1. Purpose of our Privacy Information Statement
BMD Associate Enterprises Ltd Pty as trustee for BMD Associate Enterprises Discretionary Trust trading as SquaredImpact (“we”, “us” or “our”) has adopted this Privacy Information Statement to ensure that we communicate to you how we use and disclose your personal information and how you may access that information or make complaints about the way we use, disclose or store your information.
1. We also have a Privacy Policy which documents the procedures that we use to collect, use, store and disclose personal information, including the way complaints and requests for access and correction are managed. We recommend that you read both documents in conjunction with each other.
2. Our Privacy Information Statement and Privacy Policy follow the standards of
the Australian Privacy Principles set by the Australian Government for the handling of personal information under the Privacy Act 1988 (Cth) including amendments to the Act in March 2014.
2. The information we collect
In the course of business it is necessary for us to collect personal information. We always let you know when we are collecting information. This information allows us to identify who you are for the purposes of our business, contact you in the ordinary course of business and transact with you. Without limitation, the type of information we may collect about you is:
1. Identity Information – we may collect personal details such as your name, location, date of birth, nationality, details of licenses & registrations, associations, family details, passwords, clues, employment details and third-party usernames and other information that allows us to identify who you are;
2. Contact Information – we may collect information such as your email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact you;
3. Financial Information – we may collect information about your finances such as your bank accounts and credit cards, the value of transactions you undertake with us or through our services, the value of certain assets that you declare to us and other information that allows us to transact with you and/or provide you with our services;
4. Statistical Information – we may collect information about your online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes.
5. Health Information – we may indirectly receive health and medical information about you from our customers, although we do not have access to this information.
6. Social Information – we may indirectly receive social information about your employment, family, income, social & community services, although we do not have access to this information.
We may collect other personal information about you, which we will maintain in accordance with our Privacy Policy. We may also collect non-personal information about you such as information regarding your computer, network and browser. This may include your IP address. Where non-personal information is collected the Australian Privacy Principles do not apply.
Individuals have the option to not identify themselves to us, or to use a pseudonym, unless we are required or authorised by law to deal with individuals who have identified themselves, or it is impracticable for us to deal with individuals who have not identified themselves.
We may directly or indirectly collect or receive sensitive information. Where we collect sensitive information we will comply with the requirements under the Australian Privacy Principles to:
a. seek consent before collecting the sensitive information and ensure that the information is reasonably necessary for one or more of our functions or activities (unless an exemption in the Australian Privacy Principles applies), where the information is directly solicited; or
b. Where the information is unsolicited, destroy or de-identify the information if we determine that we could not have obtained the information if we had sought to solicit it directly (and the information is not containing a Commonwealth record).
3. When your personal is information used & disclosed
The primary principle is that we will not use the information you provide us other than for the purpose for which it was collected other than with your permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
Your information is used to enable us to operate our business, especially as it relates to you. This may include:
1. The provision of goods and services between you and us.
2. Verifying your identity.
3. Communicating with you about your relationship with us; our goods and services; marketing and promotions; and competitions, surveys and questionnaires;
4. Investigating any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or as required or permitted by any law (including the Privacy Act).
5. It is necessary, and you consent, for us to disclose your personal information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business, which includes investigations into your conduct insofar as it relates to your relationship with us or a possible contravention of any relevant laws or regulations. We will not disclose or sell your personal information to unrelated third parties under any circumstances.
6. There are some circumstances in which we must disclose your information that you should be aware of: as part of a sale (or proposed sale) of all or part of our business; and/or; as required or permitted by any law (including the Privacy Act).
7. We will not disclose your personal information to any entity outside of Australia that is in a jurisdiction that does not have a similar regime to the Australian Privacy Principles or an implanted and enforceable privacy policy similar to our Privacy Policy.
4. Opting “in” or “out”
1. You may opt to not have us collect your personal information. This may prevent us from offering you some or all of our services and may terminate your access to some or all of the services you access with or through us. You will be aware of this when:
1. Opt In. Where relevant, you will have the right to choose to have information collected and/or receive information from us; or
2. Opt Out. Where relevant, you will have the right to choose to exclude yourself from some or all collection of information and/or receiving information from us.
2. If you believe that you have received information from us that you did not opt in or out to receive, you should contact us using the details below.
3. We will not use your personal information for direct marketing except where an exemption under APP 7 of the Australian Privacy Principles applies.
5. How to access and/or update your information
1. We endeavour to ensure that the personal information collected and disclosed is accurate, up-to-date, and complete.
2. You have the right to request from us the personal information that we have about you, and we have an obligation to provide you with such confirmation within 28 days of receiving your written request unless an exemption in Australian Privacy Principle 12 applies.
3. If you have an online account or membership with us, you will most likely be able to update all your necessary details from within your private account.
4. It is your responsibility to provide us with accurate and truthful personal information. We cannot be liable for any information that you provide us that is incorrect.
5. We may charge you a reasonable fee for our costs incurred in meeting any of your requests to disclose the personal information we hold about you.
6. Complaints and disputes
1. If you have a complaint about our handling of your personal information, you should address your complaint in writing to the details below.
2. If we have a dispute regarding your personal information, we both must first attempt to resolve the issue directly between us.
3. If we become aware of any unauthorised access to your personal information we will inform you at the earliest practical opportunity once we have established what was accessed and how it was accessed.
7. Contacting us
1. You should address all correspondence to the Privacy Officer with regards to privacy by email info@squaredimpact.com.au in the first instance.
2. Correspondence regarding privacy can also be mailed to The Privacy Officer at the following address:
The Privacy Officer
SquaredImpact
PO Box 174 Yarraville
VIC 3013
