COMMUNITY TRADELINK. PRIVACY POLICY AND COMPLAINTS PROCESS
Privacy is important, especially when you consider the number of ways we communicate and interact these days. That’s why we’ve put together this statement. It explains how we collect, hold, use and disclose your personal information and who we share it with.
And because it’s guided by privacy laws, you can be sure we take your rights seriously. Above all, this statement is your assurance that we never take your privacy for granted and we always take the utmost care in protecting your personal information. We call this statement our Privacy Policy and it gives you rights and tells you the undertakings we give in relation to your personal information. You have a right to request access to the personal information that we hold about you and to ask us to correct it or delete it. You also have a right to make a complaint about how we have managed your personal information. Our Privacy Policy tells you how to do these things and how we will deal with your request or complaint.
When you visit our communitytradelink.com (the Website), use our services, or contact us, you accept that this Privacy Policy shows the way that we collect and manage your personal information. All personal information held by us will be governed by our most recent policy posted on the Website. This Privacy Policy was last updated 20 December 2019. If you continue to deal with us or visit our website, we will take it that you have consented to this Community Tradelink. Privacy Policy.
When we say ‘we’ or ‘us’ we mean Community Tradelink. a trading name of UBT Marketing Pty Ltd ACN 162 091 796 as trustee for UBT Marketing Trust ABN 84 296 716 805 (UBT) and any other authorised businesses that sell goods and services under the UBT brand.
Here are the questions we look at in our Privacy Policy; the answers can be found by scrolling down the page:
· What is "personal information"?
· When do we collect personal information?
· Do we collect personal information via websites?
· How do we use the personal information we collect about you?
· How do we check the quality of personal information?
· Who sees your personal information?
· Do we use your personal information for marketing?
· How do we keep your personal information safe?
· How can you see the personal information that we hold about you?
· How can you correct your personal information?
· What can you do if you have a question, problem or complaint about our use of your personal information?
What is "Personal Information"?
Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable.
When do we collect Personal Information?
1. We collect Personal Information about individuals directly from those individuals or their authorised representative:
a. When you interact with us, we may collect Personal Information, such as names, contact details and other relevant information. Some instances of this are when you:
· i. apply for access to our website
· ii. use our services
· iii. contact us by telephone
· iv. complete electronic, verbal or paper-based registrations, feedback, surveys, promotions, emails, instructions or enquiry forms
· v. subscribe to a publication, newsletter or mailing list
· vi. apply for a job or volunteer your services
· vii. provide information voluntarily.
b. We do not collect Sensitive Information without your consent and then only if it is reasonably necessary for one or more of our activities, for example for investigating a complaint.
2. We may also collect Personal Information about you from a third party or from a publicly available source, but only if:
a. You have consented to such collection or would reasonably expect us to collect information in this way. Example: When personal information is updated with another party trading under the UBT brand, this may be updated in our databases as well.
b. It was not reasonable or practical to collect this information directly from you. Example: We may obtain reports from the licensor of the Marketplace about services provided to members for understanding use by members, negotiating better terms, auditing reports and improving customer service.
Do we collect Personal Information via websites?
1. We do not collect any Personal Information about visitors to websites except when they knowingly provide it or as otherwise described below.
2. Click Stream Data – when you visit and browse the Website, the Website may collect Personal Information for statistical reporting and maintenance purposes via Google Analytics and Wistia (for video).
3. Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as:
a. the date, time and duration of a visit;
b. whether the visitor has been to the site before;
c. what site referred the visitor to the Website; and
d. the number of users visiting the Website and the number of pages viewed.
4. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity browser type or website visiting patterns; if you access the Website a cookie may be downloaded onto your computer's hard drive when you first log onto the Website and it is automatically deleted from your hard drive after a period of thirty days.
a. Web beacons are images that originate from a third-party site to track visitor activities; we may use web beacons to track the visiting patterns of individuals accessing the Website.
b. Login audit logs are used to record a user’s usage history and selections.
c. We may implement a Live Agent Web chat application provided by Salesforce that collects data from users online so our staff can identify who they are speaking with.
How do we use the Personal Information we collect about you?
1. We use the information we collect about you to:
a. Establish your access to the Website
b. Identify you and conduct appropriate checks
c. Communicate with you
d. Provide you with services you have requested
e. Provide you with information about goods and services we reasonably believe you may be interested in
f. Provide you with general information we reasonably believe you may be interested in
g. Personalise and customise your experiences with the Websites
h. Help us research the needs and expectations of users and improve the provision of our services and preferred suppliers
i. Manage complaints and disputes, and report to dispute resolution bodies
j. Comply with Occupational Health and Safety regulations
k. Comply with industry codes or a lawful request.
2. We will only collect and use your Personal information in accordance with this Privacy Policy or otherwise with your prior express written consent. If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, the main consequences for you will be that we may not be able to provide you with all or some of the requested service.
How do we check the quality of Personal Information?
1. We take reasonable steps to ensure the personal information we collect is accurate, up to date and complete. We may do this by providing you access to edit some of your personal information, periodic update requests, when interacting with you and where practical electronic synchronisation of UBT databases.
2. We provide you the right to access and correct or delete Personal Information.
Who sees your Personal Information?
1. We disclose the information about you if or when:
a. We have your consent to share the information; or
b. Someone acting on our behalf provides the service you have requested; or
c. We reasonably believe that your actions on the Website violate our Terms.
2. We may disclose Personal Information to third parties but only to the extent necessary to fulfil the purposes for which the Personal Information was collected. Example: We may disclose Personal Information to our officers and employees and our professional advisers and consultants to help improve our services but only on a confidential and need-to-know basis.
3. We may also disclose your Personal Information to the website host in certain limited circumstances. Example: If the Website experiences a technical problem it can operate in an effective and secure manner.
4. We may disclose your Personal Information to organisations that are located in foreign countries solely for the purposes set out in this Privacy Policy provided that such disclosure is permitted under the applicable Privacy Principles. The applicable Privacy Principles permit disclosure to a person in a foreign country where we reasonably believe that the recipient of the information is subject to a law binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the applicable Privacy Principles. The foreign countries where information may be disclosed are likely to be New Zealand, USA, UK, Canada, Argentine and the Caribbean (which is where other of our affiliated entities reside) and in countries where our contracted service providers operate or store information such as virtual or cloud-based operations which may include additional countries such as Hong Kong and the Philippines. If you leave the Website by way of any hyperlink we advertise or display, we make no representation as to the privacy policy in place in any website visited by means of the hyperlink; you are required to make your own investigation and assessment as to the privacy policy of any website visited by this means. In particular, if you visit a payment gateway or a telecommunications site or the site of some preferred supplier mentioned on the Website, please be aware that the sharing of your personal information on those sites is not within the control or oversight of this privacy policy.
5. We may collect government related identifiers from you, which will be used or disclosed only where such use or disclosure is reasonably necessary to verify your identity for the purpose of an activity we are undertaking on your behalf.
Do we use your Personal Information for marketing?
1. We may use your Personal Information to provide you with promotional material about us or our services or services and products offered by UBT and its preferred suppliers. If you do not wish to receive promotional information you can contact our Privacy Officer by emailing [email protected] at any time requesting that your name be removed from our marketing lists.
2. Otherwise we will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the applicable Privacy Principles.
How do we keep your Personal Information safe?
1. We take reasonable steps to protect and keep your Personal Information from misuse, interference, loss, unauthorised access, modification or disclosure. The ways we do this include:
a. Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information
b. Limiting physical access to our premises and files
c. Limiting electronic access to our networks, applications and files
d. Using security related hardware and software
e. Implementing personnel safe practice policies and training
f. Monitoring and reviewing our practices periodically
g. Using third parties who meet obligations under the aplicable Privacy Principles.
2. We periodically consider whether we need to retain your Personal Information in order to continue providing our goods and services to you, and may destroy or de-identify your Personal Information, except where we are required by law to retain it.
How can you see the Personal Information that we hold about you?
1. You are entitled to access Personal Information that we hold about you.
2. Access to your Personal Information is subject to our being satisfied that you are the individual we hold Personal Information on or that the person requesting is authorised to make a request on your behalf.
3. If we delay or refuse your request to access some or all of your Personal Information, we will provide you written notice of the reasons for the delay or refusal, such as access would unreasonably impact upon the privacy of others or would not otherwise be permitted under the applicable Privacy Principles.
4. A request for access can be made by Email: to [email protected]
How can you correct your Personal Information?
1. You can update your Personal Information at any time by contacting the relevant us at [email protected] . Otherwise our Privacy Officer will correct your Personal Information. If we find that we have no further need for your Personal Information we will permanently de-identify it or remove it from our system and destroy all record of it. We welcome any changes to your details so as to keep our records up to date.
What can you do if you have a question, problem or complaint about our use of your Personal Information?
If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy Policy or the applicable Privacy Principles in respect of your Personal Information, please contact our Privacy Officer Email to [email protected] or lodge a complaint per our Complaints Process below.
PRIVACY COMPLAINTS PROCESS
Privacy Policy
This process is to be read in conjunction with the Community Tradelink. Privacy Policy as above and words and phrases in this Process have the meanings attributed to them in the Privacy Policy.
Purpose
This policy sets out our approach to resolving complaints from individuals about the way we have dealt with their personal information and outlines what people can expect when they make a complaint.
Management of Privacy Complaints
Privacy complaints are managed by the Privacy Officer. The Privacy Officer will:
· Receive and acknowledge the complaint
· Seek further information from the complainant if necessary
· Thoroughly investigate the complaint
· Respond to the complainant with the outcome of the investigation
· Provide feedback to the relevant internal stakeholders.
PRIVACY COMPLAINTS PROCESS
1. Complaint Receipt
We ask that complaints be made in writing. The Privacy Officer may receive an oral complaint if he considers that making a written complaint would be impracticable or unreasonably onerous for the complainant. In written complaints, complainants should:
· Include sufficient contact details to enable us to identify them
· Clearly and succinctly state the nature of their complaints
· Include sufficient information for the Privacy Officer to understand the complaints
· Provide details such as what happened, when they became aware of it, and who was involved
· State which Privacy Principle they believe has been breached (if known)
· Outline the impact the event has had on them
· Include details of what they would like to see happen to resolve the complaints.
· Complaints can be emailed to [email protected] or posted to: Level 6, 10 Herb Elliott Avenue, Sydney Olympic Park, NSW 2127
· If a complaint is received from someone other than the individual involved, we will only proceed if we have evidence that the person submitting the complaint has authority to do so.
2. Complaint Acknowledgement
The Privacy Officer will acknowledge the complaint within five working days of receiving it.
3. Complaint Investigation
The Privacy Officer will investigate the concerns raised by the complainant. This may involve obtaining further information from the complainant, speaking with the relevant staff members, reviewing relevant documents or client files, and obtaining technical or legal advice. It is anticipated that in most cases, the duration of the investigation will not exceed 20 working days. If the investigation is likely to take longer than 20 days, the Privacy Officer will notify the complainant.
4. Complaint Outcome
The Privacy Officer will inform the complainant in writing as to the outcome of the investigation.
If the complainant remains dissatisfied with the response provided, he or she may wish to contact the Office of the Information Commissioner (The Privacy Commissioner). For more details, see http://www.oaic.gov.au/ or the Privacy Commissioner in your region.
5. Internal Feedback
Where appropriate, the Privacy Officer will provide feedback, including recommendations of process improvements, to the relevant internal stakeholders to ensure continued compliance with the applicable Privacy Principles.
