Carpe Group Investments Pty Ltd and any of its Related Bodies, as that term is defined in the Corporations Act 2001 (Cth) ("Carpe Group", "we", "us", "our"), are bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act).
We understand the importance of, and are committed to, protecting your personal information.
This Privacy Policy explains how we manage your personal information, including our obligations and your rights in respect of our dealings with your personal information.
"Personal information" is information or opinion about an identified individual, or an individual who is reasonably identifiable.
We collect and hold personal information that is reasonably necessary for, or directly related to, one or more of our functions or activities as the supplier of goods and services. The personal information we collect will depend on the type of dealings you have with us, and that information may include (as well as other information):
"Sensitive information" is information or opinion about an individual which is:
We will only collect sensitive information (including health information) about you with your consent, except where we are required or permitted by law to collect your sensitive information without your consent.
Purpose
Our main purposes for collecting, using, holding and disclosing personal information is to:
We may also collect, use, hold and disclose personal information for any other purpose explained at the time of collection, or:
any other purpose for which you have provided consent.
We do not sell, rent or lease your personal information to third parties.
You have the right to refuse to provide us with personal information, and where it is lawful and practical to do so, we will provide individuals with the option to not identify themselves or to use a pseudonym. However, if you decide not to provide us with personal information, we may be unable to provide you with the products, goods and services you have requested or inquired about.
Method of collection
We only collect personal information by lawful and fair means. We generally collect personal information directly from you. This information may be collected in various ways, including:
Unsolicited information
If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under privacy law if we had requested it, we will destroy or de-identify the information, if it is lawful and reasonable to do so.
Notices
If we have collected personal information about you, we will take reasonable steps to notify you of the collection and of matters relevant to the collection, unless it is obvious from the circumstances that you would expect us to have that information. This notification is generally done by way of a collection notice.
Direct marketing
Where you have given us your express or implied consent, or where we are permitted by law to do so, we may use or disclose your personal information to market our products and services to you.
If you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. Where possible, we will, provide you with a choice to opt-out of any of our direct marketing communications. We will respect any request to decline to receive our marketing communications.
In general, we do not use or disclose your personal information for a purpose other than:
We may also disclose your personal information to other organisations, for example, to:
We take all reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations with respect to the protection of your personal information. We may disclose your personal information to these parties to enable them to assist us in providing our products and services to you.
Overseas recipients
We are unlikely to disclose your personal information to any overseas recipients. If this changes, we will comply with the requirements of the Privacy Act in relation to cross border disclosures of personal information and this Privacy Policy will be amended to reflect those requirements.
Government related identifiers
We will not use any government related identifier (including a passport number or driver's licence number) as our identifier of individuals or otherwise use or disclose any government related identifier unless this is permitted under the Privacy Act (for example, to verify the identity of an individual as required by Australian law).
You may request access to the personal information that we hold about you by contacting us.
We will deal with your request for such access within a reasonable time. If we refuse your request, we will provide you with a written notice which sets out the reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access.
We may recover reasonable costs in relation to a request for access to personal information.
We take reasonable steps to make sure that the personal information we collect is accurate, up-to-date and complete. We take reasonable steps to make sure that the personal information we use or disclose is accurate, up-to-date, complete and relevant. Where we believe that the personal information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will taken reasonable steps to correct that information.
You may also request that we correct your personal information that we hold by contacting us by using the contact details provided above. We will take reasonable steps to correct the information to ensure that it is accurate, up-to-date, complete, relevant and not misleading.
We will deal with your request to correct your personal information within a reasonable time. If we do not agree with the corrections you have requested, we are not obliged to alter you personal information accordingly. However, where we refuse to correct any personal information as requested by you, we will give you a written notice which sets out the reasons for our refusal.
We hold your personal information in paper-based and/or electronic files. We take all reasonable steps to ensure that your personal information which is kept in our files is protected from:
This means that, in respect of our paper-based files, we maintain various security systems on our premises, and in respect of electronic files, we maintain secure electronic network systems.
When we no longer require your personal information (including when we are no longer required by law to keep records relating to you), we ensure that it is destroyed or de-identified.
This section explains how we handle personal information collected from our website. If you have any questions or concerns about transmitting your personal information via the internet, you may contact us, as there are other ways for you to provide us with your personal information.
Visiting our website
Anytime you access an unsecured part of our website, that is, a public page that does not require you to log on, we will collect information about your visit, such as:
"cookie" is a small text file which is placed on your internet browser and which we access each time you visit our website. When you visit the secured pages of our website (ie pages that you have to provide login details to access) we use cookies for security and personalisation purposes. When you visit the unsecured pages of our website (ie public pages that you can access without providing login details) we use cookies to obtain information about how our website is being used.
You may change the settings on your browser to reject cookies, however doing so will prevent you from access the secured pages of our website.
When we receive emails, we will retain the content of the email and our response to you where we consider it necessary to do so.
Your email address will only be used or disclosed for the purpose for which is was provided. It will not be added to any mailing lists or used for any other purpose without your consent.
We make reasonable efforts to ensure that the most up-to-date security measures are used on our website to protect your personal information. Any data containing personal information which we transmit via the internet is encrypted. However, we cannot guarantee that any information transmitted via the internet by us, or yourself, is entirely secure. You use our website at your own risk.
Our website may contain links to third party websites. We advise that the terms of this Privacy Policy do not apply to external websites. If you wish to find out how any third parties handle your personal information, you will need to obtain a copy of their privacy policy.
We may use your personal information, including your contact details, to provide you with information about products and services which we consider may be of interest to you. We may do this even if you are on the Do Not Call Register.
We may also provide your details to other organisations for specific marketing purposes.
You may opt out at any time if you no longer wish to receive marketing information. In order to do so, you will need to request that we no longer send marketing materials to you or disclose your information to other organisations for marketing purposes. You can make this request by using the contact details provided above, or by "unsubscribing" from email marketing messages.
We are generally exempt from the Privacy Act when we collect and handle employee records and this Privacy Policy does not apply to that information. However, where State or Territory health privacy legislation applies, we are still required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.
If we sell or otherwise transfer with all or part of Carpe Group or our business to another organisation (such as in the course of a sale, merger, acquisition, liquidation or receivership), you agree that your personal information that we have collected may be disclosed to a third party, prospective purchaser, insolvency practitioner or transferee and that this is reasonable for the purposes of that party to continue or manage the business.
If you have any questions, concerns or complaints about this Privacy Policy, or our use of your personal information, please contact us. You can also contact us if you believe that the privacy of your personal information has been compromised or is not adequately protected.
Once a complaint has been lodged, we will respond to you as soon as possible.
You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or email: enquiries@oaic.gov.au.
We may make changes to this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our website.
