Retail First Pty Ltd and its subsidiaries (Retail First) is bound by the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles as set out in the Privacy Amendment (Enhancing Privacy Sector) Act 2012 (Cth) (the Amendment Act).
What Information Does Retail First Collect?
‘Personal information’ refers to information or an opinion relating to an individual which can be used to identify that individual.
We receive and store any personal information you enter on our website or give us in any other way, such as contact information via telephone, electronic mail or online form. This information may be collected when you:
• Request a service;
• Contact us for customer support;
• Submit electronic forms requesting us to provide services or take actions;
• Submit messages or comments; or
• Participate in online surveys.
The types of information we gather from visitors to Retail First are:
• Contact Information: This information includes your full name, company name, mailing address, phone number, email address, and, where provided, your facsimile number.
• Demographic Information: If you visit our website to read, browse or download information, our system may record information such as the date and time of your visit to the website, the pages accessed and any information downloaded. We may collect and store anonymous demographic information (such as your post code, gender and age), and use this data to improve our services and how we market Retail First. No personally identifiable information will be linked to aggregated demographic information. It is used for statistical, reporting and website administration and maintenance purposes only. We will not use this information to identify you as an individual unless we are required by law, or where the website is accessed via links in an email we have sent which specifically states that clicked links may be tracked.
You are not obligated to give us your personal information. However, if you choose not to provide Retail First with your personal information we may not be able to provide you with the full range of our services. Retail First will at all times collect and manage personal information by fair and lawful means.
Retail First takes take great care to protect personal information on our website, however no data transmission over the Internet can be guaranteed to be secure. Retail First therefore cannot warrant the security of any information sent to us or received from us online as we have no way of guaranteeing that information is protected in transit. Once we receive your information we will make our best effort to ensure its security.
In certain emergency or law enforcement situations, Government agencies may have the authority to review web server records.
If our website contains links to other websites, we are not responsible for the privacy practices or policies of those sites.
Why Does Retail First Collect This Information?
If you are acquiring or have acquired a product or service from Retail First, we may collect personal information for the purpose of:
• Providing you with the relevant product or service;
• Managing and administering the product or service;
• Protecting against legislative breach where it is a financial management service.
• We may also acquire personal information provided in order to provide ongoing customer support or to improve our services and marketability.
Does Retail First Share Your Personal Information?
If Retail First collects personal information about you for a particular purpose, we will not use or disclose the information for another purpose unless you have consented to the use or disclose of that information.
However, we may release account and other personal information when we are required or authorised to do so:
• under an Australian law, court or tribunal order or other Government or law enforcement body or regulatory agency to enforce or apply our Services Agreement or other agreements;
• when we believe in good faith that disclosing this information is necessary or advisable, including the protection of the rights, property, or safety of Retail First, our users or others in relation to Retail First’s functions or activities;
• for the establishment, exercise of defence of a legal or equitable claim; or
• for the purposes of a confidential alternative dispute resolution process.
This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
In line with modern business practices and to meet your specific needs, we may disclose your personal information to the Company’s related entities. Where your personal information is disclosed, we will endeavour to ensure that the information is held, used or disclosed in accordance with the Act and the Amendment Act.
The Company generally does not disclose any information to overseas recipients. We will not transfer or disclose personal information to an overseas recipient unless we have your consent, we are required to do so by law or it is required in the course of providing services to you and only if we reasonably believe that the recipient of the information is subject to laws that have the effect of protecting the personal information in a substantially similar way in which the Act and the Amendment Act protect the information.
The Company will only use or disclose your personal information for direct marketing purposes if:
• it was collected from you;
• you would reasonably expect your personal information to be used or disclosed for direct marketing;
• you have the option to request not to receive direct marketing; and
• you have not made such a request.
Security and Storage
Retail First will take all reasonable steps to protect the security of the personal information that we hold. This includes taking reasonable steps to prevent unauthorised access, modification or disclosure and appropriate measures to protect electronic materials and materials stored and generated in hard copy.
Where Retail First no longer requires personal information for a permitted purpose under the Act or the Amendment Act, we will take reasonable steps to destroy it in a secure manner or de-identify it if that is appropriate.
What Information Can I Access?
Subject to the exceptions set out in the Act and the Amendment Act, Retail First gives you the ability to access your personal information that we hold. This may be for the purpose of viewing and, in certain cases, updating or correcting that information. If you wish to do so, you may email us your request or call our executive staff.
In providing access to your personal information, we may ask you to verify your identity and to specify what information you require. If requested by you, we will provide you with an opportunity to interact with us anonymously if it is practical to do so. For example, if you wish to remain anonymous when dealing with the Company in relation to a particular matter and request to use a pseudonym as a means of identifying you, we will use the pseudonym when dealing with you unless we are authorised by law to deal with individuals who have identified themselves, or in the circumstances it is impractical to deal with an unidentified individual.
Please note that no financial information will be provided over the phone, and in no event will such information be provided without verification.
We do not adopt identifiers that are assigned by Commonwealth Government Agencies as a means of identifying individuals.
When you update your information, we may keep a copy of the prior version for our records.
In certain circumstances we may not be required by law to provide access to or to correct personal information. If that is the case, we will give you our reasons for that decision.
Access may be denied if:
• The request does not relate to the personal information of the person making the request;
• Providing access would pose a serious and imminent threat to life or health of a person;
• Providing access would create an unreasonable impact on the privacy of others;
• The request is frivolous and vexatious;
• The request relates to existing or anticipated legal proceedings
• Providing access would prejudice negotiations with the individual making the request;
• Access would be unlawful;
• Denial of access is authorised or required by law;
• Access would prejudice law enforcement activities;
• Access discloses a ‘commercially sensitive’ decision making process or information; or
• Any other reason that is provided for in the Act or the Amendment Act.
Where it is established that the personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, or where you request to have the information corrected, we will take reasonable steps to correct the information.
Retail First may impose a fee for providing access related to the time taken to locate, collate and provide the information requested. Retail First reserves the right to impose charges for:
• Delivery costs of information stored off-site, where information is stored off-site, the cost of obtaining access to the information; and
• Access to electronic databases.
Conditions of Use, Disclaimer and Revisions
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
• how personal information is collected;
• how personal information is stored;
• how this information is used or disclosed; or
• how access is provided
Retail First attempts to resolve grievances at the local level if possible. If you have any concerns about your privacy with Retail First or any possible breaches of your privacy, please click here to contact our executive staff, and we will attempt to resolve it. Alternatively, please contact us on the details below.
Retail First will keep a record of your complaint and the outcome which will be logged on a database/complaints register. We will seek to achieve an effective resolution for your complaint within a reasonable timeframe of 28 days, or as soon as possible.
Retail First Contact Details
Office Level, Sunnybank Plaza
Cnr Mains Road and McCullough St
PO Box 737
Sunnybank Queensland 4109
Telephone | +61 7 3323 8888
Facsimile | +61 7 3323 8800
Email | [email protected]up.com.au