In this policy the expressions "we", "us" and "our" are a reference to Gordon Brothers Pty Ltd ABN 42 616 884 274 (Gordon Brothers Australia) and each of its Related Bodies Corporate (together, Gordon Brothers Group).
The expressions "you" and "your" refer to each individual whose Personal Information we may handle from time to time where we are required to comply with the Privacy Act in respect of such Personal Information.
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
Related Bodies Corporate has the same meaning as under the Corporations Act 2001 (Cth).
Sensitive Information means:
(a) information or an opinion about an individual’s:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual orientation or practices; or
(ix) criminal record;
that is also Personal Information; or
(b) health information about an individual; or
(c) genetic information about an individual that is not otherwise health information; or
(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(e) biometric templates.
Spam Act means the Spam Act 2003 (Cth).
2. Types of information collected
We only collect Personal Information to the extent that this is reasonably necessary for one or more of our functions or activities.
This includes but is not limited to the following kinds of information:
(a) your contact details, such as name, company name, address, telephone number and/or email address; and
(b) additional details required to fulfill an order on the Site, such as delivery address, financial and credit card information (encrypted on our service providers' servers for added protection).
We may also collect certain aggregate and non-personal information when you visit our Site. This is information that you do not visibly enter, such as your IP address, browsing pattern on the Site and/or click stream.
3. Method of collection
Our preference is to collect Personal Information about an individual directly from that individual unless it is unreasonable or impracticable for us to do so.
Information will generally be collected from the following sources:
(a) collected directly from you when you provide information to us, via our Site or directly to us in another manner; and
(b) collected from your computer or other device when you visit our Site.
4. Purposes of collection, use and disclosure
We may use and disclose your Personal Information for the primary purpose for which we collected your Personal Information, for reasonably (or directly if the Personal Information is Sensitive Information) related secondary purposes within your reasonable expectations and where required or authorised by law including, but not limited to:
(a) providing our services;
(b) fulfilling information requests;
(c) signing up for conferences and events;
(d) applying for a position with a member of the Gordon Brothers Group;
(e) participating in our user posting areas (eg. with surveys);
(f) sending news and information about our activities, events and general promotional material which we believe may be useful to you;
(g) monitoring who is accessing our Site or using services offered on the Site and profiling the type of people accessing the Site; and
(h) transferring the Personal Information that we have collected about you to a successor in the event that we sell or transfer all or a portion of our business or assets.
If you do not provide us with Personal Information, we may not be able to provide you with our goods or services or certain aspects of the Site may not operate correctly.
We may also share Personal Information provided by you with service providers we have retained to provide services on our behalf. In addition, we may disclose Personal Information about you where otherwise permitted under the Privacy Act, such as if we are required to do so by law or pursuant to legal process, or in response to a request from law enforcement authorities or other government officials in connection with an investigation of suspected or actual illegal activity.
5. Communication from us
We do not use Sensitive Information for marketing purposes.
We may use and disclose your Personal Information (other than Sensitive Information) to provide you with information on offers, products and services offered by us and you expressly consent to us doing so.
If at any time you no longer wish to receive any direct marketing from us or do not want your information disclosed for direct marketing, contact our Privacy Officer using the details in paragraph 12. Please note that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services and other factual information as permitted under the Privacy Act and Spam Act.
6. Storage of data and overseas disclosure
We, including our service providers, may hold electronic records of your Personal Information using cloud technology or by other electronic means, or in paper form. These means of holding Personal Information may include offshore storage.
We may disclose Personal Information to other parties including other members of the Gordon Brothers Group and service providers as permitted by the Privacy Act. These third parties may be located overseas including in the United States and other locations in which Gordon Brothers Group members do business. It is not practicable for us to specify in advance the location of every service provider with whom we deal.
7. Employee records
In accordance with the Privacy Act, this policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, and an employee record held by us relating to the employee.
8. Data security and third party websites
We will take such steps as are reasonable in the circumstances to protect the Personal Information we hold from misuse or loss and from unauthorised access, modification or disclosure, including appropriate physical, electronic and managerial procedures. We will also take steps as are reasonable in the circumstances to destroy or de-identify Personal Information once we no longer need it for any purpose for which the information may be used, disclosed or retained under the Privacy Act. However, when using our Site you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you provide us over the Internet and you do so at your own risk.
We may provide links to third party websites as a service to you. Those links are provided for convenience only and may not remain current or be maintained. We are not responsible for the content or privacy practices associated with third party websites, which may differ from those of our Site. We encourage you to review and understand the privacy policies of those websites before providing any information to them.
10. Access, correction and further information
We will take such steps as are reasonable in the circumstances to ensure that the Personal Information which we collect remains accurate, up to date and complete.
We will provide you with access to your Personal Information held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us via the details in paragraph 12 if you:
(a) wish to have access to the Personal Information which we hold about you;
(b) consider that the Personal Information which we hold about you is not accurate, complete or up to date; or
(c) require further information on our Personal Information handling practices.
There is no charge for requesting access to your Personal Information but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Act, to correct that information if you so request.
We will respond to all requests for access and/or correction within a reasonable time.
If you have a complaint or inquiry about the way in which we have handled any privacy issue, please advise us via the details in paragraph 12.
We will use reasonable efforts to deal promptly with complaints and inquiries and, in any event, acknowledge your complaint or inquiry within 30 days.
If you are not satisfied with how we manage your complaint, you may contact the Office of the Australian Information Commissioner.
12. Contact Information
Our Privacy Officer may be contacted at:
Attention: The Privacy Officer
Mail: Suite 3, Level 14
20 Hunter Street