Privacy Policy


PRIVACY POLICY

1) PURPOSE

Aline Group Australasia Pty Ltd and Aline Service Pty Ltd (Aline) is committed to maintaining the privacy and integrity of our data. This document sets out Aline’s Privacy Policy, and outlines how we collect, use, transfer and manage personal information while performing our functions and activities.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and other applicable laws that protect your privacy. We are committed to complying with these laws, including the Australian Privacy Principles (APPs) which are set out in the Act, and regulate how we must handle your personal information.

2) SCOPE

This Policy applies to all employees and contractors of Aline and any contractors or others who are informed by Aline that this Policy applies to them. This Policy applies to others entering contracts with us or otherwise providing us with personal information. This Policy applies to all your dealings with Aline and its related bodies corporate carrying on business in Australia in relation to personal information it obtains.

3) RESPONSIBILITIES

Position Responsibilities
Managers Responsible for the promotion of the Policy at all levels of Aline and are required to take steps, so far as is reasonably practicable, to help maintain the privacy of individuals.
Employees
  • Familiarise themselves with and understand and comply with Aline’s Policy as a priority.
  • Take reasonable care for maintaining the privacy and integrity of our data.
Contractors Comply with this Policy and legislative obligations.

4) PERSONAL INFORMATION

The Act provides for the protection of “personal information” which is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is either identified or reasonably identifiable. When used in this Privacy Policy, the term personal information has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

The types of personal information we may collect about you include:

• name

• mailing or street address

• email address

• telephone number

• payment details

• age or birth date

• IP Address

• any unique alphanumerical identifier issued under Australian law, which is recorded in the database being relied upon by a registrar for that Person (e.g. ABN number for a sole trader, Drivers Licence number).

• driver’s licence

• user IDs and passwords

• records of communications between Aline and yourself

• usage information

• and any other information disclosed by you.

5) SENSITIVE INFORMATION

Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health, racial or criminal record information.

The Privacy Act defines ‘sensitive information’ as:

information or an opinion about an individual’s:

• racial or ethnic origin

• political opinions

• membership of a political association

• religious beliefs or affiliations

• philosophical beliefs

• membership of a professional or trade association

• membership of a trade union

• sexual orientation or practices

• criminal record

that is also personal information; or

• health information about an individual

• genetic information about an individual that is not otherwise health information

• biometric information that is to be used for the purpose of automated biometric verification or biometric identification

• biometric templates.

Sometimes Aline may need to collect sensitive information about you to, for example, handle a complaint.

6) HOW ALINE COLLECTS PERSONAL INFORMATION

a) COLLECTION OF YOUR PERSONAL INFORMATION

Aline will collect personal information directly from you where it is reasonable and practicable to do so. Sometimes we may be required to collect information about you from a third party, such as our contractors and agents, referees or from publicly available sources.

You may visit our website anonymously, or by using a pseudonym, and can refuse to supply personal information where it is lawful and practicable to do so. However, if you do so it may prevent you from engaging in certain activities and services with Aline.

b) COLLECTION OF PASSIVE INFORMATION

Aline uses various technologies, such as cookies, to collect anonymous information from users of its website. This information helps us analyse website traffic and guide development of the website. Most web browsers automatically accept cookies, but you can modify your browser settings to disable them. If you do so, some parts of the website may not function properly.

7) COLLECTING, HOLDING, USING AND DISCLOSING PERSONAL INFORMATION

We collect personal information about you so that we can provide you with services that you request, perform our business activities and functions, and provide the best possible quality of customer service.

We may collect, hold and use your personal information for the following purposes:

• undertaking and completing transactions with parties with whom we do business, meeting our legal and regulatory requirements

• providing customer support

• improving customer service

• developing, researching, improving, distributing and marketing our products

• performing internal administration

• maintaining business relationships to enable us to carry on our business.

a) WHO DO WE DISCLOSE YOUR INFORMATION TO?

We may disclose your personal information to:

• our insurer

• regulatory bodies

• professional advisors such as accountants, solicitors, business advisors, and consultants

• government agencies

• enforcement bodies as defined in section 6 of the Privacy Act 1988 (Cth)

• courts or other parties we are authorised or required by law to disclose information to, and our agents

• contractors and external advisors who we engage to undertake our business functions and activities from time to time or who assist us in undertaking our business functions and activities.

• any organisation for any authorised purpose with your express consent.

b) DO WE DISCLOSE YOUR PERSONAL INFORMATION TO ANYONE OUTSIDE AUSTRALIA?

We may disclose personal information to our related third-party service providers located overseas. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the Australian privacy obligations relating to your personal information.

8) MARKETING OUR PRODUCTS AND SERVICES

From time to time, Aline may use or disclose your personal information to inform you about our products and services. If you do not wish to receive marketing materials from Aline, you may opt-out at any time by contacting our Privacy Officer.

We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including postal mail, SMS, and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time, you may opt-out of receiving marketing communications from us by using the unsubscribe link in the footer of our emails or by contacting us at [email protected].

9) PROTECTING YOUR INFORMATION

Aline maintains appropriate security, data collection, storage and processing practices to ensure reasonable steps are taken to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Where this information is no longer required, Aline will take reasonable steps to destroy or de-identify the information.

10) ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You may request access to any personal information we hold about you at any time by contacting us at [email protected] Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. Amendment requests should be forwarded to [email protected].

11) BREACH OF PRIVACY

If you believe that your privacy has been breached, please contact our Privacy Officer at [email protected] and provide details of the concern or incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will investigate and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

If we are unable to satisfactorily resolve your concerns, you can contact the Office of the Australian Information Commissioner (OAIC) via their website: https://www.oaic.gov.au

12) BREACH OF POLICY

Breaches of this Policy may be considered misconduct or serious misconduct. Disciplinary action may be taken against Aline employees who breach this Policy up to and including termination of employment. Individuals in breach of their legal obligations may also be penalised or prosecuted by the regulator for breach of relevant legislation. With respect to contractors of Aline, breaches of this Policy may be considered a material breach of a material requirement of their contractual agreement warranting termination of any contract or agreement.



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