In this Policy, Airguides, we, our or us is a reference to Hopolla Group Pty Ltd (ACN: 610 092 754).
Personal information is any information about a person where their identity is apparent, or can reasonably be ascertained, and includes Sensitive Information (Personal Information).
Sensitive Information is information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences, health or medical information or criminal records (Sensitive Information).
2. What this Policy is about
This Policy covers Personal Information collected directly from individuals, (Users).
We endorse fair information handling practices and uses of information in compliance with our obligations under the privacy laws in force in Australia from time to time. Any information provided, including identification of individuals, will be used only for the purpose/s intended and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.
This Policy represents the default position that we will take in our treatment of Personal Information. We will treat all Personal Information in a manner consistent with this Policy unless you have provided your express consent otherwise.
3. Collection of Personal Information
The Company collects the following Personal Information:
- Personal Information about our employees, contractors and job applicants, including name, address, contact details and work experience;
- Personal Information of subscribers to our weekly newsletter including name and email address;
- Personal Information about Users, including name and contact details and information volunteered through online discussion tools such as blogging, reviewing, commenting and forums.
Personal Information will be typically collected when provided directly to us by you through our website www.airguides.com (Website).
Our Website automatically collects anonymous usage data about visitors, including the URL that the visitor came from, the browser being used and the IP address. This data is utilised to improve our services and does not include any personally identifying information.
'Cookies' are alphanumeric identifiers that are stored by the web browser on a computer's hard-drive that enable our system to recognise a visitor to our Website. This helps us to track basic visitor information for the purposes of optimising the design of our systems and marketing activities.
Most web browsers automatically accept cookies and this function can be disabled by changing the browser settings of the user.
4. Use of Personal Information
The Company uses Personal Information in the following ways:
- for our own internal administration purposes, for example entering into employment contracts, processing payroll and recruiting new staff;
- for sending weekly newsletters and other occasional marketing materials to subscribers;
- to display the authorship of posts;
- to market the Website or features of the Website to users; and
- to communicate with users. For example, if we wish to feature a post written by a user, we may use Personal Information to contact that user for their permission to do so.
We may also use Personal Information we collect for related purposes such as:
- to record information about a User’s usage, preferences and behaviour, as well as any feedback provided by Users;
- to perform statistical analyses of user behaviour;
- to optimise marketing activities, user experience, and content;
- protecting individuals and users from fraud; and
- any other use for which we obtain permission from you.
As a user of our products or services, Users may occasionally receive email, promotional material or other updates from us about new information, briefings or products or services being offered by us or any of its related companies or business partners, along with newsletters and any noteworthy changes to the Website.
5. Disclosure of Personal Information
Other than disclosure to service providers (explained below) or as required by law (for example, disclosure to various Government departments or to Courts), our policy is that we do not give Personal Information to other organisations unless we have disclosed the use in this Policy or you have expressly consented for us to do so.
The parties we may share Personal Information with are our employees, subcontractors, suppliers and affiliates on a need to know basis. Access to Personal Information will be revoked within a reasonable timeframe of access no longer being required.
Occasionally, we might also use Personal Information for other purposes or share Personal Information with another organisation because:
- we believe it is necessary to protect your rights, property or personal safety;
- we believe it is necessary to do so to prevent or help detect fraud or serious credit infringements - for example, we may share information with other, credit reporting agencies, law enforcement agencies and fraud prevention units; or
- we believe it is necessary to protect our interests – for example, disclosure to a Court in the event of legal action to which we are a party;
When we share information with other organisations and service providers as set out above, we do so in accordance with this Policy. To the extent that these organisations and service providers gain access to Personal Information, their use is governed by the provisions of the Privacy Act 1988.
6. Confidentiality and Data Security
The Website and its data, including Personal Information including any Sensitive Information you provide to us, will be stored on secure servers located outside Australia.
We take all reasonable steps to manage data stored on our servers to ensure data security and to prevent the loss, misuse or alteration of Personal Information. Notwithstanding the above, we are not responsible for any third-party access to Personal Information as a result of:
- interception while it is in transit over the internet;
- an unpatched vulnerability, a zero-day vulnerability, or an attack within 48 hours of a vendor releasing a patch or update;
- spyware or viruses on the device (such as a computer or phone) from which Users access the Site; or,
- as a result of a User’s failure to adequately protect their user name or password.
We are also not responsible for any losses, expenses, damages and costs, including legal fees, resulting from such third-party access.
7. Retention and Disposal of Personal Information
We will retain Personal Information for as long as is required for us to fulfil the purposes for which the Personal Information was collected, including to comply with legal requirements.
If we no longer require Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify the Personal Information.
Personal Information is backed up frequently and tested regularly in line with our standard backup procedures. Personal Information that has been deleted may therefore persist within backups for a period of time after which it falls outside the backup rotation.
8. Access to Personal Information
You can access the Personal Information held about you at any time by contacting our Privacy Officer using the contact details in clause 10.3 below.
We will always endeavour to meet requests for access. However, in some circumstances we may decline a request for access. This includes the following circumstances:
we no longer hold or use the information;
- providing access would have an unreasonable impact on the privacy of other persons;
- the request is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
- providing access would be unlawful;
- providing access would be likely to prejudice the detection, prevention, investigation and prosecution of possible unlawful activity; and
- the information would reveal other User’s Personal or Sensitive Information.
If we decline a request for access, we will provide reasons for our decision when we respond to the request.
We reserve the right to charge you a reasonable fee for access to your Personal Information. These charges will be limited to the cost of recouping our expenses for providing you with your Personal Information, such as document retrieval, photocopying, labour and delivery.
9. Changing or deleting Personal Information
We will take reasonable steps to ensure that Personal Information is accurate, complete and up-to-date at the time of collecting the Personal Information from you or during other interactions with you.
If you believe that any Personal Information we hold about you is inaccurate, incomplete or out-of-date, you may contact our Privacy Officer. If we have collected your personal information on behalf of a Client, we may request that you contact the Client in the first instance.
We will do our best to correct any Personal Information that is inaccurate, incomplete or out-of-date or dispose of it in accordance with this Policy.
If you have a complaint in relation to the way your Personal Information has been handled by us, the complaint should be made in writing to our Privacy Officer in the first instance. We will investigate the complaint and prepare a response to you in writing within a reasonable period of time.
Our Privacy Officer can be contacted at firstname.lastname@example.org.
From time to time, our policies will be reviewed and may be revised. We reserve the right to change this Policy at any time.