This document describes how Business Switch Pty Ltd ABN 83 134 235 304 (we or us or our) complies with the requirements of the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and any other applicable privacy laws in Australia in respect of the website www.trusts.com.au (Website).
Collection of personal information
- What kinds of personal information do we collect and hold?
The kinds of personal information that we collect and hold include names, contact details and other information that is relevant to our functions and activities. We do not collect sensitive information.
In the event that we receive an application for a tax file number or an ABN, we may collect other personal information such as Tax File Numbers or other personal information relevant to such functions and activities.
We do not use government related identifiers as our own identifiers.
- How do we collect personal information?
We usually collect personal information directly from individuals.
In some instances, we may collect personal information about individuals from third parties or publicly available resources, such as Government websites, to check information.
We may also collect your personal information from your authorised agent who submits an application for a trust deed on your behalf or an applicant who identifies you as a settlor, appointor, trustee or beneficiary in respect of the trust.
We may collect your personal information when you communicate with us, such as when you:
- make inquiries about us, our services or contact us for any other reason so that we can process, deal with and respond to your queries or other issues including any complaints; or
- submit an application for a trust deed; or
- apply for a tax file number or ABN;
- use our Website; or
- subscribe to a newsletter, fill out a form or survey, enter or participate in any promotions; or
- call our call centre and your call is recorded by us for quality review purposes.
Any personal information collected on our Website will state to the user that personal information is being collected.
- What happens if you do not provide your personal information to us?
If you do not provide personal information that we request in connection with our activities, we may not be able to provide our products or services to you.
- Why do we collect, use, hold and disclose your personal information?
We collect, use, hold and disclose your personal information as necessary for purposes directly related to our functions and activities, including:
- names and contact details to provide our services to you and information about our services; and
- names, contact details, transaction and experience information such as information on your transactions and our communications with you, for direct marketing including promotions and newsletters.
We track traffic patterns throughout the URL registered to us.
We use "cookies" on our Website. A "cookie" is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser, but not you. If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our Website, but not all services may be available.
We may automatically collect general statistical information on our Website about visitors to our Website, such as IP addresses, browsers used, dates visited, pages visited and number of visitors. However, such information does not refer to individuals by name or their contact details. We use this data in aggregate to improve our Website. We may provide such aggregated data to third parties, but in so doing, we do not provide personal information without the individual's consent.
Will we disclose personal information to anyone else?
We may disclose personal information to:
- our related companies;
- payment processors such as PayPal or Stripe;
- nominated representatives authorised to act on our behalf in processing your application; and
- professional service firms providing services to us, such as legal, accountancy or marketing services as well as data hosting and technology firms.
We may also provide your information to others, if required or permitted to do so by law, in accordance with the APPs.
We will only disclose your personal information:
- with your consent; or
- for a purpose which you would reasonably expect; or
- as required or permitted by law; or
Do we disclose personal information overseas?
We may disclose your personal information overseas to a service provider in the Philippines.
Unsubscribing from our marketing materials
- Unsubscribing from email lists
At any stage, should you wish to stop receiving any of our emails that we send to you for marketing or promotional purposes, simply click on the “Unsubscribe” link at the bottom of the email.
- Unsubscribing from hard copy promotional materials
When we send you hard copy promotional materials, such materials will include instructions on how you may unsubscribe from receiving such materials.
Dealing with us anonymously or using a pseudonym
You may deal with us on an anonymous basis or by using a pseudonym when making inquiries through our Website, or when you make general inquiries by telephone and do not require a further response from us. However, we may need certain contact details from you to respond to inquiries.
Generally, we will require your personal information in order to transact with you.
We use industry-standard methods and take such steps as are reasonable to protect your personal information from unauthorised access, modification or disclosure and from misuse, interference and loss.
Among other techniques, we usually:
- store such information on a computer behind our "firewall" in a secure location;
- restrict the number of employees internally who can access such data; and
- keep hard copies of documents in lockable cabinets in a secure location.
Once personal information is no longer required by us for the purposes for which it was collected or held or otherwise in accordance with the APPs, we will take all steps as are reasonable in the circumstances to ensure that it is either destroyed or de-identified.
Access, Correction and Removal of your Personal Information
You may seek to access or correct your personal information at any time by contacting the Privacy Officer by email to email@example.com or by mail to the 'Privacy Officer, Level 23, Governor Phillip Tower, 1 Farrer Place, Sydney NSW 2000.
If we do not agree to provide you with access to your personal information or to amend or annotate the information we hold about you, you may seek a review of our decision.
If we do not agree to make the requested changes to your personal information, you may make a statement about the requested changes and we will attach it to your record.
You can send written complaints about a breach of the APPs in relation to your personal information by email to firstname.lastname@example.org or by mail to 'Privacy Officer', Level 23, Governor Phillip Tower, 1 Farrer Place, Sydney NSW 2000.
Complaints will be reviewed by our Privacy Officer and a response will usually be provided within 30 days of receipt of the complaint.
If you believe that your complaint has not been satisfactorily addressed by us, after following the procedure set out above, you can make a complaint to the Office of the Information Commissioner (OAIC). The OAIC's contact details are here.
For more information about making a complaint, contact us at email@example.com .
*As amended 28 April 2015.