[Last updated February 2017]
This Privacy Notice should be read in conjunction with our Terms & Conditions.
Privacy Disclosure Statement
In order to comply with the requirements of the Privacy Act 1998 (Cth) and the Australian Privacy Principles, we are required to advise you that CathMacAdam.com, ABN 78 168 680 099, holds personal information about you. The information has been, and will continue to be, collected by us for the purpose of providing you with marketing advice.
If you choose to not provide us with the information requested by us, we may not be able to provide you with the services you require of us.
We may collect information from you through your use of our website, when you request information from us or engage our marketing or other services, or as a result of your relationship with one or more of our representatives and other professionals in connection with our services. .
By using any of our services including our website and by providing us with any personal information, you are consenting to the use of your personal information as set out in this policy. Please do not send us any personal information if you do not want your personal information to be used in this way.
In the event we consider it necessary to use or disclose information about you for purposes other than those detailed above, or related purposes, we will seek your consent. You are entitled to obtain access to the information which we hold about you by emailing us on firstname.lastname@example.org.
CathMacAdam.com and its associated entities abides by the Australian Privacy Principles under the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth). A summary of the Australian Privacy Principles is available by contacting our office.
Collection of Personal Information
As a marketing organisation we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information” and “sensitive information”). Our ability to provide you with a comprehensive marketing advice service is dependent on us obtaining certain personal information or sensitive information about you, including:
- ID information including names, addresses, phone, email address;
- Financial details including bank account and credit card details;
- Access to social media accounts and websites via usernames and passwords;
- Other information we think is necessary.
- Failure to provide to us the information referred to above may affect the adequacy or appropriateness of advice we give to you.
We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us. Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we will handle this information the same way we do with other information we seek from you. If not, we will destroy the information or ensure that the information is de-identified.
Generally, collection of your personal information will be effected in either over the telephone, Internet calls, face to face interviews, or by way of an online client engagement form. From time to time additional and/or updated personal information may be collected through one or more of those methods.
From time to time and if necessary to do so, we may collect information about you from other sources. Instances pertaining include:
- reliance on publicly available information to update your contact details when uncontactable;
We will only collect, maintain and use personal Information about you if it is necessary for us to provide adequate marketing advice to you.
Holding of Personal Information
Your personal information is stored in different ways, including paper and electronic form and is generally held in your client file. Information may also be held in a computer database.
The security of your personal information is important to us and at all times we seek to ensure that personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained for a period of 7 years in order to comply with legislative and professional requirements..
Use and Sharing of Personal Information
We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except as described in this policy or with your prior permission.
We will not use or disclose Personal Information collected by us for any purpose other than:
- the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
- where you have consented to such disclosure; or
- as expressed in this Privacy Disclosure Statement; or
- where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.
We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however you may, by contacting us, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned.
In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or, disclosed by them. In the event that a sale of our business is effected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.
Although we don’t send personal information overseas you should be aware of the following:
- your personal information may be accessed by our contractors, representatives or agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or, in some instances by email;
- from time to time, information may be loaded to the cloud for storage or access through programs such as drop box etc; and
Accessing your Personal Information
You may at any time request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
We will give you access to your information in the form you want it where it is reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we will always check with you first.
We are not always required to give you access to your personal information to the extent that:
- providing access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
- providing access would have an unreasonable impact on the privacy of other individuals;
- the request for access is frivolous or vexatious;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- providing access would be unlawful;
- denying access is required or authorised by or under law;
- we have reason to believe that unlawful activity, or misconduct of a serious nature, that relates to the entity’s functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
- providing access is likely to harm the activities of an enforcement body;
- providing access would harm the confidentiality of our commercial information.
In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal. If you have any concerns, you can complain. See ‘Making a Complaint’.
Correcting your Personal Information
We will endeavour to ensure that, at all times, the personal information about you which we hold is up to date and accurate. In the event that you become aware or believe that any Personal Information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may contact us and provide us evidence of the inaccuracy, outdatedness, incompleteness, irrelevance or misrepresentation and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.
We will endeavour to respond to any request for access within 30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.
If we are unable or do not agree to correct your personal information, we will explain why within five business days of making the decision. If you have any concerns, you can complain. See ‘Making a Complaint’.
If we are unable to make corrections with the 30 day or agreed upon time frame we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to the Office of the Australian Information Commissioner.
Making a Complaint
It is our intention to use our best endeavours to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner: