Businesses - NGIS Australia Pty Ltd, Liveli Pty Ltd, Yira Technology Solutions Pty Ltd, Winyama Pty Ltd, NGIS EU Limited, Yarnda Foundation Limited
Brands – Next Mile Location Technology, TraceMark, IMW Australia, EO Data Science
1 Personal Information Policy
1.1 What is personal information?
Personal information is information or an opinion that identifies you as an individual or from which your identity can be reasonably identified (regardless of whether the information or opinion is true or not or recorded in a material form or not). The types of information that constitutes personal information, and that we may collect, include your name, email, address, and other contact information.
1.2 What is the purpose for collecting personal information?
We only collect personal information that is reasonably necessary for our business functions and activities. This may include using your personal information to process services or any requests you may have, notify you of important changes to our services, comply with record keeping requirements, advise you of products and services that may interest you (unless you have declined to receive such communications in accordance with section 4 below) or to verify your identity. Various laws may require or authorise us to collect your personal information.
We may also keep records of communications containing personal information (including recordings of telephone calls and emails) for the purpose of staff training. If we do not collect your personal information, we may not be able to provide you with our products or services.
1.3 How do we collect personal information?
We can only collect personal information about you by a lawful and fair means. We may collect information from you directly, such as when you complete a form including an online form, a contract or make an inquiry. We may also collect your personal information indirectly from third parties such as our related companies, introducers, or service providers.
1.4 How do we collect information on our websites?
For marketing purposes our websites may use UTM tags. UTM tags or UTM codes are a way to analyse website traffic or marketing campaigns from other platforms or AdWords campaigns and how you interact with our websites. To do this a ‘tag’ is added to the end of a URL which provides data to Google Analytics.
1.5 Using and disclosing personal information
We only hold, use and disclose personal information about you for the purposes outlined in section 1.2, or for related purposes which might be reasonably expected, unless we otherwise obtain your consent. To do this, we may disclose your personal information to entities within the NGIS brands.
If we are holding your personal information in connection with suspected fraud, misconduct or unlawful activity, we are not required to give you access to that personal information if we reasonably believe that such access would prejudice the taking of appropriate action in those circumstances. On some occasions, we may be obliged to disclose your personal information by law, e.g. court order or statutory notices pursuant to any legislation, and to government authorities.
1.7 Business without identifying you
In most circumstances it will be necessary for us to identify you to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with your personal information, for example, if you make general inquiries about interest rates or current promotional offers.
2 Direct marketing
From time to time, we may use the personal information collected from you for direct marketing purposes, such as targeted advertising on new services and other information which we think you may find interesting. If we do contact you in this way, it will only be in relation to matters that customer would reasonably expect us to contact them directly about. We will ensure that our marketing activities comply with applicable laws. We may contact you by telephone, email or SMS for these purposes. You acknowledge that your personal information will be disclosed to other Entities within the Group, who may tailor marketing to you by combining personal information about you, which is held by those Entities with personal information we have disclosed. If you do not wish to receive any direct marketing communications from us, you may at any time decline to receive such information by contacting us as set out in Part 8 below. You can also follow the instructions for unsubscribing in our direct marketing communications. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
We do not sell personal information to third party organisations to allow them to contact you for direct marketing purposes.
3 Keeping personal information secure
Your personal information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the personal information we hold about you. The security of your information is very important to us, and we have security measures to protect any personal, credit or sensitive information that we hold.
Before disclosing personal information to a customer, we confirm the identity of that customer to prevent misuse or unlawful disclosure of the information.
We have security measures to ensure the physical security of personal information held on our premises and systems. When records containing personal information are no longer required, we delete the information or permanently de-identify it. In relation to data stored or transmitted electronically, we regularly review developments in security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as completely secure. We take all reasonable steps to protect the information in our systems from misuse, interference, loss, and any unauthorised access, modification, or disclosure.
We take reasonable steps to preserve the security of cookie and personal information in accordance with this policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).
3.2 Data breaches
A data breach occurs if personal information that the Group or its Entities hold is subject to unauthorised access or disclosure or is lost. We will take all reasonable steps to prevent a data breach from occurring.
A data breach will be notified to you and the Australian Privacy Commissioner (Commissioner) if:
• There is unauthorised access to or disclosure of your personal information.
• The unauthorised disclosure is likely to result in serious harm to you; and
• We have been unable to prevent the likely risk of serious harm with remedial action.
We will also conduct an assessment if it is not clear if a suspected data breach meets the above criteria. The assessment will determine whether the data breach is an ‘eligible data breach’ that triggers notification obligations to you and to the Commissioner.
Once you are notified about a data breach that we have assessed as an eligible data breach, you are encouraged to take steps to reduce your risk of harm, through measures such as changing passwords and being alert to identity fraud or scams.
4 Access and correction of personal information
You are entitled under the Privacy Act to access the personal information we hold about you and (if it is reasonable and practicable) to do so in a manner that you request.
We will need to validate the identity of anyone making an access request, to ensure that we do not provide your information to anyone who does not have the right to that information.
We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances, it may take longer (for example, if we need to contact other entities to properly investigate your request).
There may be situations where we may refuse to provide you with access, such as where the information relates to existing or anticipated legal proceedings, if the request is vexatious or if the information is commercially sensitive. If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.
We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs.
If you feel that the personal information, we hold about you is incorrect, you can contact us at any time to request that we correct that information. If you would like to do so, please contact our Privacy Officer using the contact details in Part 8 below.
If appropriate we will correct the information at the time of the request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information. We may need to consult with other entities as a part of our investigation (including other credit providers or CRBs). We will normally try to resolve correction requests within 30 days of you making a request. There will be no cost to you if we correct your personal information held by us.
If you believe that we have not complied with our obligations relating to your personal information (Including your credit information and sensitive information), please contact our Privacy Officer as follows:
By phone: (08) 9355 6000 between 9am and 5pm Monday to Friday
By email: Accounts@ngis.com.au
We will investigate your complaint and respond within 30 days with a proposed resolution.
If you feel we have not properly dealt with a complaint, you may contact the Office of the Australian Information Commissioner at firstname.lastname@example.org or on 1300 363 992.
You can obtain a copy of the current version on request.
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