A. Privacy Statement
The Search Provider (“we/our”) is committed to protecting user privacy. We understand that visitors and users of our sites, software services and Microsoft add-ins may be concerned about their privacy, and the confidentiality and security of any information that is provided. To address concerns about unauthorised use of personal information, we seek to comply with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, as well as the privacy requirements of individual Government agencies and non-Government suppliers.
GlobalX has adopted this policy outlining how personal information is collected, stored, used, disclosed and accessed under the Privacy Act 1988 (Cth).
C. What kind of personal information do we collect and hold?
We primarily collect information from:
- Corporate entities (as our customers are mainly business entities);
- Individuals such as our customers, contractors and other people who will come into contact with us; and
- Third parties such as Government agencies and other entitles which hold information about individuals and entities.
Personal information is any information that can identify you. It is defined under the Privacy Act 1988 (Cth) as: “Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.”
An example of this kind of information collected would be names, telephone numbers, addresses, email addresses and credit card information.
Sensitive information is a sub-category of personal information (and is subject to stricter rules of disclosure) which we may also collect. It is defined under the Privacy Act 1988 (Cth) as:
- information or an opinion about an individual’s:
- racial or ethnic origin; or
- political opinions; or
- membership of a political association; or
- religious beliefs or affiliations; or
- philosophical beliefs; or
- membership of a professional or trade association; or
- membership of a trade union; or
- sexual orientation or practices; or
- criminal record that is also personal information; or
- health information about an individual; or
- genetic information about an individual that is not otherwise health information; or
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- biometric templates.
It is unlikely that we would collect sensitive information.
D. How do we collect and hold personal information?
Collection of Personal Information
We collect personal information about our customers primarily through our User Application form, online ordering forms, face-to-face meetings, interviews and telephone calls.
We do collect some information about visitors indirectly through standard web logs. This may include information about IP address browsers being used, as well as domain names. Some data may be traceable to an individual, but we do not normally seek to identify individuals unless we believe that someone is using our sites improperly.
We will generally collect this kind of personal information directly from the individual concerned or a professional acting on their behalf (e.g. their lawyer).
We will also collect personal information about individuals from government databases and external information holding databases. In the event where personal information is collected from a third party such as these, we will assess whether it has been collected in a manner that satisfies the Australian Privacy Principles. If it could not have been collected in this manner, we will take steps to, as soon as possible, destroy or de-identify the information, where it is lawful and reasonable to do so. If it could have been collected in this manner, we will deal with it in compliance with the Australian Privacy Principles.
Holding Personal Information
We hold personal information in electronic data storage devices owned or controlled by us. These storage facilities are secured in the manner as described in this Policy.
Where we obtain personal information from external information holding entities (such as Government databases), we will generally provide it through our servers it to a requesting third party (e.g. another lawyer). In these cases we generally do not retain the personal information.
Anonymity and Pseudonymity
You may wish for personal information to be kept anonymously or under a pseudonym. Where it is practicable or lawful for us to, we will do so at your request. However, given that we are usually supplying third party information to you (such as Government records), we would usually be unable to deliver the information to you if you do not provide us with your identity. If you would like to discuss information being made anonymous or under a pseudonym, please contact our Privacy Officer.
E. What is the purpose of collection and what do we do with the information?
Purpose of Collection
Personal information is collected for the primary purpose of enabling us to provide our services to our customers (this includes to both regular customers and Pay As You Go (PAYG) customers).
Personal information collected via our User Application forms and online Ordering Forms is used for:
- Forming our customer database;
- Day-to-day administration;
- Marketing; and
- To satisfy our legal obligations.
Some personal information may be collected about prospective employees or contractors for the purpose of deciding whether we wish to engage that person.
Once a prospective employee becomes an employee of the GlobalX Group, their personal information is excluded from the scope of the Privacy Act 1988 (Cth), as employee records are not covered by that Act.
We will only use the sensitive information we collect for the purpose for which it was collected or a directly related purpose, unless you indicate that you do not wish for us to disclose this information, or where the use or disclosure is allowed by law.
Personal information of our customers is never shared, sold, rented or otherwise disclosed outside of the GlobalX Group (save for any statutory or legal requirement) except where a business unit may be sold. GlobalX’s primary goal is to improve the quality and nature of its services and we may use your personal information to deliver you targeted and non-targeted marketing information about our goods and services. At any time you may opt-out of receiving marketing communications from us.
If you do not provide the information to us that we request, we may be unable to provide our services to you.
Access to Information
It is a function of our business to provide information to a requesting third party. To do this, we commonly act as an intermediary to access and obtain personal information held about an individual by external sources and provide this information to a requesting third party.
F. Overseas disclosures
We do not usually disclose personal information to overseas recipients. It is possible, however, that we may be required to disclose personal information about an individual to overseas recipients if requesting third parties are located overseas. Any such disclosure will be in accordance with the Australian Privacy Principles.
G. How do we use "cookies" and "log files"?
H. What do we do to safeguard personal information?
We are serious about the security of your personal information and take all reasonable steps to maintain the security of any personal information we hold. We have implemented steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure by use a variety of secure techniques to protect your information, including secure servers, firewalls, password protected access rights to computerised records, database encryption and SSL.
I. Currency, Access and Correction of Personal Information
Under the Privacy Act 1988 (Cth), you have the right to obtain access to any personal information which GlobalX holds about you and to advise GlobalX of any perceived inaccuracy. We also seek to ensure that the personal information we hold is accurate, complete and up-to-date.
To make a request to access, to update or to request the correction of any personal information we hold about you, you must contact the Privacy Officer in writing at:
1300 885 662
The Privacy Officer
GlobalX Information Pty Ltd
GPO Box 2746
Brisbane QLD 4001
GlobalX may charge a fee to cover the cost of responding to your request for access to personal information, and may require payment of this fee in advance of the personal information being provided (but will not charge a fee for the making of the request).
J. Contact and Complaints
Any complaints regarding an alleged breach of your privacy rights must first be made directly to us in writing:
1300 885 662
The Privacy Officer
GlobalX Information Pty Ltd
GPO Box 2746
Brisbane QLD 4001
After receiving a complaint, we will follow the following procedure:
- The Privacy Officer will investigate a complaint and report to our Chief Executive Officer;
- A decision will be made and you will be advised in writing of our determination within 30 days of the complaint;
- If you are not satisfied with our response or do not receive a response within 30 days of having made the complaint, you may make a complaint to the Office of the Australian Information Commissioner.