This privacy policy (Privacy Policy) sets out how BG Private Pty Ltd ABN 33 642 872 236 and its related bodies corporate (as defined in the Corporations Act 2001 (Cth)) (we, our, us) collects, stores, uses, protects, shares and discloses your personal information. It applies to our website located at bgprivate.com.au and its related services, products, websites, social media pages, tools and applications (together the Website). By visiting or using the Website you agree to the collection, storage, usage and disclosure of your personal information by us in the manner described in this Privacy Policy.
1. Types of Personal Information we collect
As part of delivering our services we may collect personal information about you as defined under the Privacy Act 1988 (“Privacy Act”). We will only collect personal information where it is reasonably necessary for the performance of our functions or activities. The personal information we collect may include the following:
• Information you provide us: this includes information that we collect to assist us in fulfilling the provision of our services to you. If you provide us feedback or contact us via e-mail, or other means including by face-to-face meeting, by phone call, post, through social media or other communication or by contracting with us, we will collect your name and e-mail address, as well as any other content included in the e-mail or conversation. We collect this information in order to send you a reply or otherwise process your request. We will store and process your communications and information as needed. When you participate in one of our forms we may also collect additional information about you. At current this includes the following forms:
– Contact form: where we collect your name, email and phone number;
– Feedback form: where we collect your name, email and phone number;
– Job application form: where we collect your name, email, phone number, right to work status, CV, Cover Letter (optional) and Qualifications (optional);
– Newsletter subscription form: where we collect your email.
We may also collect your personal information from any other areas on the Website where a form is present. At the submission stage we will clearly label which information is required and which is provided at your discretion.
• Financial information: this includes information such as payment card details and bank account details. We use this information to send to our third party payment gateways when you make payment through the Website.
• Marketing use information: on the Website you may have the ability to subscribe to various newsletters and marketing lists. We may collect the data when you input your details for subscription purposes which may include your name, email address and email marketing preferences.
• Surveys: information in connection with client surveys, questionnaires and promotions.
• Other information we collect related to your use of the Website: your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information and any other information provided by you to us via our Website or our online presence, or otherwise required by us or provided by you.
2. How we collect Personal Information
We may collect personal information either directly from you, or from third parties, including where:
• you provide information directly to us through the Website or on a hardcopy form;
• you use the Website to enter in user content;
• you use the Website generally;
• you subscribe to any of our newsletters;
• you contact us through our Website, in person, by phone or in writing;
• you submit any of our content or data forms;
• you deal with us generally via email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise;
• you interact with our Website, social applications, services, content and advertising; and
• you invest in our business or enquire as to a potential purchase of our business.
We may also collect your personal information from third parties including our other service providers and publicly available sources. Where we collect your personal information from a third party, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. By providing personal information about another person to us, you represent that you are legally permitted to do so, and we will not be responsible for verifying any such authorisation.
Social media and cookies
We may also collect personal information from you when you use or access our Services or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your Services usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.
3. Use of your Personal Information
We collect and use personal information for the following purposes:
• to operate the Website and provide services or information to you including to:
– assist in streaming and personalising information for you;
– enable us to process your personal data;
– to manage our relationship with you, including information about our services or terms and conditions or send you an email reminder that a task you have performed on our Website remains uncompleted such an incomplete form;
– enable you to communicate with us regarding your use of the Website;
– confirm your identity;
– to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing the services to you;
– communicate with you about your Account, or any transaction;
• to be de-identified for the purposes of generating statistical data and improving the Website;
• for record keeping and administrative purposes, including accounting purposes;
• to improve and optimise our service offering and customer experience;
• to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
• to administer and protect our services;
• to enable you to take part in a competition;
• to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth)). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
• to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
• to consider an application of employment from you.
4. Disclosure of your Personal Information
We may disclose your personal information to third parties for the purposes contained in this Privacy Policy, including without limitation to:
Service providers
We may share your personal information with service providers utilised by us in the provision of the services to:
• develop and improve our services;
• provide you with the services;
• conduct quality assurance testing;
• provide support; and/or
• provide other services to us.
The service providers (and if necessary data processors) include:
• information technology service providers such as web host providers and analytical providers;
• mailing houses and such other suppliers that assist in delivering goods and services;
• organisations who carry out credit, fraud and other security checks;
• payment processors;
• hosting services;
• content delivery services;
• IT support providers;
• marketing businesses engaged by us to disseminate materials to which recipients have consented; and
• specialist consultants.
We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we give it to them.
Affiliates and acquisitions
We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (Affiliates). As part of your contract with us, we may need to transfer some of your personal information to one of our international Affiliates. We will use reasonable endeavours to ensure that the recipient jurisdiction has in place a similar regime which recognises your right to privacy. All our international affiliates have privacy statements which comply with the legal requirements of their jurisdiction.
In the event we are involved in a merger, acquisition or sale of assets we may disclose personal information collected by us to such entities that we propose to merge with or be acquired by, and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.
Third parties with your consent and in other circumstances
We may also disclose your personal information to third parties to whom you expressly ask us to send the personal information to, or to third parties where permitted under the Privacy Act or where required in order to provide our Services to you. This also includes:
• your authorised representatives;
• government and regulatory authorities and other similar organisations, as required or authorised by law or as required as part of the Services; and
• such entities that we propose to merge with or be acquired by.
Any information that you submit on the Website generally will be available to the audience as chosen by you at the time of submission. For example if you submit content on the Website in a public discussion, such content will be made available to the world at large.
We may need to disclose your information to third parties outside of Australia and service providers located internationally in order to enable us to provide the Services, this includes our service providers and contractors who are located overseas (telephone answering service, data analytics, IT services) and data processing services.
Where we use a supplier outside of Australia, we will take reasonable steps in the circumstances to ensure that such overseas recipient does not breach the Australian Privacy Principles (except where such steps are not required under the Privacy Act).
We may also aggregate and/or make anonymous your personal information including sensitive information to make it available for the purposes of generating statistical data for the conducting of research and improving the Services.
5. Remarketing
We may use third party vendor re-marketing tracking cookies, including the Google Adwords tracking cookie. Where we do so, this means that we will continue to show ads to you across the internet, specifically on the Google network. The third-party vendors, including Google, will place cookies on web browsers in order to serve ads based on past visits to our Website. You can opt out of Google’s use of cookies or device identifiers by visiting Google’s Ads Settings. Alternatively, you visit the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.
6. Emails & marketing
In order to provide our services to you, you agree to receiving emails from us for the following purposes:
• notifications about activity on the Website (which are set on by default) including recommendations, and general updates;
• communication from us or our representatives in connection with the services; and
• marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing. This includes where you have signed up to our marketing or promotional newsletters.
By default you will receive these email notifications to your email address you nominate at registration.
7. Storage & security
We use third-party cloud providers that provide hosting, data storage and other services.
We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measure to protect these systems. However, we cannot guarantee the security of your personal information.
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
We employ ‘Virtual Cabinet Document Portal’ software for publishing, accessing and storing files. When installing and registering the product, personal information may be provided to our overseas subsidiary in the UK in order to obtain the licence key or other access credentials for you to be able to use the product. The portal is hosted on servers in secure data centres in the UK managed by third party suppliers. As a consequence documents accessed using the portal will also be hosted on these servers in the UK. For more information on The Virtual Cabinet software please view their website.
8. Links
Our Services may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.
9. Requesting access or correcting your Personal Information
Subject to the Privacy Act, you have a right to access and correct any personal information about you that we may hold. If you wish to request access to the personal information, we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.
If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
If we receive a request from you to access or correct personal information we will respond to you within a reasonable time after receiving your request and in the manner requested by you, if it is reasonable and practicable for us to do so. We may charge a reasonable fee for giving access to the information.
10. If we can’t collect your Personal Information
If you do not provide us with the personal information described above, some or all of the following may happen:
• we may not be able to provide the Website to you, either to the same standard or at all;
• we may not be able to provide our services to you or handle your requests effectively;
• we may not be able to provide you with information about the Website that you may want; or
• we may be unable to tailor the content of our Website to your preferences and your experience of our services may not be as enjoyable or useful.
11. Notifiable data breach
In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions in Part IIIC of the Privacy Act or any other subsequent sections or legislation which supersede this Part IIIC, we will follow our relevant notifiable data breach procedures in compliance with the Privacy Act and relevant laws.
12. Updates
This Privacy Policy is subject to occasional revision and we reserve the right, at our sole discretion, to modify or replace any part of this Privacy Policy. It is your responsibility to check this Privacy Policy periodically for changes. Continued use of our Website or services shall indicate your acknowledgement of that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications. We may amend this Privacy Policy from time to time. Not all changes to our Privacy Policy will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.
13. Enquiries, requests & complaints
Enquiries regarding this Privacy Policy or the personal information we may hold on you, should be addressed with the Privacy Officer, whose contact details are below.
If you think your personal information, held by us, may have been compromised in any way or you have any other Privacy related complaints or issues, you should also raise the matter with the Privacy Officer.
We will ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances.
If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission, whose contact details are below.
Office of the Australian information Commission
Telephone
1300 363 992
Office address
Level 3, 175 Pitt Street, Sydney NSW 2000
Postal address
GPO Box 5218, Sydney NSW 2001
Website
www.oaic.gov.au
Contacting us
Entity
BG Private Pty Ltd ABN 33 642 872 236
Contact
Please contact us by submitting a contact form on the Website.