Aviator Group Pty Ltd* (“we” / “us”/ “our”) takes their obligations to protect personal information seriously. We are bound by Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APP”) (together, “the Privacy Act”).
the kind of personal information that we collect and hold about you;
- how we collect your personal information;
- how we hold your personal information;
- the purposes for collecting, holding, using and disclosing your personal information;
- how you may access your personal information held by us and correct that information where it is incorrect;
- how you may make a complaint about the way we collect, hold, use or disclose personal information, and how we will deal with Privacy related complaints; and
- whether we will (or are likely to) disclose your personal information to overseas recipients and the countries where such recipients may be located.
This Policy applies to any individual no matter how they interact with us (e.g. on-line, in person or over the phone) or in what capacity they interact with us (e.g. as an individual, representing another person or representing a company).
We will usually be able to interact with an individual anonymously or using a pseudonym if the interaction is general in nature, however, if the interaction is more specific we will need to identify the individual.
This Policy will be kept up to date and published on the Aviator Group Pty Ltd website.
The kinds of personal information we collect and hold about you
We offer a wide range of products and services and we may collect and hold a range of personal information about you. We are likely to collect information about many types of individuals such as customers and prospective customers, employees, contractors, prospective employees and contractors, suppliers, agents, service providers and the people who represent the businesses we deal with.
The type of personal information we collect and hold may vary depending on the nature of our interactions with the individual and our relationship with them. This information can include financial information, credit related information, identification information, banking details and employment information. We will collect and hold name and contact information of all the individuals that we deal with.
In order to satisfy our legal obligations, we may need to retain your information after a transaction or a relationship has come to an end; however we will not retain your identifiable personal information longer than is reasonably necessary and allowable under Australian law.
Some elements of personal information are also referred to in the APP as sensitive information, for example, health information. We will only collect sensitive information with your consent or when permissible under Australian law and we will only use this information for a legitimate purpose where this is reasonably necessary.
How we collect your personal information
Wherever it is possible and practical to do so, we will collect personal information directly from you, this may be in person, over the telephone, by mail, over the internet, by e-mail or fax, or by completion of a form (such as an application form).
We may also collect your personal information from a third party. This will be limited to circumstances where it is impracticable or unreasonable for us to collect it from you. The type of third party who might provide information to us will vary depending on the nature of the business and interaction with you.
Whilst this is not an exhaustive list, we may obtain your personal information from the following sorts of third parties:
- an authorised representative (e.g. accountant, solicitor or other person acting on an individual’s behalf);
- another employee of an organisation (e.g. if a person representing a business we deal with wants us to interact with another individual within that business);
- a referee (for job applicants);
- a recruitment consultant (for job applicants);
- a licenced credit reference agency; and
- one or more of our related companies here or overseas.
How we hold your personal information
We understand the importance of protecting the personal information we hold about you. Given this we are focused on protecting your personal information from misuse, interference, loss, unauthorised access or modification by:
- securing all personal information;
- limiting access to personal information to those that need access; and
- protecting our systems with appropriate technology and security solutions.
The purposes for collecting, holding, using and disclosing your personal information
We collect, hold, use and disclose your personal information in order to interact with you. This includes managing and administering the products and or services we provide to our customers whether they are individuals or businesses. You may be a customer, contractor, job applicant, supplier, partner or party with whom we do or have done business, or may do business in the future. You may be acting on your own behalf of as a representative of a company or business.
Marketing and Events
Your personal information may also be used or disclosed in the course of us advising you, or the business that you represent, of products and services that may be of interest to you or that business or in inviting you or others to attend events organised by us. By puchasing a product or enquiring to purchase a product from us you consent to us sending you: pre-departure commercial elecronic messages to assist us deliver our service to you, post-departure commercial electronic messages to assist us undertake market research and deliver product updates, and commercial electroinic messages that we believe may be of interest to you. You may unsubsribe to our communications to you at any time by clicking on the unsubscribe link provided on communications from us.
If you do not want your personal information to be used for these purposes you should tell us so that we can action this request. We may be contacted for this purpose at:
Sales and Marketing Co-ordinator
How you may access your personal information held by us and correct that information where it is incorrect
You are entitled to access the information we hold about you. Simple requests are best handled by speaking to the person you usually contact when dealing with us. More complex request may be better detailed in writing to ensure we fully understand and are able to respond accurately to the requests.
If there is a reason we are unable to agree to a request for access to your personal information we will advise this in writing. Some examples of why we may refuse a request for access include, where providing the information:
- may pose a threat to the health or safety of an individual or the public;
- may have an unreasonable impact on the privacy of another individual;
- is not allowed by law; or
- may reveal internal information relating to a commercially sensitive decision making process.
If information we hold about you is incorrect we would like to know so that we can promptly correct this. To do this please contact us in the manner indicated above.
In certain situations, we may not agree to a request to correct information we hold about you, if this occurs we will advise of this and our reason for not agreeing to the correction request.
How you may make a complaint about the way we collect, hold, use or disclose personal information, and how we will deal with Privacy related complaints
If an individual wants to make a complaint about our handling of personal information, they should provide details of the complaint using the contact information below:
If the complaint is not resolved it may be referred to the Office of the Australian Information Commissioner (the “OAIC”) the contact details for the OAIC are:
The Office of the Australian Information Commissioner
GPO Box 2999
Canberra ACT 2601
Phone: 1300 363 992
Fax: 02 9284 9666
Web site: www.oaic.gov.au
Who we may disclose personal information to
From time to time, we share personal information with our related bodies corporates, as defined in the Corporations Act 2001 (Cth). We may also disclose personal information to non-Aviator Group businesses who provide various services to us. We require all of these businesses to comply with strict confidentiality requirements and the APP.
When we may disclose personal information to overseas recipients and the countries where such recipients may be located
Some Aviator Group Pty Ltd related entities do business with organisations located overseas and technology allows for services to be provided to us by different service providers including some that are located overseas and we do utilise overseas service providers. It is not practicable to list every country in which recipients are located; however, it is likely that the countries to which your information will be disclosed may include the United States of America, Canada, United Kingdom and Singapore.
Tracking information on the web
For statistical purposes, we collect information on web site activity such as the number of users who visit our web sites, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering one of our web sites from another web site, the address of that web site. This information is obtained through the use of ‘cookies’ (refer below for more information about “cookies”).
Our web sites may also contain links to non-Aviator Group Pty Ltd web sites. While these links are provided for convenience, if you are navigating to these sites please be aware that the information handling practices of the linked web sites may differ from ours. While we try to link only to sites that share our high standards and respect for privacy, we are not able to guarantee the privacy practices of other web sites.
For statistical purposes, we collect information following the dispatch of a mass market communication in the form of an email such as the number of times the email has been opened, which hyperlinks within an email have been opened, whether a person has chosen to unsubscribe to receiving emails from us, and whether an email has been forwarded to another email address. This information is obtained through the use of ‘cookies’ (refer below for more information about “cookies”).
Web site security
Whenever personal information is sent via our web site we use high security levels to protect it. The security level of a web page can be viewed by clicking on the internet browser's padlock or key icon.
A ‘cookie’ is a packet of information that allows a web site to identify and interact more effectively with a computer. Cookies do not identify you, although they do identify your browser type and Internet Service Provider.
Your browser can be individually set to accept all cookies, reject all cookies, or notify when a cookie is sent. If cookies are rejected, there may be limits on how our web sites can be used. To evaluate the effectiveness of our web site advertising, we may use third parties to collect statistical data. No personal data is collected on these occasions.
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