Polonious Pty Ltd ABN 17 117 728 999 (Polonious Pty Ltd) and it’s related entities are committed to protecting the privacy of your personal information. This privacy policy explains how Polonious Pty Ltd manages the personal information that we collect, use and disclose and how to contact us if you have any further queries about our management of your personal information. This privacy policy does not cover personal information collected or held by Polonious Pty Ltd about its employees.

Polonious Pty Ltd is required to comply with the Privacy Act 1988 (Privacy Act) and with the Australian Privacy Principles (APP) (subject to the other provisions of the Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal. Polonious Pty Ltd is also required to comply with the Spam Act 2003 (Spam Act).

What is personal information?

Personal information is information or an opinion, in any form and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. Examples include an individual’s name, address, contact number and email address.

Special provisions apply to the collection of personal information which is sensitive information. Sensitive information includes (for example) information about a person’s membership of a professional or trade association.

Collection of personal information by Polonious Pty Ltd

To the extent required by the Privacy Act:

• Polonious Pty Ltd will not collect personal information about you unless that information is necessary for one or more of our functions or activities
• Polonious Pty Ltd will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner

When Polonious Pty Ltd collects personal information directly from you, we will take reasonable steps at or before the time of collection to ensure that you are aware of certain key matters, such as the purposes for which we are collecting the information, the organisations (or types of organisations) to which we would normally disclose information of that kind, the fact that you are able to access the information and how to contact us (for example, where personal information is collected on a form, we will generally include a written privacy statement on the form which sets out these details).

Polonious Pty Ltd will collect your personal information directly from you where it is reasonable and practicable to do so. Where Polonious Pty Ltd collects information about you from a third party, we will still take reasonable steps to ensure that you are made aware of the details set out above.

Use and disclosure of personal information by Polonious Pty Ltd

If Polonious Pty Ltd uses or discloses your personal information for a purpose (secondary purpose) other than the main reason for which it was originally collected (primary purpose), to the extent required by the Privacy Act, we will ensure that:

• the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that Polonious Pty Ltd would use or disclose your information in that way;
• you have consented to the use or disclosure of your personal information for the secondary purpose:
• the use or disclosure is required or authorised by or under law; or
• the use or disclosure is otherwise permitted by the Privacy Act (for example, as a necessary part of an investigation of suspected unlawful activity)

Why does Polonious Pty Ltd collect personal information?

Polonious Pty Ltd collects personal information for a range of purposes, including to:

• process credit applications
• provide information, quotes, etc on products and services
• facilitating our business operations – eg: for managing our IT infrastructures, databases, websites and statistical and maintenance purposes
• notify customers and business partners about Polonious Pty Ltd events
• dealing with feedback and complaints
• any other purpose communicated to you at the time we collected your personal information or as required or permitted by law

From time to time, Polonious Pty Ltd surveys its customers and business partners on a range of issues such as marketing surveys regarding products and services or surveys to determine customer experience with Polonious Pty Ltd’s customer service. These surveys help us to identify and analyse the areas of improvement for our business and the quality of our products and services. If you do not wish to participate in these surveys, please advise us via the feedback details on our website.

If you are a prospective customer and you give us your consent, we may also use your personal information to provide you with information about Polonious Pty Ltd and our current and future products and services. You can advise us at any time if you no longer wish to be contacted for this purpose. Your consent will remain current until you advise us otherwise.

How might we contact you?

We may contact you in a variety of ways, for example by post, email, SMS etc.

Spam

We will not send you any commercial electronic messages such as SMSs or emails unless this is permitted by the Spam Act (for example, if we have your express or inferred consent to do so). Any commercial electronic message that we send will identify Polonious Pty Ltd as the sender and will include our contact details. The message will also provide an unsubscribe facility. If you do not wish to receive commercial electronic messages from us, please let us know (our contact details are provided at the end of this policy).

When does Polonious Pty Ltd disclose personal information to third parties?

In performing our functions and activities, we may need to disclose personal information to third parties.

Third parties with whom Polonious Pty Ltd may share your personal information include, where appropriate:

• financial institutions for payment processing
• Polonious Pty Ltd’s contracted service providers, including:
  • information technology service providers;
  • printers and distributors of direct marketing material; and
  • external business advisers (such as auditors and lawyers)

Data quality and security

To the extent required by the Privacy Act, Polonious Pty Ltd will take reasonable steps to:

make sure that the personal information that we collect, use and disclose is accurate, complete and up to date
protect the personal information that we hold from misuse and loss and from unauthorised access, modification or disclosure
destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act

Anonymity

Polonious Pty Ltd will generally provide individuals with the option of not identifying themselves when entering into transactions when it is lawful and practicable to do so.

Use of Commonwealth government identifiers

Polonious Pty Ltd will not use Commonwealth government identifiers (Identifiers) (such as Medicare numbers) as its own identifier of individuals. We will only use or disclose Identifiers in the circumstances permitted by the Privacy Act.

Transfer of personal information overseas

Polonious Pty Ltd will comply with requirements of the Privacy Act that relate to trans-border data flows.

Access and correction of your personal information

Please contact Polonious Pty Ltd if you would like to access or correct the personal information that we hold about you.

To protect your privacy and the privacy of others, we will need evidence of your identity before we can grant you access to information about you or change it.

Polonious Pty Ltd will generally provide you with access to your personal information (although a fee may be imposed), and will take reasonable steps to amend any personal information that is incorrect. In some circumstances, Polonious Pty Ltd may not permit access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision.

Further information

Please contact Polonious Pty Ltd if you have any queries about the personal information that Polonious Pty Ltd holds about you or the way we handle that personal information. Polonious Pty Ltd’s contact details for privacy queries are set out below.

Privacy Contact

Attention: Polonious-Systems Privacy Officer, Level 11, 65 York Street, Sydney 2000
E-mail: privacy@polonious.com.au

Phone: (02) 8916 6445

Complaints

Please contact the Privacy Officer using the above details if you have any concerns or complaints about the manner in which your personal information has been collected or handled by Polonious Pty Ltd.