Supple Solutions Pty Ltd (ACN 160 901 833), its related entities and all other companies within the Supple Solutions group (we or us) are committed to ensuring each individual with whom we deal have their right to privacy protected and maintained. We are also committed to complying with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).
What is ‘personal information’?
Throughout the website, we may refer to ‘personal information’. ’Personal information’ is any information or opinion (regardless of its accuracy) which identifies you, or which is capable of identifying you.
What personal information do we collect and hold?
The type of personal information we collect depends on the type of dealing you have with us and may include:
- your name, gender, date of birth, phone number, postal or delivery address and email address;
- information about the products or services you order or enquire about, including how the products or services are used;
- your financial information (such as credit card and bank account details), method of payment and any additional information required for user authentication processes; and
- any other information relating to you, including the information you provide by email or telephone, or through surveys, competitions, promotions, questionnaires or other promotional activities.
We do not collect your sensitive information (as defined by the Privacy Act). If you have accidentally provided us with your sensitive information, please contact us so it can be deleted.
Furthermore, we may collect non-personal information about you when you visit our website (i.e. the time, date and duration of your browsing session). This data does not include anything pertaining to your identity, and is simply used to maintain the functionality and ease-of-use of this site. We only collect personal information as permitted by the Privacy Act.
You do not have to provide us with your personal information. However, not doing so may limit the functionality of our website or prevent us from completing the purpose for which we have requested the information, such as to provide you with our products or services.
How do we collect personal information?
We collect personal information in several ways, including:
- through your use or orders of our products or services;
- when you visit our website or submit information through the website or contact us (in person, by phone or email, or via the website);
- when you provide information through our surveys, competitions, promotions, questionnaires or other promotional activities; and
- from publicly available sources of information.
The personal information we collect will track and enhance your use of our website or our products or services and assist us in providing a better service to you.
When we collect personal information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection. As a collection notice is specific to a particular collection of personal information, it will provide more specific information about our information-handling practices than this policy.
If you provide us with personal information about another individual (as their authorised representative), we rely on you to:
- inform them that you are providing their personal information to us; and
- advise them that they can contact us for more information.
We may also collect your personal information from third parties and organisations engaged by us to carry out some of our business functions.
Why do we collect, hold and use your personal information?
We only use and disclose your personal information for the purposes for which it is collected, which may include:
- to provide you with our products, services or website;
- to improve, develop, manage and analyse our products, services or website;
- to send you updates about our products, services or website, changes in the SEO landscape or invitations to events;
- to operate, maintain, test and upgrade our systems;
- to verify your identity;
- to customise the advertising and content on our website;
- to provide you with information we think may benefit or interest you;
- to invoice you for our products and services;
- to comply with regulatory or other legal requirements; and
- for any other purpose notified to you at the time of collection.
In order to fulfil the above purposes, we may disclose your personal information to:
- our employees, related entities, business partners, suppliers and agents; and
- third party service providers for the purpose of performing functions on our behalf (and not for any other purpose), including our professional advisors, insurer, marketing and analysis organisations, financial and credit card institutions to process payments, security and technical support specialists, consultants, archive-keeping organisations and regulatory bodies.
Our Affiliates may be located in or outside Australia. We will take reasonable steps to ensure that our overseas Affiliates treat your personal information securely.
By accessing or using our products, services or website, or providing your personal information to us, you freely consent to the transfer of your personal information to our overseas Affiliates.
We will not disclose your personal information to any third party (other than those outlined in this policy) without your written consent, unless we are otherwise required by law, permitted to under this policy or such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of our website.
We may use your personal information to send you information, including about our new or improved products or services, where you have consented to us doing so or we are otherwise permitted to do so by law.
We may send this information to you via mail, email, SMS telephone, social media or by customising online content and advertising on our website. These communications may continue even after you stop using our products or services.
You can opt out by contacting us using the details below or using the unsubscribe function in the communication (where available).
Third Party Tracking
To improve the functionality and performance of this website, we use third-party tracking tools. These tools are specifically made so that they are unable to collect personal information, instead collecting non-specific, aggregate information for statistical analysis. However, as this information is collected by a third party, we are not responsible for what information is actually collected and how the information is used.
This collected data allows us to improve our website’s functionality, on top of facilitating Analytics, Advertising, Behavioral Targeting and Retargeting, alongside the Interaction with external social media platforms.
We will take the following reasonable steps to ensure your personal information is secure, accurate and protected from misuse, interference and loss, as well as unauthorised access, modification or disclosure. However, as with any online or electronic security system, we cannot guarantee the security of any personal information transmitted through the internet, including our website. You provide your personal information to us at your own risk.
For your own protection, some sections of our website may ask for the use of a password. To maintain the strength and protection of this password, we suggest that you update it frequently and not share it with others.
We will destroy or de-identify personal information where it is no longer required, unless we are required or permitted by law to retain the information.
Suspected data breaches
We have procedures in place to deal with any suspected data security breaches, including a comprehensive data breach notification policy and response plan (Response Plan). This Response Plan outlines the steps our personnel are required to take in the event of a data breach, which allows us to identify and deal with a data breach quickly to mitigate any harm that may result.
Where we are required under the Response Plan, we will notify you as soon as practicable if we:
- discover or suspect that your personal information has been lost, accessed by, or disclosed to, any unauthorised person or in any unauthorised manner;
- believe you are likely to suffer serious harm as a result; and
- are unable to prevent the likely risk of harm.
We will also notify the Australian Information Commissioner of the suspected data breach where we are required to do so.
If you would like more information about our Response Plan, please contact us using the details below.
Third party links
We do not endorse any of those third parties, their products or services, or the content on those websites. Supple Solutions cannot make absolute guarantees as to the accuracy of the linked content or the security of any other sites or servers.
Accessing Your Information
You are entitled to access the personal information we have collected about you. This includes lodging requests to access, change or delete your personal information. If you would like to make one of these requests, contact us using the details below and provide details of your request and the relevant personal information. We will do our best to accommodate your requests. We may require proof of identity.
If we do not allow you to access any part of your personal information, we will tell you why in writing.
We will not charge you for requesting access to your personal information but may charge you for our reasonable costs in providing you with access.
- email at firstname.lastname@example.org;
- our online contact form here; or
- mail to Suite 5, 84 Church Street, Richmond, Victoria, 3121, Australia.
We will endeavour to:
- respond to you within 10 business days; and
- investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you.
Further information on your rights to privacy is available from the Office of the Australian Information Commissioner’s website (www.oaic.gov.au).
Last updated: 17 August 2018