GDPA MEMBER PRIVACY COMPLIANCE PORTAL
PAIR CONNECT GROUP
HEREIN REFERRED TO AS THE (ENTITY)
SINCE 1ST SEPTEMBER 2020 CERTIFICATION NUMBER: 80326
We are 100% committed to protecting your data, the same way we wish our own personal data to be protected by others. If you have any concern, please reach out to us. Our policy herein is designed to meet our local Data Privacy Regulation, including regulations of other jurisdictions where applicable. Should you find any aspect which does not meet our obligation towards you, please feel free to let us know via the Communication Options provided at the end of this page and we will address the matter accordingly.
CONSENT FORM
We request your consent to use the personal data you enter below. This permits us to fulfill our obligations to you. At anytime you can exercise your RIGHTS regarding your personal data that we may have in our possession. We never request excessive personal data/information just for the sake of it and are able upon request to justify the reason as to why we are requesting such data/information and its purpose.
If you are under our minimum age of consent which is 18 years of age, your details will be permanently deleted within 5 working days if it has not been forwarded by your Guardian.
APP PRIVACY POLICY
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 have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act).
The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A full copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au
Information on this site is provided for Australian residents only.
This Privacy Policy explains the information/data we gather about you, what we use that data for, and who we share it with. It also sets out your rights in relation to your information and who you can contact with your queries.We also tell you why we are able to process your information, whether you have to provide it to us and how long we store it for.
This privacy policy applies to the processing of data provided or collected online, through our sites and applications where this privacy policy is posted whether on our digital properties, or on applications we make available on third-party sites or platforms including:
website: https://pairconnectgroup.com
This policy also incorporates our obligations to comply with privacy regulations on how we collect and process your personal data via offline methods including in person, when sending physical hard copy data/information via postal services/courier (air/sea/road) and all other applicable offline methods.
By providing us with your data, you warrant that you are over the minimum age of consent. If you are not over the minimum age of consent, please provide parental, carer or guardian consent.
We the ENTITY are the data controller and are responsible for your personal data (referred to as “we”, “us” or “our” in this policy).
HOW CAN YOU CONTACT US?
If you have any questions or concerns about your privacy, you can contact us using the “Communication Options” found below. Should you have any complaints, we would be grateful if you contact us first.
WHAT INFORMATION DO WE COLLECT?
We collect, hold, use and disclose personal information for our business purposes. We may collect personal information from clients, customers, employees, job applicants, contractors and other individuals.
By providing us with your information data, you warrant to us that you are over the age of consent as defined in the Consent Form above.
Personal Information: The type of personal information we collect, hold and use will vary depending on what information we need to perform our functions and responsibilities. This includes but is not limited to:
• Your contact details including your: name, username, mailing address, email address, job title, department and phone numbers.
• Your shipping, billing and payment details.
• Information necessary to deliver customer service or technical support.
• Website analytics data created by your use of our websites.
If we don’t need your information anymore, we will anonymise or delete it.
HOW DO WE COLLECT PERSONAL INFORMATION?
Where it is reasonable or practicable to do so, we will collect your personal information directly from you. At all times we try to only collect the information we need for the particular function or activity we are carrying out.
We collect data about you through a variety of different methods including:
• Direct interactions.
• Filling in forms on our site (or otherwise).
• Communicating with us in person, by post, phone, email or otherwise.
• Ordering our products or services.
• Creating an account on our site.
• Subscribing to our services or publications.
• Requesting resources or marketing be sent to you.
• Entering a competition, prize draw, promotion or survey.
• Giving us feedback.
Automated technologies or interactions: As you use our sites, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. For further details regarding cookies, please see cookies tab below.
Sometimes we will collect personal information from a third party or a publicly available source. When this occurs, we rely on the person providing us with that personal information having the right to do so. We don’t guarantee website links or policy of authorised third parties.
HOW DO WE USE PERSONAL INFORMATION?
We will only use your personal information for the primary purpose for which it was initially collected, or for purposes that are directly related to one of our functions or activities. We may use your Information to:
• Provide our services to you.
• Manage your account, transaction history, entitlement to products, services, and events.
• Provide you upon request with commercial quotes for our products and services.
• Execute a contract between us.
• Manage your purchase transactions and provide you with customer and technical support.
• Send you product information, technical alerts, updates, promotions or offers applicable to our business.
• Analyse and improve the quality of our websites, products and services.
• Enable interoperability within our applications.
• Comply with a legal or regulatory obligation.
We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Like many other businesses in Australia, we may rely on third party suppliers or contractors to provide specialised services such as web hosting, cloud computing technology and data storage services . If personal information is provided to these suppliers and contractors in order to enable them to perform the agreed tasks, we will make every effort to ensure that the supplier or contractor handles the personal information in accordance with the Act and the Australian Privacy Principles. We will also require all suppliers and contractors to provide privacy undertakings and enter into confidentiality agreements.
We may disclose your information to the following third parties and in the following circumstances:
1. If you expressly agree to any use or disclosure.
2. When we use it for the purpose for which it was collected.
3. To our related bodies corporate and franchises.
4. To franchisees who assist us in operating our business and providing our products and services.
5. To suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes.
6. Where disclosure is required or authorised by law.
7. In circumstances where you would reasonably expect information of that kind being passed to a third party.
8. If it is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (e.g. Police, ASIC, Immigration Department ).
9. To organisations involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including maintaining or upgrading our computer systems.
10. To companies in our group who provide IT and system administration services and undertake leadership reporting.
11. To service providers who provide IT and system administration services.
12. To professional advisers including lawyers, attorneys, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
13. To Revenue & Customs, regulators and other authorities based in our Country and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
14. To Third Parties whom we sell, transfer, or merge parts of our business or our assets.
You may choose to deal with us anonymously or under a pseudonym where lawful and practical. Where anonymity or use of a pseudonym will render us unable to provide the relevant service or do business, we may request that you identify yourself. For example, when you subscribe to our services, it is essential that we record your name accurately.
If you do not provide us with the personal information as described above, some or all of the following may happen:
1. We may not be able to provide the requested products or services to you, either to the same standard or at all.
2. We may not be able to provide you with information about products and services that you may want.
3. We may be unable to tailor the content of our websites to your preferences, thus your experience of our websites may not be as enjoyable or useful.
We may occasionally be provided with personal information which has not been requested or solicited. Where this occurs we will comply with the requirements regarding dealing with unsolicited personal information set out in APP 4.
If permitted or required by law, we may keep records of this information. If not, we will destroy or de-identify the information when practicable, lawful and reasonable to do so.
We may disclose personal information to our related bodies corporate and third-party suppliers and service providers located outside Australia for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to third party suppliers within Australia, who provide specialised services such as web hosting, cloud computing technology and data storage services. These suppliers may store data on servers located outside Australia. It is not practicable to list every country in which such overseas recipients may be located.
The Act and corresponding APPs require us to ensure that, before disclosing personal information overseas, reasonable steps are taken to ensure that overseas recipients do not breach the Act or the APPs (APP 8.1). Whilst we take reasonable steps to ensure this, it is not always possible to ensure that overseas recipients will comply. We do not take any responsibility for the actions of overseas third-party recipients of personal information. In the event that a disclosure is made in an overseas country, the information will not be protected by the Australian Privacy Principles. By providing your details, you consent to your information being disclosed in this manner.
By providing us with personal information and thereby agreeing to this privacy policy, you consent to us using and disclosing your personal information off-shore and agree that APP 8.1 will not apply to such use or disclosure. If at any time you wish to withdraw your consent, contact us using the communication options provided below. However, we may not be able to provide the products &/or services you have requested in whole or in part or those products &/or services may have to be modified.
Government-related identifiers are identifiers that have been assigned by a government agency include an individual’s licence number, Medicare number, passport number and tax file number.
We do not disclose any government related identifiers, for example by using a tax file number as a client reference for filing purposes.
From time to time, we may also use your personal information to tell you about products and services we think may be of interest and value to you, but we will stop if you tell us to.
We may contact you by various means, including by mail, telephone, email, SMS or other electronic means, such as through social media or targeted advertising on our website. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
If you do not want to receive direct marketing offers from us, you can opt-out by:
• Submitting an opt-out request on the Privacy Requests Portal below or
• Using opt-out facilities provided in the marketing communications.
Once your request has been received, we will then ensure that your name is removed from our mailing list in a timely manner and as required by the regulation.
It is an important to us that your Personal Information is up to date. If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, you may request that we amend it. You may submit a correction request via our Privacy Requests Portal found on this privacy policy.
Please advise us as soon as you are practicable able, so we can update our records and ensure we can continue to provide quality services to you.
You may request access to any personal information we hold about you at any time via our Privacy Requests Portal, found on this privacy policy. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be disclosed on our website. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you reasons for any refusal.
In order to protect your Personal Information, we may require identification from you before releasing the requested information.
We are committed to keeping your personal information secure and safe. Your personal information may be stored as hard copy documents or electronically. It is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
Some of the ways we do this are:
1. Requiring employees and service providers to enter into confidentiality agreements.
2. Securing hard copy document storage, e.g. storing hard copy documents in locked filing cabinets.
3. Implementing security measures for access to our computer systems.
4. Ensuring that personal data is stored securely using modern software for online security and that is kept-up-to-date.
5. Limiting the access of personal data to personnel who need access and appropriate security shall be in place to avoid unauthorised sharing of information.
6. Ensuring when deleting personal data, to do so safely, securely and in such a manner where that the data is irrecoverable by any means.
7. Having in place appropriate back-up and disaster recovery solutions.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
We the Entity have defined the social media platforms we are found on in section 1 INTRODUCTION.
Separate to our policy herein, we also adhere to the privacy conditions related to us and placed upon us by each of the social media platforms.
Here are the links to the privacy policies provided by the social media platforms we are or may become members of and to other social media platforms which you may find useful;
You may find it beneficial and/or of interest in reading them, so you can understand on how they protect your data and where applicable any provisions they place upon us the Entity in protecting your data.
We have processes in place to investigate data breaches involving personal information and will notify you of a data breach where we are required to do so under local legislation or as is otherwise appropriate in the circumstances.
Where notification is required, we will do so promptly and as required by the regulation (within 30 days) . We will notify the Privacy Commissioner if we reasonably believe that your personal information has been subjected to a data breach that is likely to result in serious harm to you.
Where appropriate, we may also notify other third parties of a data breach.
If you believe you have fallen victim to a data breach through one of our digital platforms, report the breach to us via the “Report a Data Breach” tab below and we will act on your notification promptly.
WHAT IS A COOKIE?
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
HOW DO WE USE COOKIES?
We may use cookies to track your use of our Social Media/Web Sites (SMS). This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want. In doing so, we ensure that:
1. Non-essential cookies (e.g. social sharing tools or pixel trackers) are not set to automatically run on the landing page of our site or applications.
2. User’s have full control in configuring their cookie preferences and can make changes at any time.
3. Analytics cookies, targeting cookies and marketing cookies are triggered by user consent.
4. Consent is backed up by demonstrable organisational and technical measures that ensure a user’s expression of consent (or withdrawal) can be effectively acted on.
5. If a cookie is used to store a record that a user has given consent to the use of cookies, this cookie’s lifespan will be no longer than 6 months.
6. Any cookie banner or pop-up provides a compliant experience by requesting explicit consent and providing additional information regarding cookie usage, rather than using wording such as “by continuing to use the site, you consent to the use of cookies.”
7. Any cookie banner or pop-up is not designed in a way that “nudges” a user into accepting cookies over rejecting them. In practice, if there is an “accept” button on the banner, the banner must give equal prominence to a “reject” button, or to an option which brings users to a second layer of information and allows them to manage their cookie settings.
8. Second layers of information provide more detailed information about the types and purposes of cookies or other technologies being set, and the third parties who will process information collected when those cookies and similar technologies are deployed. It provides users with options to accept or reject such cookies/similar technologies by cookie type and purpose, e.g., via check-boxes that are not pre-checked, or sliders that are not be set to “on” by default.
Cookies are either:
• Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
• Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
• Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
• Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
• Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
Please note third parties who advertise on our SMS (including, for example, the owner/operators of the SMS, affiliates, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
HOW TO BLOCK COOKIES?
Cookies are a nemesis to all and we apply our best efforts applying cookies that permit us to perform our legitimate interest in being able to service you and to improve the functionality and flow of our business. Should you feel uncomfortable with our cookies, you may disable them via your chosen browser following the instructions provided via the following links. Please note that disabling cookies may interrupt the flow of your information to us and not permit us to meet our obligations to you:
• how to disable cookies on chrome
• how to disable cookies on firefox
• how to disable cookies on edge
• how to disable cookies on mac
• how to disable cookies on ipad
• how to disable cookies on iphone
• how to disable cookies on phone
• how to disable cookies on opera
• how to disable cookies on internet explorer
• how to disable cookies on safari
OUR COOKIE LIST
Below is the list of cookies we use. All Cookies are leveraged to provide site functionality, analytics, advertising and profiling (if applicable) to ensure you get the best experience possible.
COOKIE LIST: PAIR CONNECT GROUP
STILL HAVE CONCERNS ABOUT COOKIES?
If you are still not comfortable with the cookies we use, feel free to reach out to us via the COMMUNICATION OPTIONS below, and we will do our best to put any concern you may have to rest.
If you consider that there has been a breach of the Australian Privacy Principles, you are entitled to complain to us via the COMMUNICATION OPTIONS below.
We will acknowledge receipt of a complaint within 5 business days. We will investigate the complaint and attempt to resolve it within 30 business days after the complaint was received. Where it is anticipated that this time-frame is not achievable, we will contact you to provide an estimate of how long it will take to investigate and respond to the complaint.
If you consider that we have not adequately dealt with a complaint contact us using the communication option provided. If you find our response inadequate you may complain to the Office of the Australian Information Commissioner on the below details:
Postal Mail: Officer of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 2001, Australia
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
This policy was last updated 18th of August, 2022
DATA BREACH REGISTER
CYBER SECURITY REGISTER
COMMUNICATION OPTIONS
Company: Pair Connect Group
Address: 430 Little Collins Street
City: Melbourne
State: VIC
Postcode: 3000
BUSINESS PHONE NUMBER
☎ Business Hours: 0403 711 556
BUSINESS HOURS
★ Monday to Friday
★ 9am to 5pm
★ Excluding Public Holidays
Title:
Name:
Email:
Phone:
We have declared ourselves to the applicable Supervisory Authorities.
Following is a detailed list of all Supervisory Authorities: