Privacy

Privacy Policy of www.strawberryjames.com

This Application/Website collects some Personal Data from its Users.

Policy summary

Personal Data collected for the following purposes and using the following services:

  • Advertising
    • Google Marketing
      Personal Data: Cookies; Usage Data
  • Analytics
    • Google Analytics, Hotjar Form Analysis & Conversion Funnels, Google Ads conversion tracking, Facebook Ads conversion tracking (Facebook pixel), Display Advertising extension for Google Analytics and HubSpot Analytics
      Personal Data: Cookies; Usage Data
  • Contacting the User
    • Contact form
      Personal Data: address; city; company name; country; email address; first name; last name; phone number; state; ZIP/Postal code
    • Mailing list or newsletter
      Personal Data: address; city; company name; country; email address; first name; last name; phone number; profession; state; Usage Data; ZIP/Postal code
  • Managing contacts and sending messages
    • MailChimp Email Marketing
      Personal Data: email address; Usage Data
    • Campaign Monitor
      Personal Data: email address
  • Remarketing and behavioural targeting
    • Facebook Remarketing, Remarketing with Google Analytics and Google Ads Remarketing
      Personal Data: Cookies; Usage Data
    • Facebook Custom Audience
      Personal Data: Cookies; email address
  • Tag Management
    • Google Tag Manager
      Personal Data: Usage Data

Further information about Personal Data

Strawberry James Removals Privacy Policy
Strawberry James Removals, (us, our, we) is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) (collectively referred to as the Privacy Act). SJR adopts the APPs as Standards Privacy Principals across all SJR entities.

The purpose of this Policy is to provide you with information in relation to how we collect, treat and manage your Personal Information (as defined in s6 of the Privacy Act 1988 (Cth)). It also describes how customers may access and amend Personnel Information held by us on your behalf.

This includes:

·        the kinds of Personal Information that we collect and hold about you;

·        how we collect and hold your Personal Information;

·        the purposes for collecting, holding, using and disclosing your Personal Information;
how you may access your Personal Information held by us and correct that information where it is incorrect;

·        how you may make a complaint about the way we collect, hold, use or disclose Personal Information, and how we will deal with Privacy related complaints; and

·        whether we will (or are likely to) disclose your personal information to overseas recipients and the countries where such recipients may be located.

You can choose to interact with us anonymously or by using a pseudonym if such interaction is general in nature. However, if the interaction is specific to an account or relates to your Personal Information, we will need to identify you before we can engage in further discussions and correspondence.
We will keep this Privacy Policy up to date and published on our website.

1. How we collect your Personal Information
We will only collect Personal Information from you for business purposes only. which include providing Home, Corporate and Commercial Services (Primary Purpose). Such Personal Information collected includes contents and locations of items stored with us.

We also collect and hold Personal Information for secondary purposes. These include

·        customers’ names and addresses for contact and billing;

·        information relating to previous services provided by SJR;

·        details of persons authorised to access information; and

·        employment or financial information.

(Collectively referred to as Secondary Purposes).

The information obtained for Secondary Purposes will not be used or disclosed otherwise than in accordance with Part 2 of this Privacy Policy.

We require you to notify individuals prior to disclosing Personal Information that you will:

·        Disclose their Personal Information to us, and

·        Describe the services we will provide.

We will keep your records in secured premises. Your records, including any Personal Information contained in them, will not be passed on to a third party without your consent unless specified by law.

In consideration of us providing our services you warrant that:

·        You have obtained the consent from relevant individuals to provide their Personal Information to us;

·        You are not aware that the collection of the Personal Information by us will infringe the rights of any third party;

·        You have consent from relevant individuals for us to provide our services in respect of their Personal Information.

We will notify you concerning matters listed below before collecting any Personal Information:

·        the Primary Purpose for collecting your Personal Information;

·        other related uses or disclosures that we may make of the Personal Information (Secondary Purposes);

·        the main consequence s (if any) for you if you do not provide all or some of the Personal Information;

·        our identity and how you can contact us and access or seek correction of the Personal Information that we hold about you;

·        how you may make a complaint about any alleged breach of the Privacy Act by us;

·        whether we are likely to disclose the Personal Information to overseas recipients and if so, the countries where such recipients are likely to be located; and

·        the organisations or types of organisations to whom we usually disclose the Personal Information including contractors.

Some elements of Personal Information are also referred to as Sensitive Information (as defined in s6 of the Privacy Act 1988 (Cth)).

We will only collect Sensitive Information:

·        with your consent; or

·        when permissible under Australian law, and will only use such information for a legitimate purpose where this is reasonably necessary.

2. How we use and disclose your Personal Information
We may use personal information for its primary purpose of collection (e.g. the delivery of services to the person) or for any related secondary purpose that we could reasonably be expected to use the personal information for.

We will not use or disclose Personal Information about an individual other than for providing the services agreed upon unless required to do so by law. For example, we may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

We will not copy or exploit any Personal Information provided to us. In certain circumstances, we may use personal information for promotional or direct marketing purposes. However, a person may at any time request we not to use their personal information for sending direct marketing material to that person. Such a request can be made by contacting SJR either in writing, by email or by telephone at the contact details below. There is no fee for making such a request.

We will take reasonable steps to ensure that our contractors also comply with the requirements of the Privacy Act however, we accept no responsibility for the actions of our contractors and will not be liable for any claims arising as a result of a breach of the Privacy Act by our contractors.

We may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

We may disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
In order for us to provide a high level of service to you, from time to time, we may share Personal Information with our related bodies corporates, as defined in the Corporations Act 2001 (Cth).

3. How we protect your Personal Information
We will take such steps as are reasonable in the circumstances to protect all collected Personal Information from misuse, interference and loss. This includes, but is not limited to the following:
1. Ensuring that all of our employees and contractors perform their duties in a manner that is consistent with our legal responsibilities under the Privacy Act.
2. Ensuring that paper and electronic records containing Personal Information are stored in facilities that are only accessible by authorised employees, agents and contractors.

Information Security
We use a variety of security technologies and procedures, including Secure Socket Layer (SSL) encryption, to help protect your personal information from unauthorized access, use, or disclosure. For more information of how SJR protects information, refer to SJR Information Security Policies & Procedures.

Storage and Data Security
Storage of personal information (and the disposal of information when no longer required) is managed in accordance with the Australian Government’s records management regime. We will take steps to destroy or de-identify Personal Information after as short a time as possible after being notified by you that the information should be destroyed, unless the law requires otherwise.

We take all reasonable steps to protect the personal information held in our possession against loss, unauthorised access, use, modification, disclosure or misuse.

4. Access to, and Correction of your Personal Information
We will take all reasonable steps to ensure that the Personal Information that we collect and hold is accurate, up to date and complete.

We will:

a)      grant you access to; and/or

b)     correct, our records containing Personal Information about you as soon as practically possible at your request in accordance with the Privacy Act.


Should you wish to lodge a request to access and/or correct your Personal Information, you should do so by contacting our Privacy Officer (details of our Privacy Officer are set out in clause 8).

We reserve the right to charge you for the reasonable cost incurred by us in providing access to your Personal Information in accordance with this Privacy Policy. For the avoidance of doubt, such charges will not apply to the making of any such request for access to your Personal Information by you.

If there is a reason we are unable to agree to a request for access to your Personal Information, we will advise you of this in writing. Some examples of why we may refuse a request for access include, where providing the information:

a)      may pose a threat to the health or safety of an individual or the public;

b)     may have an unreasonable impact on the privacy of another individual;

c)      is not allowed by law; or

d)     may reveal internal information relating to a commercially sensitive decision making process.

5. Complaints
If you wish to voice a complaint about:

a)      an alleged breach of the APPs by us; and/or

b)     an alleged breach of a registered APP code by us,
then you should contact our Privacy Officer (details of our Privacy Officer are set out in clause 8).

·        Once a complaint is officially lodged with our Privacy Officer, it will be dealt with confidentially in accordance with our Complaints Handling Policy.

6. Transferring Personal Information Overseas
If Personal Information is sent overseas, we will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the Australian Privacy Principles and the Privacy Act.

7. Privacy Officer and Contact Procedure
Our Privacy Officer is Reece Young. The contact information for our Privacy Officer is as follows:

a. Phone – 1800 914 411
b. Email –[email protected]
c. Hours – 8.30am – 5.30pm.

You should contact the Privacy Officer with respect to all requests relating to access, complaints or correction of your Personal Information under this Policy.

The Privacy officer will take your enquiry and provide you with a response within a reasonable time period.

Contact information

    • Owner and Data Controller
      Strawberry James Removals – PO Box 431, Waverley, NSW, 2024
      Owner contact email: [email protected]

Full policy

Owner and Data Controller

Strawberry James Removals – PO Box 431, Waverley, NSW, 2024

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that this Application/Website collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; phone number; company name; address; country; state; email address; ZIP/Postal code; city; profession.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application/Website.

Unless specified otherwise, all Data requested by this Application/Website is mandatory and failure to provide this Data may make it impossible for this Application/Website to provide its services. In cases where this Application/Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application/Website or by the owners of third-party services used by this Application/Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application/Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application/Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Tag Management, Contacting the User, Managing contacts and sending messages, Advertising and Remarketing and behavioral targeting.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Advertising
    This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application/Website, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application/Website. For more information, please check the privacy policies of the relevant services.
    Microsoft Advertising (Microsoft Corporation)
    Microsoft Advertising is an advertising service provided by Microsoft Corporation.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy – Opt Out. Privacy Shield participant.
  • Analytics
    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
    Google Analytics (Google Inc.)
    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application/Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy – Opt Out.
    Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
    Hotjar is an analytics service provided by Hotjar Ltd.
    Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: Malta – Privacy Policy – Opt Out.
    Google Ads conversion tracking (Google Inc.)
    Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this Application/Website is accessed from, that connects data from the Google Ads advertising network with actions performed on this Application/Website.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy. Privacy Shield participant.
    Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
    Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application/Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy. Privacy Shield participant.
    Display Advertising extension for Google Analytics (Google Inc.)
    Google Analytics on this Application/Website might use Google’s Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy – Opt Out.
    HubSpot Analytics (HubSpot, Inc.)
    HubSpot Analytics is an analytics service provided by HubSpot, Inc.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out .
  • Contacting the User
    Contact form (This Application/Website)
    By filling in the contact form with their Data, the User authorizes this Application/Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
    Personal Data collected: address; city; company name; country; email address; first name; last name; phone number; state; ZIP/Postal code.
    Mailing list or newsletter (This Application/Website)
    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application/Website. Your email address might also be added to this list as a result of signing up to this Application/Website or after making a purchase.
    Personal Data collected: address; city; company name; country; email address; first name; last name; phone number; profession; state; Usage Data; ZIP/Postal code.
  • Managing contacts and sending messages
    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
    MailChimp Email Marketing (MailChimp, Inc.)
    MailChimp Email Marketing is an email address management and message sending service provided by MailChimp, Inc.
    Personal Data collected: email address; Usage Data.
    Place of processing: US – Privacy Policy.
    Campaign Monitor (Campaign Monitor)
    Campaign Monitor is an email address management and message sending service provided by Campaign Monitor Pty Ltd.
    Personal Data collected: email address.
    Place of processing: US – Privacy Policy.
  • Remarketing and behavioral targeting
    This type of service allows this Application/Website and its partners to inform, optimize and serve advertising based on past use of this Application/Website by the User.
    This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
    In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
    Facebook Remarketing (Facebook, Inc.)
    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application/Website with the Facebook advertising network.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy – Opt Out.
    Facebook Custom Audience (Facebook, Inc.)
    Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application/Website with the Facebook advertising network.
    Personal Data collected: Cookies; email address.
    Place of processing: US – Privacy Policy – Opt Out.
    Remarketing with Google Analytics (Google Inc.)
    Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application/Website is accessed from, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy – Opt Out. Privacy Shield participant.
    Google Ads Remarketing (Google Inc.)
    Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application/Website is accessed from, that connects the activity of this Application/Website with the Google Ads advertising network and the DoubleClick Cookie.Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: US – Privacy Policy – Opt Out. Privacy Shield participant.
  • Tag Management
    This type of service helps the Owner to manage the tags or scripts needed on this Application/Website in a centralized fashion.
    This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
    Google Tag Manager (Google Inc.)
    Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location this Application/Website is accessed from.
    Personal Data collected: Usage Data.
    Place of processing: US – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

  • Strawberry James Removals Privacy Policy
    Strawberry James Removals, (us, our, we) is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) (collectively referred to as the Privacy Act). SJR adopts the APPs as Standards Privacy Principals across all SJR entities.

    The purpose of this Policy is to provide you with information in relation to how we collect, treat and manage your Personal Information (as defined in s6 of the Privacy Act 1988 (Cth)). It also describes how customers may access and amend Personnel Information held by us on your behalf.

    This includes:

    • the kinds of Personal Information that we collect and hold about you;
    • how we collect and hold your Personal Information;
    • the purposes for collecting, holding, using and disclosing your Personal Information;
    • how you may access your Personal Information held by us and correct that information where it is incorrect;
    • how you may make a complaint about the way we collect, hold, use or disclose Personal Information, and how we will deal with Privacy related complaints; and
    • whether we will (or are likely to) disclose your personal information to overseas recipients and the countries where such recipients may be located.

    You can choose to interact with us anonymously or by using a pseudonym if such interaction is general in nature. However, if the interaction is specific to an account or relates to your Personal Information, we will need to identify you before we can engage in further discussions and correspondence.
    We will keep this Privacy Policy up to date and published on our website.

    1. How we collect your Personal Information

    We will only collect Personal Information from you for business purposes only. which include providing Home, Corporate and Commercial Services (Primary Purpose). Such Personal Information collected includes contents and locations of items stored with us.

    We also collect and hold Personal Information for secondary purposes. These include
    • customers’ names and addresses for contact and billing;
    • information relating to previous services provided by SJR;
    • details of persons authorised to access information; and
    • employment or financial information.

    (Collectively referred to as Secondary Purposes).

    The information obtained for Secondary Purposes will not be used or disclosed otherwise than in accordance with Part 2 of this Privacy Policy.

    We require you to notify individuals prior to disclosing Personal Information that you will:
    • Disclose their Personal Information to us, and
    • Describe the services we will provide.

    We will keep your records in secured premises. Your records, including any Personal Information contained in them, will not be passed on to a third party without your consent unless specified by law.

    In consideration of us providing our services you warrant that:
    • You have obtained the consent from relevant individuals to provide their Personal Information to us;
    • You are not aware that the collection of the Personal Information by us will infringe the rights of any third party;
    • You have consent from relevant individuals for us to provide our services in respect of their Personal Information.

    We will notify you concerning matters listed below before collecting any Personal Information:
    • the Primary Purpose for collecting your Personal Information;
    • other related uses or disclosures that we may make of the Personal Information (Secondary Purposes);
    • the main consequence s (if any) for you if you do not provide all or some of the Personal Information;
    • our identity and how you can contact us and access or seek correction of the Personal Information that we hold about you;
    • how you may make a complaint about any alleged breach of the Privacy Act by us;
    • whether we are likely to disclose the Personal Information to overseas recipients and if so, the countries where such recipients are likely to be located; and
    • the organisations or types of organisations to whom we usually disclose the Personal Information including contractors.

    Some elements of Personal Information are also referred to as Sensitive Information (as defined in s6 of the Privacy Act 1988 (Cth)).

    We will only collect Sensitive Information:
    • with your consent; or
    • when permissible under Australian law, and will only use such information for a legitimate purpose where this is reasonably necessary.

    2. How we use and disclose your Personal Information

    We may use personal information for its primary purpose of collection (e.g. the delivery of services to the person) or for any related secondary purpose that we could reasonably be expected to use the personal information for.

    We will not use or disclose Personal Information about an individual other than for providing the services agreed upon unless required to do so by law. For example, we may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

    We will not copy or exploit any Personal Information provided to us. In certain circumstances, we may use personal information for promotional or direct marketing purposes. However, a person may at any time request we not to use their personal information for sending direct marketing material to that person. Such a request can be made by contacting SJR either in writing, by email or by telephone at the contact details below. There is no fee for making such a request.

    We will take reasonable steps to ensure that our contractors also comply with the requirements of the Privacy Act however, we accept no responsibility for the actions of our contractors and will not be liable for any claims arising as a result of a breach of the Privacy Act by our contractors.

    We may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

    We may disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
    In order for us to provide a high level of service to you, from time to time, we may share Personal Information with our related bodies corporates, as defined in the Corporations Act 2001 (Cth).

    3. How we protect your Personal Information

    We will take such steps as are reasonable in the circumstances to protect all collected Personal Information from misuse, interference and loss. This includes, but is not limited to the following:
    1. Ensuring that all of our employees and contractors perform their duties in a manner that is consistent with our legal responsibilities under the Privacy Act.
    2. Ensuring that paper and electronic records containing Personal Information are stored in facilities that are only accessible by authorised employees, agents and contractors.

    Information Security

    We use a variety of security technologies and procedures, including Secure Socket Layer (SSL) encryption, to help protect your personal information from unauthorized access, use, or disclosure. For more information of how SJR protects information, refer to SJR Information Security Policies & Procedures.

    Storage and Data Security
    Storage of personal information (and the disposal of information when no longer required) is managed in accordance with the Australian Government’s records management regime. We will take steps to destroy or de-identify Personal Information after as short a time as possible after being notified by you that the information should be destroyed, unless the law requires otherwise.

    We take all reasonable steps to protect the personal information held in our possession against loss, unauthorised access, use, modification, disclosure or misuse.

    4. Access to, and Correction of your Personal Information
    We will take all reasonable steps to ensure that the Personal Information that we collect and hold is accurate, up to date and complete.

    We will:
    a. grant you access to; and/or
    b. correct, our records containing Personal Information about you as soon as practically possible at your request in accordance with the Privacy Act.

    Should you wish to lodge a request to access and/or correct your Personal Information, you should do so by contacting our Privacy Officer (details of our Privacy Officer are set out in clause 8).

    We reserve the right to charge you for the reasonable cost incurred by us in providing access to your Personal Information in accordance with this Privacy Policy. For the avoidance of doubt, such charges will not apply to the making of any such request for access to your Personal Information by you.

    If there is a reason we are unable to agree to a request for access to your Personal Information, we will advise you of this in writing. Some examples of why we may refuse a request for access include, where providing the information:
    a. may pose a threat to the health or safety of an individual or the public;
    b. may have an unreasonable impact on the privacy of another individual;
    c. is not allowed by law; or
    d. may reveal internal information relating to a commercially sensitive decision making process.

    5. Complaints
    If you wish to voice a complaint about:
    a. an alleged breach of the APPs by us; and/or
    b. an alleged breach of a registered APP code by us,
    then you should contact our Privacy Officer (details of our Privacy Officer are set out in clause 8).

    Once a complaint is officially lodged with our Privacy Officer, it will be dealt with confidentially in accordance with our Complaints Handling Policy.

    6. Transferring Personal Information Overseas
    If Personal Information is sent overseas, we will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the Australian Privacy Principles and the Privacy Act.

    7. Privacy Officer and Contact Procedure
    Our Privacy Officer is Reece Young. The contact information for our Privacy Officer is as follows:
    a. Phone – 1800 914 411
    b. Email –[email protected]
    c. Hours – 8.30am – 5.30pm.

    You should contact the Privacy Officer with respect to all requests relating to access, complaints or correction of your Personal Information under this Policy.

    The Privacy officer will take your enquiry and provide you with a response within a reasonable time period.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

 

Additional information about Data collection and processing

 

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application/Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

 

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application/Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

 

System logs and maintenance

For operation and maintenance purposes, this Application/Website and any third-party services may collect files that record interaction with this Application/Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

 

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

 

How “Do Not Track” requests are handled

This Application/Website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

 

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application/Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

 

 

Definitions and legal references

 

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

 

Usage Data

Information collected automatically through this Application/Website (or third-party services employed in this Application/Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application/Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application/Website) and the details about the path followed within the Application/Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

 

User

The individual using this Application/Website who, unless otherwise specified, coincides with the Data Subject.

 

Data Subject

The natural person to whom the Personal Data refers.

 

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

 

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application/Website. The Data Controller, unless otherwise specified, is the Owner of this Application/Website.

 

This Application/Website

The means by which the Personal Data of the User is collected and processed.

 

Service

The service provided by this Application/Website as described in the relative terms (if available) and on this site/application.

 

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

 

Cookies

Small piece of data stored in the User’s device.

 

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application/Website, if not stated otherwise within this document.

Latest update: November 23, 2020