Trimantium GrowthOps Limited (ACN 621 067 678)
Trimantium GrowthOps Limited and its related entities (referred to as “GrowthOps”, “we” or “our”) are committed to the protection of your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (“Privacy Act”).
1. What is “Personal Information”?
“Personal Information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
2. What Personal Information do we collect and hold?
GrowthOps may collect and hold Personal Information such as your name, gender, date of birth, age, contact details (including your address, phone number and email, whether personal or for work), financial information, payment details, bank account details, tax file number and/or products and services information and preferences.
3. Why do we collect Personal Information?
- GrowthOps collects Personal Information from customers, officers, employees, contractors, consultants, service providers, agents, shareholders and other individuals that is reasonably necessary for one or more of our functions or services, including: in order to allow us to conduct our business functions, to market and sell our products and services, to conduct officer, employee, contractor, consultant, service provider, agent or shareholder related activities and to conduct product and market research related activities.
- If you choose not to provide your Personal Information to GrowthOps, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.
4. When and how do we collect Personal Information?
- GrowthOps collects Personal Information when you: become an officer, employee, contractor, consultant, service provider or agent of GrowthOps, visit our Website, supply, use, or buy products or services, request information about us or our products or services, provide feedback, contract with us, become or apply to become a shareholder, fill in a form on our Website, fill in one of our surveys, or contact us by telephone, facsimile, email, post or in person.
- GrowthOps may also collect Personal Information about you via third parties including our suppliers, merchants, survey providers or marketers.
- You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.
5. Information collected via our Website
- GrowthOps will not collect any Personal Information about users of our Website except when they knowingly provide it or as otherwise described below. For example, GrowthOps may collect Personal Information from users when they:
- complete an online form on our Website; and/or
- complete one or more of our surveys; and/or
- otherwise correspond with GrowthOps.
Click Stream Data
- When you visit and browse our Website, our Website host may collect Personal Information for statistical, reporting and maintenance purposes. Subject to clause 4, the Personal Information collected by our Website host will not be used to identify you. The information may include:
- the number of users visiting our Website and the number of pages viewed;
- the date, time and duration of a visit;
- the IP address of your computer; or
- the path taken through our Website.
- GrowthOps’ Website host uses this information to administer and improve the performance of our Website.
- Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns.
- If you access our Website, a cookie is downloaded onto your computer’s hard drive when you first log on to our Website. You can adjust your internet browser to disable cookies, however GrowthOps may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.
- Web beacons are images that originate from a third party site to track visitor activities. GrowthOps may use web beacons to collect aggregate data and provides this information to our Website host to administer and improve the performance of our Website.
6. How GrowthOps uses the Personal Information it collects about you
- GrowthOps uses the Personal Information it collects about you for our business functions and activities, which may include the following:
- to provide you with information, products or services you have requested;
- to promote and market our products and services to you;
- to personalise and customise your experiences on our Website;
- to help GrowthOps research the needs of its customers;
- to conduct research for the purposes of improving existing products or services or creating new products or services;
- to provide you with ongoing information about GrowthOps and its activities;
- to allow us to provide third party information and offers in which we believe you may be interested;
- to comply with regulatory or other legal requirements;
- for purposes related to the employment of our personnel and providing internal services to our staff;
- if you are a shareholder or apply to become a shareholder, to process your application, service your needs as a shareholder, provide facilities or services that you request, and administer your shareholding; and
- for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
- GrowthOps may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes in clause 1, if we have your consent or if otherwise provided for under the Privacy Act.
- GrowthOps may use your Personal Information to provide you with direct, targeted, or other marketing materials on an ongoing basis. GrowthOps may provide you with these materials by telephone, electronic messages (e.g. email), our digital services and other means. GrowthOps will only provide you with direct marketing materials where you would reasonably expect us to, or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing communications may include promotional material about GrowthOps or may relate to the products and services GrowthOps, and our related entities, provide and other products and services which may be of interest to you.
- You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 14.
7. Who do we disclose your Personal Information to?
- Depending on the nature of your engagement with GrowthOps, we may disclose your Personal Information to shareholders, officers, employees, contractors, consultants, agents of GrowthOps, third parties that provide products and services to or through GrowthOps or our Website, directly to you (at your request), suppliers and other third parties, or otherwise as required by law.
- GrowthOps may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
- We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.
8. Disclosure of your Personal Information overseas
- Your Personal Information may be disclosed outside of Australia to an entity in a foreign country, including entities in which GrowthOps has an ownership interest or to a service provider in the business of providing data storage and processing services (which commonly involve diverse geographic locations which change from time to time, which means it is not practical for us to notify you of which country your Personal Information may be located in). It is possible that entities with whom we share your information outside Australia may be subject to foreign laws that do not provide the same level of protection of Personal Information as in Australia.
- By providing your Personal Information, you acknowledge that you understand the risks associated with the disclosure of your Personal Information overseas and expressly consent to the disclosure of your Personal Information to an overseas entity.
9. Employee records
Employee records are not generally subject to the Privacy Act. As such this policy may not apply to the handling of officer, employee, contractor or consultant information. Please contact us directly for information about these information handling practices.
10. Storage and security of Personal Information held by GrowthOps
- GrowthOps views the protection of privacy as a serious matter. GrowthOps will take reasonable steps to protect your Personal Information from misuse, interference and loss and from unauthorised access, modification or disclosure.
- GrowthOps aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on GrowthOps’ computer systems.
11. Updating and Correcting your Personal Information
We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up- to-date and complete. You have a right to request your Personal Information to be corrected. You can update your Personal Information at any time by contacting GrowthOps in any of the ways specified in clause 14. GrowthOps welcomes any changes to your Personal Information so as to keep our records up to date.
12. How long will GrowthOps keep your Personal Information?
- We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law.
- Where we no longer need to keep your Personal Information in accordance with clause 1, we will take reasonable steps to destroy or de-identify your Personal Information.
- If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).
13. Finding out what Personal Information GrowthOps holds about you
- You are entitled to access Personal Information that GrowthOps holds about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Australian Privacy Principles or at law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
- A request for access can be made by contacting GrowthOps in any of the ways specified in clause 14.
14. How to contact us
Email: [email protected]
Trimantium GrowthOps Limited
Level 9, 287 Collins Street
Melbourne VIC 3000
GrowthOps will review and respond to your complaint as soon as possible, generally within 30 days of receiving it. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.
Last updated: 10 November 2017