We are committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We are bound by the applicable laws, including but not limited to, the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.
This policy explains how and why we collect, use, hold and disclose your Personal Information.
”We”, “us” and “our” means SUREFIRE SYSTEMS PTY LTD (ACN 632 748 193) having its office at Level 5, 606 St Kilda Rd, Melbourne, VIC 3004:
If you provide Personal Information to us you consent to us collecting, holding, using, and disclosing your Personal Information in accordance with this policy.
WHAT IS PERSONAL INFORMATION?
Personal Information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be Personal Information regardless of whether it is true.
WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We collect Personal Information in the following ways:
Information you give us: we collect any information you provide us in relation to subscribing to the services of Surefire, when you call us, when you interact with us on social media, when you download resources from any of our websites, when you sign up to any of our online newsletters.
Automatic Information: we automatically collect certain types of information when you interact with any of our services, for example authentication and security credential information, location of your computer or device, network and connection information, email addresses and phone numbers used to contact you.
Information from other sources: We might collect information about you from other sources, including service providers, partners, via our other related entities located in Australia or internationally and publicly available sources.
We may collect information about how you access, use, and interact with the website. We also use a range of other tools such as Google Analytics, WIX website form data tools, Google Search and Ads platforms and Zoom Info to collect information about how you use, access and interact with our website. This information may include:
(a) the location from which you have come to the site and the pages you have visited; and
(b) technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language, and operating system; user demographics and metadata.
We also hold Personal Information that have been collected by our customers when they use our software and/or services to deliver products and/or services to you.
WHY DO WE COLLECT, HOLD AND USE YOUR PERSONAL INFORMATION?
We collect, hold, and use your Personal Information so that we can:
(a) provide you and our customers with products and/or services;
(b) manage our relationship with you and our customers/vendors;
(c) contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
(d) comply with our legal obligations and assist government and law enforcement agencies or regulators;
(e) identify and tell you about other products or services that we think may be of interest to you;
(f) market our services.
If you do not provide us or our customers with your Personal Information, we or our customers may not be able to deliver certain products or services to you, communicate with you or respond to your enquiries.
HOW DO WE STORE AND HOLD PERSONAL INFORMATION?
We store most information about you in computer systems and databases (including cloud service providers) operated by either us or our external service providers. No information about you is recorded in paper files and physical storage
We implement and maintain processes and security measures to protect Personal Information which we hold from misuse, interference, or loss, and from unauthorised access, modification, or disclosure.
These processes and systems include:
(a) the use of identity and access management technologies to control access to systems on which information is processed and stored;
(b) requiring all employees to comply with internal information security policies and keep information secure;
(c) requiring all employees to complete training about information security; and
(d) monitoring and regularly reviewing our practise against our own policies and against industry practice.
We will also take reasonable steps to destroy or de-identify Personal Information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the applicable law.
WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO, AND WHY?
We may transfer or disclose your Personal Information to our related companies.
We may disclose Personal Information to external service providers so that they may perform services for us or on our behalf, which includes our outsourced service providers (such as Google, Microsoft, NetEffects, Zoom Info and WIX)
We may also disclose your Personal Information to others where:
(a) we are required or authorised by law to do so;
(b) you have expressly consented to the disclosure, or the consent may be reasonably inferred from the circumstances;
(c) we need to share it with data processors to operate our business and provide products and services to our customers for your benefit;
(d) you have consented to the disclosure of your Personal Information for marketing purposes; and
(e) we have shared it with our other subsidiary companies and related companies located overseas as part of delivering products and services to our customers for your benefit.
If the ownership or control of all or part of our business changes, we may transfer Personal Information we hold to the new owner.
DO WE DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
We may disclose your Personal Information to recipients which are located overseas.
Those recipients are likely to be our staff in our related companies, our overseas contractors, and consultants. These overseas recipients are located around the world, but the ones who will primarily have access to your Personal Information are located in Canada, Philippines, United Kingdom, Australia, New Zealand, United States of America and Singapore.
WHERE IS YOUR PERSONAL INFORMATION STORED?
DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING?
We may use your Personal Information to offer you products we believe may interest you, but we will not do so if you tell us not to. These products may be offered by us, [our related companies, our other business partners or our service providers.]
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
HOW TO ACCESS TO AND CORRECT YOUR PERSONAL INFORMATION?
You may access or request correction of the Personal Information that we hold about you by contacting us directly. Our contact details are set out below. Please understand there are some circumstances in which we are not required to give you access to your Personal Information, but we will advise you if these circumstances apply to your request.
There are also circumstances where we may not be able to correct the Personal Information that we hold about you, particularly if our customers have collected that information.
There is no charge for requesting access to your Personal Information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct Personal Information in a reasonable time and will take all reasonable steps to ensure that the Personal Information we hold about you remains accurate, up to date and correct (where we have control to do so).
YOUR RIGHTS UNDER THE EU GDPR
Under the European Union (EU) General Data Protection Regulation (GDPR), as a data subject (if you are a citizen or resident of the EU) you have the right to:
(a) access your data;
(b) have your data deleted or corrected where it is inaccurate;
(c) object to your data being processed and to restrict processing;
(d) withdraw consent to having your data processed;
(e) have your data provided in a standard format so that it can be transferred elsewhere; and
(f) not be subject to a decision based solely on automated processing.
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your Personal Information, you should contact us. Our contact details are set out below.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
If you have any questions, comments, requests, or concerns, please contact us at:
phone: 1300 724 667
address: Level 5, 606 St Kilda Rd, Melbourne, VIC 3004
CHANGES TO THIS POLICY