1. Our Commitment
MSAC Solutions Pty Ltd (ABN 33 601 307 831) and its related entities (“us”, “we” or “our”) are committed to maintaining the privacy and confidentiality of our customers’ (“you” or “your”) personal.
We are an Australian resident company and we elect to adhere to the Australian Privacy Principles (“APPs”) when collecting, using and disclosing personal information. We seek to manage Personal Information of our clients in an open and transparent way.
2. Your Personal Information
We respect the importance of your privacy and acknowledge that when you provide your Personal Information, you do so, on the proviso that we will only collect, use and disclose your Personal Information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”).
3. Your Sensitive Information
We will not collect Sensitive Information about you except with:
(a) your consent; or
(b) where it is reasonably necessary to collect such information, or
(c) is required or permitted by law.
We will notify you as soon as practicable should we obtain or require Sensitive Information about you.
4. Collection and Storage
We collect Personal Information about individuals, where the information is necessary to conduct our business.
4.1 Kinds of Personal Information we collect and hold
The type of Personal Information about you that we collect includes the following:
(b) residential address;
(c) date of birth;
(e) contact details, including email address and telephone numbers;
(f) employment or business details;
(g) banking details; and
(h) information collected via electronic communications, which may include system account details, internet protocol addresses, the time, date and place of the communication.
4.2 How we collect and hold your Personal Information
Your Personal Information is collected when you:
(a) provide it to us;
(b) visit and browse our website and other online platforms including eLearning, support, project management and finance systems;
(c) interact with us electronically, via social media platforms (i.e. LinkedIn, Facebook, Instagram and Twitter); or
(d) contact us by email, telephone, online chat, video conferencing or facsimile.
Personal Information that we receive about you that we have not requested from you personally, will, if we could not have collected the information ourselves, be destroyed or de-identified within a reasonable period after we received that information.
4.3 Collection from Third Parties
We may collect Personal Information from a third party where:
(a) the third party is one of our Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)), business partners, credit reporting bodies, other customers or your representatives; or
(b) you have consented to the collection of the information; or
(c) we are required, or authorised under Australian law, court/ tribunal, to do so; or
(d) it is unreasonable or impracticable to obtain the information from you; or
(e) the information is publicly available.
4.4 Purpose of Collection
The Purpose for which we may collect, use or disclose your Personal Information include:
(a) to verify your identity;
(b) to provide you with our products or services;
(c) to assist you with enquiries or purchases, or to provide you with better customer service;
(d) to administer and manage the products and services we provide;
(e) reproduce and store the Personal Information for the Primary or Secondary Purposes; or
(f) to share your Personal Information internally or to Related Bodies Corporate, or with our contractors and other service providers, in connection with clauses 4.4(a) to (e),
collectively, the (“Primary Purpose”).
We will not use or disclose the information for any other purpose (“Secondary Purpose”) unless:
(g) You consent to such use; or
(h) You would reasonably expect us to use or disclose the information for a Secondary Purpose which:
(i) where the information is Sensitive Information, directly related to the Primary Purpose; or
(ii) where the information is not Sensitive Information, related to the Primary Purpose; or
(iii) such use and disclosure is permitted by law or a court/tribunal order
We may use your Personal Information to send you marketing. When you receive our marketing, we will provide you
with an option to opt out of receiving future direct marketing. If you do not elect to opt out of receipt
of future marketing, we may continue to send you marketing until you opt out.
6. Data Quality and Security of your Personal Information
Protecting your Personal Information is a priority for us. We may hold your Personal Information in electronic and physical files or on secure servers, storage and archive systems, including the Cloud, and take reasonable steps to ensure that your Personal Information is protected.
It is important to us that the Personal Information we maintain and use is accurate, complete and up-to-date. If at any time your Personal Information changes, contact the Privacy Officer on the details below so that we can update our records.
The Personal Information we hold about you is treated confidentially and is only accessed when necessary. Whilst we take appropriate caution to protect your Personal Information, no data transmission over the internet or electronically can be completely secure. Once we have received your Personal Information, we will take all appropriate measures to use procedures and programs to ensure that the information on our systems is secure. We will take reasonable steps to protect the Personal Information we retain from misuse, loss and from unauthorised access, modification or disclosure.
We will not be liable for any loss, corruption, delay or loss of confidentiality arising from any data or information transmitted electronically if we have followed appropriate virus checking and privacy procedures.
You may also assist us to keep your Personal Information secure by ensuring appropriate back-up, security and virus check procedures are in place for any data or information provided to or received from us electronically. Please use your discretion and exercise caution when providing your Personal Information.
We will not retain any of your information for any longer than it is required by us or the law. We may also de-identify your information where applicable.
7. Accessing, Correcting and Deleting Your Personal Information
You may request access to Personal Information that we hold about you at any time. However, this right of access is subject to some exceptions permitted by law. To make a request, please put your request in writing to the Privacy Officer using the contact details below.
In normal circumstances we will give you full access to the Personal Information held about you as soon as practicable, subject to and in accordance with the Privacy Act. However, in some circumstances we may require proof of identity, impose a charge or deny your request if it would be unreasonable to provide you with access, or would impact on the privacy of another person.
We reserve the right to charge a fee for searching for and providing access to your Personal Information. In the event we refuse you access to your Personal Information, we will provide you with an explanation for that refusal.
You may deal with us anonymously where it is lawful, practicable and reasonable to do so.
You can request that information about you be corrected or deleted. However, Personal Information may be retained in certain files in order to resolve disputes or for auditing purposes. Some Personal Information may also be retained in our technical systems in accordance with its data security procedures.
8. Cross-border disclosure of personal information
We may in connection with the Primary Purpose and Secondary Purposes, disclose personal information to an overseas recipient. Where this occurs, we will take reasonable steps to ensure that the overseas recipient does not breach the APP’s, or is otherwise subject to laws or a binding scheme that is substantially similar to APP’s in the way in which information is protected.
9. Changes to this Policy
If you believe there has been a breach of your privacy, you may make a complaint by advising the Privacy Officer in writing, using the contact details below. We will respond to your complaint within a reasonable period of time.
If the complaint cannot be resolved, you may refer your complaint to the Office of the Australian Information Commissioner.
11. Governing Law
Where we receive information that is derived from Europe or the United States, we apply additional compliance measures to ensure compliance with the General Data Protection Regulations and the California Consumer Protection Act as applicable.
13. Contact Details of Privacy Officer
Address: 1/12 Castles Drive, Torquay, Victoria, Australia 3228
Phone: +613 5261 5800
14. Glossary of Terms
(a) “Australian Privacy Principles” or “APP’s” means the principles established pursuant to the Privacy Act; 3 pmsac01_20193488_009.docx
(b) “Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(i) whether the information or opinion is true or not; and
(ii) whether the information or opinion is recorded in a material form or not.
(c) “Primary Purposes” means conducting the business of MSAC Solutions, including:
(i) supplying goods and services to you.
(d) “Secondary Purposes” means matters incidental to conducting the business of MSAC Solutions, including:
(i) business marketing;
(ii) data use and collection for internal business purposes;
(iii) storage and security of the information;
(iv) debt collection; and
(vi) complying with the law.
(e) “Sensitive information” means information or an opinion about an individual’s:
(i) racial or ethnic origin;
(ii) political opinions;
(iii) membership of a political association;
(iv) religious beliefs or affiliations;
(v) philosophical beliefs;
(vi) membership of a professional or trade association;
(vii) membership of a trade union;
(viii) sexual orientation or practices;
(ix) criminal record;
(x) health information;
(xi) genetic information; or
(xii) biometric information or templates.
Find out how MSAC can benefit your business.