required or authorised by law.
We may also disclose your Personal Information to your associated organisation, if you access our goods or services, including our Apps, because of your association with that organisation (as described in the section ‘Using our goods and services (including our Apps) through an employer or other associated organisation’ above).
We collect, hold, use and disclose Personal Information to:
(a) offer and provide you (or your associated organisation) with our goods and services;
(b) manage and administer those goods and services, including account keeping procedures;
(c) personalise your Website experience and allow us to deliver the type of content and product offerings in which you are most interested;
(d) communicate with you, including (but not limited to), emailing you tax invoices, dispatch and tracking information, returns and exchange authorisations, and to better respond to your customer service requests;
(e) administer contests, promotions, surveys, and other Website features;
(f) assess prospective employees;
(g) manage our contractors;
(h) perform our engagements by clients;
(i) comply with our legal and regulatory obligations; and
(j) otherwise to manage our business.
We will not use or disclose your Personal Information for any other purpose unless we believe that you would reasonably expect this to occur, you have consented to such use or disclosure, or the use or disclosure is otherwise required or permitted by law.
We may disclose Personal Information between our organisations or to third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. We may also contract with third party service providers to assist us in better understanding our website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. We will hold Personal Information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.
We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of Personal Information. This also applies to disposal of Personal Information.
We further protect Personal Information by restricting access to Personal Information to only those who need access to the Personal Information do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your Personal Information, such as the use of secure servers.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. Any Personal Information stored in client files will be kept by us for a minimum of 7 years to comply with our business obligations.
Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us (such as where you have signed up to receive our email newsletter), or from third parties which may be of interest to you.
We may disclose your Personal Information to third party service providers for the purposes of assistance with our own marketing activities. We will not otherwise disclose your Personal Information to third parties for marketing purposes without your consent.
You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting our Privacy Officer utilising the contact details set out below.
You may choose to turn off all cookies using your browser’s settings, however you will no longer have access to many features that make your site experience more efficient, and some of our services will not function properly.
Access to your Personal Information
You may access the Personal Information we hold about you and/or request that we update or correct it or delete it entirely, at any time. If you wish to access your Personal Information, please contact the Privacy Officer. On the rare occasions when we refuse access or deletion, we will provide you with a written notice stating our reasons.
Universal Site Monitoring will not charge any fee for your access or deletion request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing or deleting the requested information.
We are not obliged to correct any of your Personal Information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
We will respond to all requests for access to or deletion or correction of Personal Information within a reasonable time. You can revoke your consent to our Apps having access to any Personal Information or Sensitive Information of yours at any time by changing the Apps’ permissions in your device settings.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Overseas Transfers of Personal Information
From time to time we may engage service providers located outside of Australia to provide services to us, which may involve your Personal Information being transferred to locations outside of Australia. For example, we may use cloud-based storage providers to hold your Personal Information on our behalf in locations outside of Australia.
By providing your Personal Information to us, you consent to us disclosing your Personal Information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that Privacy Principle 8.1 will not apply to such disclosures.
For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
This Policy may change from time to time without notice to you and an up-to-date copy is available on our Website.
The Privacy Officer
Universal Site Monitoring
GPO Box 2619
Darwin NT 0801
Telephone: +61 (0)8 8986 7177
We take all complaints seriously, and will respond to your complaint within a reasonable period.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992