1.1 Rapid Global Pty Ltd ACN 161 913 882 (we, us or our) is subject to the 13 Australian Privacy Principles (the APPs). The APPs apply to the collection and use of Personal Information as set out in the Privacy Act 1988 (Cth) (the Act) (as amended from time to time). For the purpose of this Policy:
1.1.1 Personal Information means information, including financial information, or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is in a material form or not.
1.1.2 Sensitive Information means information or an opinion (that is also Personal Information) about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual practices, criminal record or health information.
1.2 We recognise the importance of protecting your Personal Information. We will take reasonable steps to ensure all Personal Information held by us is secure and all Personal Information collected, used or disclosed by us is accurate, complete and up to date. Our handling of Personal Information is regulated by the Act and the Credit Reporting Privacy Code (as amended from time to time) (the Code).
1.3 This Policy is published on our website and may be updated from time to time at our discretion. By continuing to use our website, or otherwise continuing to deal with us, you accept this Policy as it applies from time to time.
2. TYPES OF PERSONAL INFORMATION
2.1 Depending on the particular circumstances, we may collect and hold a range of different Personal Information about you.
2.2 This may include, but is not limited to:
2.2.1 your name;
2.2.2 date of birth;
2.2.3 contact details (including address, email address and telephone number);
2.2.4 driver’s licence number;
2.2.5 credit history;
2.2.6 information about your computer or device and about your visits to and use of our website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation);
2.2.7 information about you if you are being inducted by, or a contractor or visitor to an entity which uses our services;
2.2.8 payment, transaction and financial information.
2.4 We may hold credit card details and bank account numbers if provided to us directly. However, credit card details are not processed through or retained on our servers if goods or services are purchased via our website (in which case credit card information is processed via the eWay, St George Bank or National Australia Bank credit card processing system).
3. SOURCES OF PERSONAL INFORMATION
3.1 Where possible, we will collect Personal Information directly from you. In some instances, we may collect Personal Information from other sources such as third parties, publicly available sources, press reports or other publications, in which case, we will endeavour to verify such details with the person concerned.
3.2 We acknowledge that there is no obligation for you to provide us with Personal Information except as required by law. However, if you choose not to provide us with certain necessary details, we may not be able to provide you with our full range of services or employment and you may not be able to provide services to the entity you were to be inducted by, were to contract to or were to visit.
3.3 We collect Personal Information in a number of ways, including but not limited to:
3.3.1 directly from you when you order or purchase goods or services from us, set up an account with us, complete an online induction or otherwise use our online products;
3.3.2 when you browse our website;
3.3.3 if you apply for employment with us, from any third parties that you nominate as your referees (and you consent to use obtaining Personal Information about you from third party sources such as social sites).
4. PURPOSE FOR USE AND DISCLOSURE
4.1 The purpose for which we use and disclose Personal Information will depend on the circumstances in which it is collected. Generally, we may use or disclose Personal Information:
4.1.1 for the purposes for which it was collected;
4.1.2 for a related secondary purpose, if the use or disclosure could be reasonably expected;
4.1.3 for other purposes to which you have consented; and
4.1.4 as otherwise authorised or required by law (for example, to comply with work, health and safety, industrial relations and taxation laws.
4.2 Specific purposes for which we may use or disclose Personal Information include the purposes of:
4.2.1 providing you with products and/or services;
4.2.2 providing our services to an entity which you are being inducted by, are a contractor of or are visiting;
4.2.3 dealing with customer care related activities;
4.2.4 marketing and developing our products and services;
4.2.5 the operation and administration of accounts;
4.2.6 carrying out certain checks (for example, in relation to credit);
4.2.7 considering an individual for employment;
4.2.8 interacting with companies or organisations with whom we have a business relationship;
4.2.9 complying with our obligations under agreements with third parties; and
4.2.10 carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.
4.3 In the event we collect Sensitive Information about you, you consent to us collecting, using and disclosing the Sensitive Information for the purpose for which it was disclosed and as permitted by the Act and other relevant laws.
4.4 It is not likely that we will disclose Personal Information that we collect and hold about you to any overseas recipients (as defined in the Act). If we transfer your information to third parties we will ensure that reasonable steps are taken to ensure that the overseas recipient does not breach the APPs in relation to the information, that the overseas recipient is in a jurisdiction that has an adequate level of protection for your data before we provide them with it.
4.5 For the avoidance of doubt, we provide software as a service to entities in order to assist them comply with their obligations under work, health and safety laws by inducting workers, managing hazards and workers and by ensuring the health and safety of their contractors and visitors. As such, if you use our online services your Personal Information may be shared with the entity which you are being inducted by, are a contractor of or are visiting and you consent to this use.
5. ANONYMITY AND PSEUDONYMITY
5.1 You can deal with us anonymously (without identifying yourself) or under a pseudonym (fictitious name) unless you are applying for credit from us or applying for employment with us. You will also not be able to deal with us anonymously where this would be inconsistent with the services we are providing to you or our customers or where it would otherwise be impractical or unlawful to deal with you anonymously or under a pseudonym.
6.1 We will take reasonable steps to keep your Personal Information confidential and to protect the Personal Information we hold from misuse and loss or unauthorised access, modification and disclosure.
6.2 All Personal Information collected by us will be retained as part of our business records, which will be securely monitored and maintained. We hold Personal Information in a number of ways, including:
6.2.1 on secure servers in our secure facilities;
6.2.2 on our web server computer, which is protected by firewalls;
6.2.3 as part of customer records and other electronic documents on which Personal Information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business; and
6.2.4 by securely storing hard copy documents on which Personal Information is contained, at our various premises and using third party document management and archiving services.
6.3 While we take reasonable technical and organisational precautions to ensure the security of your data on our systems (and without limiting anything set out in our Trading Terms or Website Terms):
6.3.1 data transmission over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet; and
6.3.2 without limiting the above (and except to the extent we are in breach of the Act), we do not take responsibility for any unauthorised access to your Personal Information or loss of or corruption of data caused by any computer virus or Trojan horse or via any system from an internet service provider linking your computer system to ours.
7. RETENTION OF PERSONAL INFORMATION
7.1 If we receive Personal Information where we have not taken any steps to collect such information, then within a reasonable time we will decide whether we could, under the APPs, have solicited that Personal Information ourselves. If we determine that we would not, under the APPs, have been permitted to solicit the Personal Information, we will as soon as practical (where lawful and reasonable to do so) destroy or de- identify that unsolicited Personal Information. If we could, under the APPs, have solicited the Personal Information then we may use and disclose the Personal Information for the purpose for which it was disclosed and as permitted by the Act and other relevant laws.
7.2 Where Personal Information held by us is no longer required to be held, and its retention is not required by law, then we will destroy such Personal Information by a secure means.
8. CREDIT REPORTING
8.1 If you apply for credit from us, we will need to collect Personal Information from you so we can assess your Credit Application. In order to assess your Credit Application, you consent to your Personal Information being disclosed to, and us obtaining your Personal Information from, third parties. Such third parties may include credit reporting bodies (CRB), companies who provide commercial credit references, people you authorise us to contact in connection with your Credit Application or any approved Business Credit Account, mercantile agencies and other companies who provide outsourced services to us. For contact details and information on how a CRB manages credit related Personal Information, please see their privacy policies available at the websites set out above.
8.2 CRBs may include your Personal Information in reports that they provide to credit providers to assist those providers in assessing your credit worthiness. If you fail to meet your payment obligations in relation to consumer credit or commit a serious credit infringement, we may be entitled to disclose this to a CRB.
8.3 CRBs offer a service to credit providers wanting to send direct marketing material about credit services to individuals (credit pre-screening). You have the right to request that CRBs do not use your Personal Information for credit pre-screening. To opt-out of credit pre-screening, contact the CRB, using the contact details on their websites set out above. You can also ask a CRB not to use or disclose your Personal Information for a period if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.
9. THIRD PARTY LINKS
10. ACCESS TO PERSONAL INFORMATION
10.1 You can gain access to your Personal Information, subject to certain exceptions contained in the Act. To request access to your Personal Information, or to update or correct that Personal Information, please send a written request to either Rapid Global, Level 2, 118 Franklin Street, Adelaide SA 5000 or to email address firstname.lastname@example.org (Contact Address). We will check the identity of individuals making requests to determine within 14 days whether the request will be met.
11. DIRECT MARKETING
11.1 We may send you marketing communications in line with your previously expressed marketing preferences or as otherwise permitted under the Act and other relevant laws. If you do not wish to receive such communications, please contact us via the Contact Address or follow the opt-out instructions contained in each marketing communication.
12.1 If you are concerned that the way in which we collect, hold, use or disclose your Personal Information may be in breach of the APPs/and or the Code, please send written details of your complaint to the Contact Address.
12.2 After receiving a complaint, we will conduct internal discussions and evaluate whether we believe that such collection, holding, use or disclosure of your Personal Information was in breach of the APPs and/or the Code. We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex issues or requires extensive investigation, it may not be possible to respond within this timeframe. If the conclusion of our investigation is that our collection, holding, use or disclosure of your Personal Information was in breach of the APPs and/or the Code, we will take steps to remedy the breach as soon as reasonably practicable. If after dealing with us you are still not satisfied, you are entitled to make a complaint to the Office of the Australian Information Commissioner or the Financial Ombudsman Service.
13. EUROPEAN UNION
13.1 If you are a resident of the European Union for the purposes of the General Data Protection Regulation (being Regulation 2016/679 of the European Parliament and of the Council) (GDPR), then in addition to what is set out above, the following applies to you.
13.2 We are a data controller and processor for the purposes of the GDPR and by you consenting to this Privacy Statement, we are able to process your personal data as defined in the GDPR (Personal Data) in accordance with this Privacy Statement.
13.3 In providing our services to you, we may make use of a number of automated processes using your Personal Data and your activity on our website as tracked by us, in order to provide more tailored and relevant services to you.
13.4 In addition to your rights set out above, you may:
13.4.1 update or rectify any of the Personal Data that we hold about you by contacting us as per paragraph 10 above;
13.4.2 withdraw your consent to our use of your Personal Information as described in this Privacy Statement (although this shall not affect the lawfulness of processing based on your consent before its withdrawal); and
13.4.3 request that we provide you with a copy of the Personal Data we hold about you in a portable and machine-readable form or share your Personal Data with a nominated third party.
13.5 You may request the above from us by contacting us as per paragraph 10 above.
13.6 Should you have any concerns in relation to our collection and/or processing of your Personal Data, then in addition to the process set out in paragraph 12 above, you have the right to complain to a supervisory authority (within the meaning of the GDPR). Our representative for the purposes of the GDPR can be contacted as per paragraph 10 above.
Updated on the 23rd of April 2019