- who we collect information from;
- the types of personal information collected and held by us;
- how this information is collected and held;
- the purposes for which your personal information is collected, held, used and disclosed;
- how you can gain access to your personal information and seek its correction;
- how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled; and
- whether we are likely to disclose your personal information to any overseas recipients.
Who do we collect personal information from?
In the course of providing our products and services, GJS Group Australia (ABN 84 002 147 846) (“GJS”) - including our related entities - may collect personal information from customers, potential customers, staff, prospective staff, consultants and contractors.
What types of personal information do we collect?
In the course of providing products and services we may collect:
- Personal information including names, addresses and other contact details.
- Financial information including credit card and bank account details for order or refund processing.
- For Employees - Sensitive Information including government identifiers (such as your TFN), your nationality, country of birth, professional memberships, family court orders and criminal records.
How do we collect and hold your personal information?
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible GJS has attempted to standardise the collection of personal information by using specifically designed forms (e.g. PDF forms, website). However given the nature of our operations we often also receive personal information by email, letters, notes, exchange of business cards, over the telephone, in face-to-face meetings and through financial transactions.
We may also collect personal information from other people (e.g. a third party referee) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.
Sometimes we may be provided with your personal information without having sought it through our normal means of collection. We refer to this as "unsolicited information". Where we collect unsolicited information we will only hold, use and or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the information as appropriate.
We may automatically collect the following information about your use of our Site or Services through cookies, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site, and the following: access time, browser type, device ID, IP address, all data submitted by you, page views and referring URL.
How we use your personal information?
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include but are not limited to:
- fulfilling sales orders and product servicing
- publication of subscription based newsletters and blogs, and provision of materials for download via industry specific public websites;
- satisfying our legal obligations;
- helping us to improve our operations including training our staff; systems development; developing new programs and services; undertaking planning, research and statistical analysis;
- the employment of staff; and
- the engagement of contractors and consultants;
- to tailor the content and information that we may send or display to you, to offer location customisation, and personalised help and instructions, and to otherwise personalize your experiences while using the Site or our Services;
- marketing and promotional activities including communicating with you about the other products and services we provide. We also may use the information that we learn about you to assist us in advertising our Services on third party websites;
- to better understand how users access and use our Site and Services, both on an aggregated and individualised basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes;
- we collect the data to have a better visibility on our customer base and their behavior. It’s used by our sales team to learn about customers’ engagement levels, and used in aggregate by our product and marketing team to better understand the navigation path, retention and funnel drop-offs;
We only collect sensitive information reasonably necessary for one or more of these functions or activities if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety or another permitted general situation or another permitted health situation exists.
Storage and security of your personal information
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers.
The security of your personal information is of paramount importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
These steps include:
- Restricting access to information on our databases on a need to know basis with different levels of security being allocated to staff based on their roles and responsibilities and security profile.
- Encrypting sensitive data including passwords and credit card details on our website database.
- Ensuring all staff are aware that they are not to reveal or share personal passwords.
- Implementing physical security measures at our premises to prevent break-ins.
- Implementing ICT security systems, policies and procedures designed to protect personal information storage on our computer networks.
- Password protecting all staff PCs to protect personal information storage held on these devices.
- Implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
- Undertaking due diligence with respect to third party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
Personal information we hold that is no longer needed, or required to be retained by any other laws, is destroyed in secure manner, deleted or de-identified as appropriate.
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
When we disclose your personal information
We only use personal information for the purposes for which it was given to us, or for purposes which are directly related to one or more of our functions or activities. We may disclose your personal information to government agencies, and other recipients from time to time, only if one or more of the following apply:
- you have consented;
- you would reasonably expect us to use or disclose your personal information in this way;
- we are authorised or required to do so by law;
- disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;
- where another permitted general situation applies or another permitted health situation exists;
- disclosure is reasonably necessary for a law enforcement related activity.
Disclosure of your personal information to overseas recipients
We may disclose personal information about an individual to overseas organisations that help us provide our services, in certain circumstances, such as when storing information with a "cloud service provider" which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual's personal information to overseas recipients unless:
- we have the individual's consent (which may be implied);
- we have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime;
- we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or
- we are taking appropriate action in relation to suspected unlawful activity or serious misconduct
How we ensure the quality of your personal information
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection and when using or disclosing the personal information.
On an ongoing basis we maintain and update personal information when we are advised by individuals or when we become aware through other means that their personal information has changed.
Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.
How to gain access to your personal information we hold
You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us.
If we do not agree to provide you with access or to amend your personal information as requested, you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
How we collect non-personal information
We do not collect any personal information on visitors to our website.
We do collect non-personal information that allows us to log information about visitors to our website for statistical purposes, such as:
- the number of unique sessions as identified by server address and top-level domain name (e.g. .com, .gov, .org, etc.);
- the number of page hits;
- the pages accessed or downloaded by session;
- the type of browser being used;
- the length of time spent on the site and on particular pages;
- the device being used (e.g. desktop or mobile); and
- the type of mobile device being used (e.g. iPhone 6);
- the actions performed on our Site (e.g. adding products to shopping cart, downloading documents, checking out);
- we have implemented and use Display Advertising;
- we use Remarketing with Google Analytics to advertise online;
- third-party vendors, including Google, show our ads on sites across the Internet;
- we and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on someone's past visits to our website; and
- users can opt out by utilising Google's Opt-Out Browser Add On (https://tools.google.com/dlpage/gaoptout/) and/or Ads Preferences Manager (https://www.google.com/settings/ads/);
- we have implemented and use a Live Chat feature which logs the pages you visit on our website only which enables us to provide support to any questions you have about our website functionality or product information;
- users opt in to chat by making themselves identifiable by providing their name, email address and an optional phone number;
- this information is only used to assist Live Chat questions;
- use automated applications to track our visitors and evaluate usage of our Site. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences.
If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email, letter or by personal delivery to any one of our contact details as noted below. You may also make a complaint verbally.
We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we make seek further information from you in order to provide a full and complete response.
Your complaint may also be taken to the Office of the Australian Information Commissioner.
How to Contact Us
- Emailing email@example.com
- Calling 1800 457 888
- Writing to GJS’s Privacy Officer at Unit 2/16 Mavis Street REVESBY NSW 2212
Changes to our privacy and information handling practices