Spectur Limited ACN 140 151 579
1. SCOPE OF THIS POLICY
2. OUR BUSINESS AND ACTIVITIES 2.1 At the date of this policy, our business involves developing, manufacturing and commercialising remote high-definition remote security systems which operate using solar power and transmit images using the 3G and 4G mobile telephone network, and provision of associated services.
2.2 We will only collect and maintain a record of personal information if it is reasonably necessary to pursue at least one of our functions and activities in the course of operating our business.
2.3 Our functions and activities include, but are not limited to:
(a) operating and managing our business as outlined above, including:
(i) the sale or hiring of security cameras and related equipment; and
(ii) the provision of security monitoring and related services;
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
3.2 In the course of carrying out recruitment activities in respect of employees and contractors, we may collect a wide range of information, including information regarding an applicant’s educational qualifications, career history, interests, hobbies and job interests and such other information as may be routinely included within a curriculum vitae.
3.3 From time to time, we collect sensitive information about individuals in order to provide our services. However, we generally only collect sensitive information if:
3.4 The APPs list a number of circumstances that permit the collection of sensitive information about an individual without their consent. We only collect sensitive information without an individual’s consent if one or more of those circumstances applies.
4. HOW DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
4.1 We will only collect personal information by lawful and fair means and not in an unreasonably intrusive way.
4.2 We may collect this personal information either from you or from third parties. We may collect this information when you:
4.3 In order to provide our services we may collect personal information from third parties, including government agencies and your family and friends.
4.4 We will only collect personal information from third parties if:
(a) we are required or authorised by or under an Australian law, or a court/tribunal order, to collect the information from someone other than the individual concerned;
(b) it is unreasonable or impracticable to collect the information directly from the individual concerned; or
(c) it is provided to us in the course of us providing at least one of our functions and activities.
5. WHY DO WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION?
5.1 We will only collect and hold personal information if it is reasonably necessary to pursue at least one of our functions or activities or its collection and storage is required or authorised by or under an Australian law or a court/tribunal order.
5.2 When information is sensitive information we will only collect and store information with the consent of the individual concerned and when the information is reasonably necessary for us to carry out at least one of our functions or activities.
5.3 Alternatively, we may collect sensitive information when the APPs otherwise permit such collection.
5.4 We may collect, hold, use and disclose your personal information for the following purposes (primary purpose)
5.5 Generally, we will only use or disclose personal information for the purpose for which it was collected (the primary purpose), including the purposes set out above.
5.6 However, we may use or disclose personal information for secondary purposes if we receive your consent to do so, or without your consent, if you would reasonably expect us to use your information for the secondary purpose, or otherwise when the APPs permit us to do so.
5.7 For example, the APPs permit us to use and disclose personal information for a secondary purpose without an individual’s consent if the individual would reasonably expect us to use or disclose the information for a certain secondary purpose and the secondary purpose is:
(a) if the information is sensitive – directly related to the primary purpose; or
(b) if the information is not sensitive – related to the primary purpose; or
(c) the use or disclosure of the information is permitted or authorised by or under an Australian law or a court/tribunal order (for example where disclosure of your information will reduce or prevent a serious threat to life, health or safety or where our disclosure is in response to any unlawful activity).
6. NOTIFICATION OF COLLECTION
6.1 At or before the time we collect personal information about an individual (or, if that is not practicable, as soon as practicable after), we will take such steps as are reasonable in the circumstances to notify the individual of the following information (Collection Information):
6.2 Circumstances may arise where it would be reasonable for us not to provide the individual about whom the information relates with notice of all or some of the Collection Information.
7. DO WE USE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
7.1 We may, from time to time, use or disclose personal information for the purpose of direct marketing.
7.2 We may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
7.3 We may use or disclose personal information (other than sensitive information) for direct marketing if:
7.4 In this regard, you may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).
7.5 If personal information is also sensitive information, we will not use or disclose the information for direct marketing without the consent of the individual concerned.
8. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
9. RECEIPT OF UNSOLICITED PERSONAL INFORMATION
9.1 If we receive personal information that we did not solicit, we will, within a reasonable period of receiving the information, determine whether we would have been permitted to collect the information pursuant to the APPs.
9.2 If we determine that we have received personal information that we would not have been permitted to collect pursuant to the APPs (and the information is not contained in a Commonwealth record), we will as soon as practicable and where it is lawful and reasonable to do so, destroy the information or ensure that it is de-identified.
9.3 If we determine that we would have been permitted to collect the personal information pursuant to the APPs, we will ensure that the information is dealt with in a manner that complies with the APPs.
10. DISCLOSURE TO OVERSEAS RECIPIENTS
10.1 From time to time, circumstances may arise where there may be a need for us to disclose personal information to an overseas recipient. This may occur in a range of circumstances. For example, where data is being stored and accessed by way of cloud computing or where we correspond with professional advisors located outside of Australia.
10.2 Before disclosing personal information to an overseas recipient, we will take such steps as are reasonable in the circumstances to ensure that the overseas recipient also complies with the APPs in relation to that information, unless the APPs do not require us to do so.
10.3 We will not be required to take the steps described in paragraph 9.2 above if:
11. OUR WEBSITE AND COOKIES
11.1 We may collect personal information about you when you use and access our website.
11.2 While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
11.3 We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other devices. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
11.5 Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ from this Policy, so we encourage you to read them before using those websites.
12.1 We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a
number of physical, administrative, personnel and technical measures to protect your personal information.
The Company’s security measures include:
12.2 If we hold personal information about an individual which we no longer require, we will take reasonable steps to destroy the information or ensure that it is de-identified (unless our compliance with the APPs or a law requires us to avoid taking such steps).
13. ANONYMITY AND PSEUDONYMITY
13.1 When interacting with us, individuals may choose to remain anonymous or to use a pseudonym. However, we may elect not to deal with the individual anonymously or pseudonymously if:
13.2 In some circumstances, it may not be possible for us to properly provide a service without the knowledge of an individual’s identity. This will often be the case where we are providing healthcare services.
14. QUALITY OF PERSONAL INFORMATION
14.1 We will endeavour to take reasonable steps to ensure that the personal information that we collect is accurate, up-to-date and complete.
14.2 The reasonable steps described above that we may undertake include:
14.3 If you think that the personal information, we hold about you might be out of date and needs to be corrected, please contact us using the details located at paragraph 19.
15. ACCESSING YOUR PERSONAL INFORMATION
15.1 You can access the personal information we hold about you by contacting us. Requests for access to personal information should be made in writing and addressed to the Company Secretary whose contact details are located in paragraph 19 below.
15.2 Upon request of personal information, we will within a reasonable period of the request being made, give access to the information in the manner requested (if it is reasonable and practicable to do so), subject to exceptions set out in the APPs.
15.3 The APPs provide a list of situations in which we may deny individuals access to their personal information. These situations include where:
15.4 If we refuse to give access to the personal information in accordance with the APPs, or if we refuse to give access in the manner requested, we will take such steps (if any) that are reasonable in the circumstances to give access in a way that meets our needs and the needs of the individual.
15.5 If we refuse to give access to personal information in accordance with the APPs, we will provide a written notice setting out:
15.6 Generally we will not charge fees for giving access to personal information. However, we reserve the right to charge reasonable fees where requests for personal information contain complications or are resource intensive.
16. CORRECTION OF PERSONAL INFORMATION
16.1 Requests for correction of personal information should be made in writing and addressed to the contact person listed under paragraph 19.
16.2 If with regard to the purpose for which it is held, we are satisfied that personal information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, or if the individual about whom the information relates makes a request, we will take reasonable steps to correct the information. However, as a matter of practice, when we receive personal information we will hold the information for a period of time before we consider whether it is inaccurate, out-of-date, incomplete, irrelevant or misleading (unless we are informed otherwise).
16.3 If we correct personal information, we will take reasonable steps to notify any third party to whom we had previously disclosed the information, if the individual about whom the information relates requests as such and it is not unlawful or impracticable for us to do so.
16.4 If we refuse to correct personal information in accordance with the APPs, we will provide a written notice setting out:
16.5 If we refuse to correct personal information in accordance with the APPs, the individual may request that we associate the information with a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. Where such a request is made, we will take reasonable steps to associate the statement so that it is apparent to the users of the personal information.
16.6 We will aim to respond to any request regarding the correction of personal information within 30 days of the request being made.
16.7 We will not charge fees for requests for the correction of personal information or for associating the statement with the personal information.
17. MAKING A COMPLAINT
17.2 Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
17.3 If you think that we have failed to resolve the complaint satisfactorily, a complaint may be made to the Office of the Australian Information Commissioner.
18. CHANGES TO THIS POLICY
19. CONTACT US
Contact: Privacy Officer Spectur Limited
Address in Person: Unit 2/6 Merino Entrance Cockburn Central, Western Australia Australia 6164
PO Box 5168, SOUTH LAKE, WA 6164
Telephone: (08) 9414 9059
20. DEFINITIONS OF KEY TERMS
“collect” Personal information, including sensitive information, will be ‘collected’ if it is included in a record or a generally available publication.
“consent” You can give consent either:
“personal information” Personal information is defined in the Privacy Act. In summary, personal information is information or an opinion about an identifiable person, or a reasonably identifiable person no matter whether:
Some examples of personal information include a person’s name, address and date of birth.
“sensitive information” Sensitive information is a type of personal information. Some examples of sensitive information include information or an opinion about an individual’s:
Authorised by: The Board 13/12/2019