This Policy applies to Spring FG Digital Pty Ltd ACN 143 840 528 (‘Spring’). The word ‘individual’ refers to a customer, or advertiser, a consumer, or any other person who accesses our services via our website or any other means, or any person with whom we come into contact.
This Policy outlines Spring’s obligation to manage and protect the personal information we hold about individuals.
Spring is bound by the National Privacy Principles (‘NPPs’) contained in the Privacy Act 1988 (C’th) (‘Privacy Act’).
‘Personal information’ is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information which we collect is ‘sensitive information’. Sensitive information includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, that is also personal information, and also includes health information about an individual.
How we collect personal information
We generally collect personal information directly from the individual. For example, an individual may deal with us on the phone, send us correspondence (by letter, fax or email) or contact us in person. Also, Spring will collect personal information from forms filled out by individuals, interviews, business documents and from other people.
Typically, the type of personal information we collect about the individual includes name, age, date of birth, occupation, financial information, mailing address, phone numbers, email address and other information that is relevant to the services we provide.
About whom do we collect personal information?
The type of information we may collect and hold includes (but is not limited to) personal information about:
– consultants and contractors;
– prospective employees, employees and contractors; and
– other people with whom we come into contact.
Use of Information and disclosure
Spring may use and disclose personal information for the primary purposes for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g., where required by law).
We use and disclose personal information for the following purposes:
• to enable companies to place advertisements on their website;
• to enable investors and consumers to post comments on the website;
• to enable consumers to participate in on-line polls;
• for research purposes;
• to conduct our business;
• to comply with our legal obligations; and
• to help us manage and enhance our services.
We do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive information for direct marketing purposes.
We engage other people to perform services for us, which may involve that person handling personal information we hold. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it.
In relation to sensitive information held by us, wherever possible, Spring will attempt to de-identify the information. We also delete all personal information about an individual when it is no longer needed or relevant.
To whom might we disclose personal information?
We may disclose personal information to:
• consultants we engage;
• organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
• organisations involved in managing our funding functions;
• regulatory authorities, if required by law; and
• anyone else to whom the individual authorises us to disclose it.
We also collect personal information from these organisations and individuals, and deal with that information in accordance with this Policy.
Sending information overseas
We will not send personal information to recipients outside of Australia without obtaining the individual’s consent (in some cases this consent will be implied) or otherwise complying with the NPPs.
Management of personal information
The NPPs require us to take all reasonable steps to protect the security of personal information.
Spring takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. All personal information stored on Spring’s computer system is backed up daily and monthly.
Where we no longer require the personal information for a permitted purpose under the NPPs, we will take reasonable steps to destroy it.
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes.
How do we keep personal information accurate and up-to-date?
Spring takes reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out below.
You have the ability to gain access to your personal information
Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information which Spring holds about them by contacting the Spring Privacy Officer. If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act. When an individual requests access to personal information, which includes evaluative information created by Spring (as defined in NPP 6.2), a representative of Spring will meet the individual personally (where this is possible), and explain the evaluative information to the individual, without giving them a copy of it.
An individual’s request for access to his/her personal information will be dealt with by allowing the individual to look at his/her personal information at the offices of Spring. We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise the likely cost in advance whenever practicable.
Updates to this Policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.