This policy applies to all personal information received by RECOM. Personal information means information or opinion about an identified (or reasonably identifiable) individual.
RECOM’s website may contain links to third party websites, materials, products, services or activities. RECOM is not responsible for the content, privacy practices or policies of such third parties. You should read them carefully before providing any personal information to these third parties.
How and what personal information is collected or received
Personal information may be collected or received from you by RECOM in different forms (e.g. in hard copy, by email or other electronic communication or verbally) and in various ways, whenever you interact or transact with RECOM, including:
- when you order or request to receive services from RECOM, including services available online (Digital Services);
- when you seek to provide services to RECOM or transact with RECOM (as a supplier, contractor, consultant, purchaser, agent or other);
- when you apply for a job with RECOM;
- when you submit an application, form, request or complaint to RECOM;
- when you provide data or instructions to RECOM;
- when you visit or use RECOM’s website.
Examples of personal information that may be collected or received by RECOM include:
Customer Information: information you provide for the purpose or in the course of receiving services from RECOM or accessing Digital Services, including your name, ABN, postal address, email address, phone and fax number, and information related to the services provided (such as nature, time and location).
Supplier Information: information you provide for the purpose or in the course of providing services to RECOM or transacting with RECOM as a supplier, contractor, consultant, purchaser, agent or other), including your name, ABN, postal address, email address, phone and fax number, and information related to the services provided (such as nature, time and location).
Financial Information: can include trading or financial information provided by you to establish a credit account, details of payments for services provided, billing address, bank account details, payment facility details (including information related to cheque, money orders, letter of credit and credit card).
Digital activity related Information: RECOM may receive or collect information produced during or in relation to your activities on RECOM’s website or when using RECOM’s Digital Services, including the content you access or create, web pages you visit, the time, date and login information of your activities (including browser type and language), the location of the communication device and its internet protocol (IP) address (including phone number used and associated carrier).
Cookies information: When you access RECOM’s website or Digital Services through any communication device, a small data file called cookie may be stored on that device. The cookie enables RECOM to improve the quality of service provided to you, for example, by making it easier for you to login again or by tracking your preferences and personalising the services offered to you. You can block or remove cookies via your browser settings but that may impact on your use of the website or Digital Services.
Third Party Information: RECOM may receive, from third parties you interacted with or received services from, information relating to your communications, activities or transactions with them. Such third parties may include service providers of RECOM (contractors, agents, credit reporting agencies, recruiters) and companies related to RECOM.
Job Applicants Information: information provided by job applicants or recruiters including in job applications and accompanying communications, resumes, RECOM Employee Application forms and police checks done by applicants.
CCTV Footage: produced by security cameras installed at RECOM’s offices.
Use and Disclosure of personal information
Personal Information received and collected by RECOM may be used or disclosed, subject to any applicable law, for the following purposes (Primary Purposes):
- To verify your identity;
- To assess or process any request or application submitted by you, including a job application;
- To assess, provide, administer, manage, monitor, review or improve services you have requested to receive, are receiving, or have received from RECOM;
- To assess, administer, monitor, review or improve services you have agreed to provide, are providing, or have provided to RECOM;
- To enable third parties (in Australia and overseas) to provide to you products or services you have requested or receive from you products or services you have agreed to provide;
- To personalise, customise or improve services or products offered to you (directly or through third parties) and your use of RECOM’s website and any Digital Services;
- To provide to you from time to time offers or updates in relation to products, services or benefits that may be of interest to you (including direct marketing materials) unless you indicate that you do not wish to receive such communications;
- To market, provide, develop, maintain, monitor, measure, protect and improve RECOM’s services in general;
- To handle any complaint or respond to any feedback received from you;
- To protect, defend or enforce the rights of RECOM or third parties (including defending RECOM against potential or existing legal claims);
- For any purpose you agree to;
- For any purpose related to the above purposes that can reasonably be expected by you.
- You have no obligation to provide personal information to RECOM but if you choose not to provide certain information it may prevent, limit or affect, RECOM’s ability to provide services to you, receive services from you, process an application or form submitted by you, or address a complaint lodged by you.
Occasionally, RECOM may use or disclose your personal information to communicate to you special offers and promotions relating to products, services or benefits, which RECOM believes may be of interest to you. Such direct marketing communications may be verbal (by phone) or written (by email, text, or via the Digital Services). You can request RECOM not to send you such communications by using any opt-out method outlined in these communications or by contacting RECOM at any time (see Contact details at the end of this policy).
Disclosure or transfer of personal information
RECOM will not use or disclose to third parties your personal information for purposes other than the Primary Purposes, or related purposes you would reasonably expect, unless you have consented to such use or disclosure or it is permitted by law. Third parties to whom RECOM may disclose personal information include, without limitation:
- Entities that are or become affiliated with RECOM such as parent or sister companies, subsidiaries or entities acquiring control of RECOM or merging with RECOM;
- Law enforcement, government and regulatory agencies or authorities.
- Your authorised representatives and advisors if requested by you;
- RECOM’s agents, contractors, service providers or advisors who are acting for or on behalf of RECOM in Australia and overseas in connection with the Primary Purposes, including without limitation:
- Customs agents;
- Transport service providers;
- Credit reporting agencies;
- Debt collectors;
- Marketing and customer service providers;
- Providers of ICT services including servers, storage, routing and website related services;
- Recruiters, lawyers, accountants, tax advisors and professional advisors.
RECOM may retain your personal information for as long as it is needed for any of the Primary Purposes or any other permitted purpose.
Transfer to overseas recipients
Some of the entities mentioned above which receive, use or access, the personal information may be located overseas.
If required by law RECOM will take reasonable steps to ensure that the receiving third parties are committed to protect personal information through applicable privacy and confidentiality obligations.
Sensitive Information and Government Related Identifiers
RECOM does not collect sensitive information about you unless you have consented or it is required by law. Sensitive information includes information about your health, racial or ethnic origin, political opinions, association memberships, religious beliefs, sexual orientation, criminal history, genetic or biometric information.
Government related identifiers (e.g. TFN’s) will generally not be used unless required by law or necessary to complete a transaction or service.
Protecting personal information
RECOM is committed to the protection of personal information and has put in place various security measures (physical, electronic and procedural) to secure the personal information held by RECOM and protect it from unauthorised access, disclosure, or use.
While such measures reduce the risk of security breaches no method of transmitting or storing data provides absolute or perfect protection. RECOM cannot guarantee that personal information will never be accessed, used, or released in a manner that is inconsistent with this policy. To the fullest extent permitted by law RECOM will not be responsible for any such unauthorised access or use or its consequences.
To protect the security and privacy of your personal information you must safeguard any username or password you may have been assigned with in connection with accessing or using the website or Digital Services (“User Details”). You must keep such User Details strictly confidential and not allow anyone to access them and/or use them. You are fully responsible for all activities which occur under your User Details including any security breaches or privacy violations.
Please contact RECOM without delay to inform it of any security concerns you have, or violations you become aware of, including any unauthorised use of your User Details (see Contact details at the end of this policy).
How to access or correct personal information
You may contact us at any time and request to access or correct any personal information RECOM holds about you (using the Contact details at the end of this policy). RECOM will need to verify your identity, may ask for further details before processing your request, and may charge you a fee to cover the reasonable administrative costs involved.
RECOM may refuse your request to access or correct personal information in certain circumstances permitted by law. In such case RECOM will notify you in writing of the reasons for the refusal and advise you of any complaint mechanisms available.
RECOM may retain a copy of any personal information before and after any changes, updates or deletions, to it for internal back up, administration, compliance, enforcement, protection and defence purposes.
You can also ask RECOM to notify any correction made to any entity which the information has previously been disclosed to.
Policy variation and enforcement
No failure or delay by RECOM in exercising any right, power or remedy, conferred by this policy will operate as a waiver of or otherwise prevent the exercise of the right, power or remedy.
Post: PO Box 194, Rose Bay, NSW 2029, Australia
Phone: +61 2 9194 3451
RECOM will respond to complaints within 30 days.
You can also obtain information at the Office of the Australian Information Commissioner’s website: www.oaic.gov.au.
Last updated: March 2017
© ReCom Trading Pty Ltd 2017