In this Policy:
‘Infinite’, ‘Our’, ‘We’ or ‘Us’ refers to Infinite Networks Pty Ltd ACN 097 243 055.
Whose personal information do We collect? We may collect Your personal information from a range of sources, including from You, recruitment agencies, contractors, business partners and government agencies. For example, We may collect Your personal information when You request or acquire a product or service from Us, provide a service or product to Us, apply for employment with Us or communicate with Us via Our website, by e-mail, telephone or in writing.
What types of personal information do We collect and hold? The personal information We collect includes:
- names, addresses, e-mail addresses, phone numbers, payment details, occupation and other information to assist Us in conducting Our business, providing and marketing Our products and services;
- information about staff and directors, as required in the normal course of human resource management and the operation of a business; and
- information about current and previous Infinite suppliers and clients with whom Infinite has
How do We collect personal information? We only collect personal information by lawful and fair means. We usually collect personal information from:
- face-to-face meetings, interviews and telephone calls;
- business cards;
- electronic communications – for example, e-mails and attachments; forms filled out by people, including as part of acquiring a product or service from Us;
- third parties – for example, from recruitment agencies and Your representatives or agents; and
- Our website, including if You use it to contact Us.
Why do We collect personal information? We collect the personal information necessary for Us to provide You with the products and services You have requested from Us; for marketing purposes and to provide You with information about products and services that may be of interest to You; to improve the products and services We provide; and to enable Us to conduct Our business, including meeting Our legal and regulatory obligations. If You do not provide Your personal information, We may not be able to supply the requested product or service, employ You or otherwise deal with You.
Infinite may also collect personal information about You in accordance with Our obligations under the data retention provisions of the Telecommunications (Interception and Access) Act 1979 (Cth).
How We deal with unsolicited personal information? If We receive personal information about You that We have not requested, and We determine that We could not have lawfully collected that information under the APPs had We asked for it, We will destroy or de-identify the information if it is lawful and reasonable to do so.
Do You have to disclose Your identity when dealing with Us? Where lawful and practicable, We will give You the option of interacting with Us anonymously or using a pseudonym.
Use of personal information: We only use Your personal information for the purpose for which it was provided to Us, for related purposes or as required or permitted by law. Such purposes include:
- in the ordinary course of conducting Our business. For example, supplying or acquiring products and services, responding to Your enquiries and feedback, and providing information about Our events, news, publications and products and services that may be of interest to You;
- market research and product and service development, so that We are able to better understand Our customers’ needs and tailor Our future products and services accordingly;
- performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
- employment-related purposes, such as recruiting and providing services to staff;
- as part of a sale (or proposed sale) of all or part of Our business;
- as required or authorised by the Telecommunications (Interception and Access) Act 1979 (Cth) and the Telecommunications Act 1997 (Cth);
- as required by or in accordance with any mandatory industry code or standard registered under the Telecommunications Act 1997 (Cth); and
- other purposes related to or in connection with Our business, including meeting Our legal and contractual obligations to third parties and for internal corporate governance purposes.
Disclosure of personal information: We may disclose, and You consent to Us disclosing, Your personal information to third parties:
- engaged by Us to provide products or services, or to undertake functions or activities, on Our behalf. For example, processing payment information, managing databases, marketing, research and advertising;
- that are authorised by You to receive information We hold;
- that are Our business partners, joint venturers, partners or agents;
- as part of a sale (or proposed sale) of all or part of Our business. For example, We may disclose information to Our external advisers, to potential and actual bidders and to their external advisors;
- such as Our external advisers, and government agencies. For example, where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct; or
- as required or permitted by law.
Marketing use and disclosure: We may use and disclose Your personal information to provide You with information about Our products and services that We consider may be of interest to You. You may opt out at any time if You do not, or no longer, wish to receive marketing and promotional material. You may do this by: contacting Us via e-mail or in writing at the address below and requesting that We no longer send You marketing or promotional material; or where applicable, clicking the “Unsubscribe” button.
Disclosure of personal information overseas: In most cases we do not disclose information to overseas recipients. In the event We do disclose Your personal information to overseas recipients – for example, when storing personal information online or in the ‘cloud’, overseas disclosure will be limited to Singapore. We request You provide Us with written confirmation if You do not consent to your information being disclosed overseas. We will not send Your personal information overseas without obtaining Your consent (this may be implied) or otherwise in compliance with the APPs.
How is my personal information kept secure? We take reasonable steps to protect Your personal information from misuse, interference, loss and unauthorised access, modification and disclosure. Such steps include: physical security over paper-based and electronic data storage and premises; computer and network security measures, including use of firewalls, password access and secure servers; restricting access to Your personal information to employees and those acting on Our behalf who are authorised and on a ‘need to know’ basis; retaining Your personal information for no longer than it is reasonably required, unless We are required by law to retain it for longer; and entering into confidentiality agreements with staff and third parties.
Where We no longer require Your personal information, including where We are no longer required by law to keep records relating to You, We will ensure that it is de-identified or destroyed.
Data quality: We take reasonable steps to ensure that Your personal information is accurate, complete and up-to-date. However, We rely on You to advise Us of any changes or corrections to the information We hold about You. If You consider that the information We hold about You is not accurate, complete or up-to-date, or if Your information has changed, please let Us know as soon as possible.
Access: You may request access to the personal information We hold about You by contacting Us. We will respond to Your request within a reasonable time. We will provide You with access to the information We hold about You unless otherwise permitted or required by law. If We deny You access to the information, We will notify You of the basis for the denial unless an exception applies. Where reasonable and practicable, We will provide access to the information We hold about You in the manner You request. No fee applies for requesting access to information We hold about You. However, We reserve the right to charge a reasonable fee where We do provide access.
Correction: If You believe that personal information We hold about You is incorrect, incomplete or not current, You may request that We update or correct Your information by contacting Us. We will deal with Your request within a reasonable time. If We do not agree with the corrections You have requested (for example, because We consider that the information is already accurate, up‑to‑date, complete, relevant and not misleading), We are not required to make the corrections. However, where We refuse to do so, We will give You a written notice setting out the reasons.
Identifiers: We do not adopt, use or disclose government related identifiers except as required or permitted by law.
Complaints: If You have a complaint in relation to the collection, storage, use or disclosure of Your personal information, please contact Our Privacy Officer using the details below. You will need to provide Us with details of Your complaint, as well as any supporting evidence and information. We will review all complaints received and Our Privacy Officer will respond to You. If You are not satisfied with Our response, You may discuss Your concerns with or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
(a) by email to: firstname.lastname@example.org
(b) by writing to: Privacy Officer, PO Box 316 Deakin West ACT 2600
(c) by telephone: 1300 790 337
Effective date: 1 June 2017