Reidy Investments Pty Ltd ACN 050 989 216 trading as Desert Palms Alice Springs ABN 72 050 989 216 (we, us or our) takes the issue of the privacy of your Personal Data seriously and we aim to provide you with the best possible products and services. We also want you to have confidence that we afford Personal Data an appropriate level of privacy, consistent with the national privacy principles set out in the Privacy Act 1988 (Cth) (Privacy Act), the Spam Act 2003 (Cth) (Spam Act) and the EU General Data Protection Regulation (GDPR). The Privacy Act, Spam Act and GDPR are jointly referred to as privacy legislation (Privacy Legislation).
IF YOU USE ANY GOOD AND/OR SERVICE PROVIDED BY US AND IN THE COURSE OF DOING SO YOU VOLUNTARILY PROVIDE ANY PERSONAL DATA TO US THEN YOU SPECIFICALLY REPRESENT TO US THAT YOU HAVE READ, UNDERSTOOD AND CONSENTED TO THE COLLECTION, USE AND STORAGE OF YOUR PERSONAL DATA.
What is Personal Data?
Personal Data is any information relating to an identified or identifiable natural person (Data Subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It also includes date of birth, address, contact number and email address.
Why do we collect and process Personal Data?
We collect and process Personal Data for a range of purposes including:
- responding to queries that you may have about the products and services that we offer;
- confirming that you have provided necessary identification for the purpose of providing our products and/or services;
- supplying products and services and enter into contract/s with the Data Subject or at the request of the Data Subject;
- facilitating payment for products and services;
- arranging for products and services to be supplied to customers by third parties (including our sub-contractors) where appropriate;
- protecting the legitimate interests pursued by us or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject); and
- conducting competitions.
Use of your Personal Data
- providing you with the best possible products and services;
- maintaining records for accounting and administration purposes;
- providing customer support;
- responding to complaints;
- analysing customer needs and develop customer strategies;
- meeting legal and regulatory requirements:
- of regulatory authorities (eg the Australian Tax Office) or law;where authorised by law (eg to protect our interests or
- where we have a duty to make such disclosure); or
- forwarding information about you to third parties such as:
- insurance providers (where you have requested that they supply products and services to you);
- government and regulatory authorities (for example for compliance with financial transactions reporting or anti-money laundering legislation), police, local council authorities;
- our insurers if you are involved in any infringement to person or property;
- financial institutions for payment processing, referees, referrals or guarantors whose details you have provided to us;
- our independent contractors (Independent Contractors), including, without limitation:
- website designers and information technology service providers;
- marketing and communications agencies;
- call centres and call training centres;
- mailing houses, freight and courier services;
- printers and distributors of direct marketing material; and
- external business advisors (such as auditors, accountants, financial advisors, lawyers and debt collectors).
We may disclose Personal Data to the Independent Contractor and the Independent Contractor may in turn provide us with Personal Data collected from you in the course of providing the relevant products or services. We take steps to help ensure that our Independent Contractor comply with the Privacy Legislation when they collect and handle your Personal Data.
We reserve our right to use or disclose Personal Data or information to try to locate an individual if we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website.
What sort of Personal Data do we collect?
- basic user information, such as your name, username, gender, birth date, email address, mailing address, billing address, phone number and other identification details (for example, your drivers’ licence or passport number);
- messages and interactive post information from our online services;
- other background, contact and demographic information, such other interests and self- descriptions you choose to provide; and
- debit and credit card information which may be processed by a third party engaged by us to validate such credit and debit card information. We do not store such information as that information is passed through to our debit and credit card validator.
Other information which may form part of Personal Data
Other information we may collect about you includes information gathered automatically whilst using our online services, such as our webpage and/or app (if available) and includes:
- how you interact with our services and how and with whom you communicate with through our services;
- content information that you contribute;
- access, with your permission, to your device phonebook and GPS location data; and
- via usage (possibly without prompted permissions) access to your camera and photos, your device information and specifications and log
Additional internal information
This additional information is predominantly used by us in an anonymous, aggregated form for any other purpose allowable by law including statistical and web site development purposes.
How do we collect Personal Data?
Much of the Personal Data that we hold is collected when you seek products and/or services from us or related services through us. We may also collect Personal Data in a number of other ways, for example:
- if you contact us with a query (whether in person, or by phone, fax, email, through the forms on our website or through social media (for example, Facebook and Twitter));
- if you access our website or app and/or create an online user;
- if you enter a competition conducted by us;
- if you respond to one of our direct marketing campaigns;
- if you respond to a customer satisfaction survey and the survey results are provided to us;
- if we collect information from prior providers of products and/or services to facilitate the provision of services to you; or
- if we have arranged for third parties to supply you with products and/or services and those third parties provide us with information about the products or services that you have purchased from them (please note that we do not collect your credit or financial details from finance or insurance suppliers).
Cookies, web beacons and tracking technologies
A cookie is a small data file that is sent to your web browser by a website you visit. Cookies are stored in your web browser and allows our website or a third party to recognise you and make your next visit to our website easier.
Third party collection of information
Sometimes, we may collect your Personal Data about you from third parties, for example where:
- you respond to a customer satisfaction survey and the survey results are provided to us;
- we collect information from prior providers of products and/or services to facilitate the provision of services to you;
- you log on to our website or create a user; or
- we have arranged for third parties to supply you with products and services and those third parties provide us with information about the products or services that you have purchased from them (please note that we do not collect your credit or financial details from finance or insurance suppliers).
Customer satisfaction surveys and emails
From time to time, we survey our customers on a range of issues, including customer satisfaction and the quality of our service. These surveys help us to improve our services and tailor the way that we do business with you. If you do not wish to receive these surveys please unsubscribe at any time using the unsubscribe link contained in the email or email us with your request.
We have a legitimate interest in adding you to our email database/emailing you to provide you with information about our relationship, contract specific information, product specific information, reminders, information e-newsletters and e-mail marketing including relating to businesses that we are associated with. Our legitimate interest is to keep you informed in relation to the products and/or services you may have purchased or may purchase in the future. You have the ability to unsubscribe at any time using the unsubscribe link in the email or email us with your request.
Email is not a secure method of communication. If you are concerned about sending your Personal Data to us by email we suggest that you consider contacting us in person, by writing or by telephone.
Accessing Personal Data and ensuring it is up to date
If you request us to provide you with access to your Personal Data that we hold, then we will provide such information to you in a timely manner in accordance with GDPR requirements. Please submit your request to the email address noted below.
Accurate Personal Data is important to conducting our business and providing you with the agreed services. Please ensure that you advise us promptly if:
- there has been any change to your Personal Data or information that we hold; and/or
- you become aware that we possess your Personal Data or information that is not correct, accurate, up to date or complete,
so that we may take all reasonable steps to correct the information about you and ensure that the Personal Data and information we hold is accurate complete and up to date. Personal Data and information will be updated as soon as practical following verification of the new information.
Security of Personal Data
The security of information is important to us and we take all reasonable precautions to protect the Personal Data that we hold from misuse, loss, unauthorised access, modification or disclosure.
Some of the ways that we secure Personal Data include:
- external and internal physical premises security;
- maintaining technology products to prevent unauthorised computer access, including identifiers, passwords and/or encryption of personal information;
- restricted access to Personal Data to staff who need it to perform their day to day functions;
- conducting training to ensure that staff are aware that they must only access, use and disclose Personal Data for appropriate purposes;
- requiring staff who have access to Personal Data to agree to protect the privacy of that information; and
- maintaining physical security over paper
Despite our reasonable precautions, we do not guarantee or warrant the security of the information you share with us and we will not be responsible against destruction, theft, loss or inadvertent disclosure of Personal Data or information.
Period of storage of Personal Data
We will take reasonable steps to destroy or permanently de-identify Personal Data that is no longer needed for any purpose that is permitted by the Privacy Legislation within a reasonable time.
Use of Commonwealth government identifiers
We will not use Commonwealth government identifiers (Identifiers) (for example, Medicare numbers) as our own identifier of individuals. We will only use or disclose Identifiers in the circumstances permitted by the Privacy Legislation.
Transfer of Personal Data overseas
If we transfer your Personal Data outside Australia, we will comply with requirements of the Privacy Legislation that relate to transborder data flows. Please note that some of the servers on which our customer information is held may be located overseas. As a result, Personal Data collected and held by us may be transferred overseas to be held on these servers.
Access to your Personal Data
If you require access to your Personal Data that we hold about you, then please send a request to us at the email address noted below. We will respond to your request within a reasonable time in accordance with the GDPR requirements.
Access to your Personal Data may be refused in a number of circumstances, including where you have already been provided with the information, the information relates to anticipated legal proceedings, or the request for access is frivolous or vexatious.
If we deny or restrict your access to Personal Data, we will explain why. Similarly, in some limited circumstances we may not make requested corrections to Personal Data, in which case we will provide you with reasons for this decision.
Removing your consent and the right to be forgotten
If you are a resident of a jurisdiction that is a member of the European Union and the GDPR applies to your Personal Data, then:
- you may email us and advise us that your consent for us to allocate, store and/or use your Personal Data is withdrawn; and
we will subject to the requirements of the GDPR and subject to any binding laws upon us to the contrary and subject to validating your request use all reasonable efforts to remove any Personal Data about you within a
- reasonable time commencing on the date that you advise us by email that your consent concerning the collection, storage and usage of your Personal Data is withdrawn.
Nothing in this clause requires us to breach any law in Australia that requires us to keep your Personal Data including taxation laws.
Job applicants and employees
Any Personal Data provided to us in connection with job applications may be used to consider the applicant for current and future employment and may be disclosed to our third party advisors to assist us in the selection and recruitment process.
If your application for employment is successful, we will rely on the exemption in the Privacy Legislation relating to employee records where applicable.
Information that is not Personal Data
If you have any concerns about the way your Personal Data is managed by us, or believe that a breach of your privacy has occurred, please let us know by contacting us. We will respond to your concerns as soon as possible.
Contact details and additional information
Address: 74 Barrett Drive, Alice Springs, Northern Territory 0870 Australia Phone: 08 8952 5977
Fax: (08) 8953 4176
Email: desertpalms(at)desertpalms.com.au Website: www.desertpalms.com.au