1. Privacy Act
1.1 The Privacy Act 1988 (Act) requires entities bound by the Australian Privacy Principles (APPs) to have a privacy policy in place. The Peregrine Group (we, us or our), is an organisation and an APP entity for the purposes of the Act, and are committed to the APPs contained in the Act.
1.2 This Privacy Policy outlines the personal information handling practices of the Peregrine Group and provides a general overview of our policies in respect of the collection, handling, disclosing and management of your personal information in the course of our day-to-day operations.
1.3 Personal information is any information or opinion about you that identifies you or is capable of identifying you, even if the information is not true and also includes information that is in a physical form and information that is not.
1.4 By providing us with your personal information you agree to the terms and conditions in this Privacy Policy and understand that we may update this Privacy Policy when our collection, handling, disclosing and management practices change.
1.5 If you have any queries about our management of your personal information, you are encouraged to contact our Privacy Officer for further information (see section 13 below).
2. Exemptions
No general exemptions under the Act apply to us or to any of our acts or practices.
3. Collection of your Personal Information
3.1 The personal information we collect from you will depend on the dealings we have with you, but we will limit the information we collect to what is reasonably necessary for us to provide you with products, promotions and services we have in-store and online.
3.2 The personal information we collect may include, but is not limited to, your name, contact details, delivery address, date of birth, in-store CCTV camera images, details of enquiries you make or feedback you provide us with.
3.3 When collecting personal information, we will take reasonable steps to make you aware of the purposes for which the information is collected, the organisations to which we may disclose your information, the consequences if you fail to provide the requested information, and whether we are likely to disclose your information to overseas recipients.
3.4 We will, whenever possible, collect personal information directly from you and will take reasonable steps to provide you with reasons for the collection of your personal information.
3.5 We may at times receive personal information from third parties and will notify and provide you with details relating to the personal information collected and the manner in which it was collected. We will also determine if we are entitled to receive the information and will treat such information in the manner set out in this Privacy Policy. We will destroy or de-identify all personal information received from third parties which we are not entitled to hold.
3.6 We do not collect sensitive information from you, unless you consent to the collection of the information or if we are required to do so by law.
4. Storage and management of your personal information
4.1 The personal information we hold is stored in a secure manner and encryption technologies are used to safeguard transactions and personal information. Our customer data is protected against misuse, loss, unauthorised access and modification or disclosure.
4.2 We will endeavour to destroy or de-identify your personal information as soon as it is no longer required by us (as permitted by law).
4.3 We have a data breach response plan in place, this will allow us to respond to data breaches in an effective and timely manner, allowing us to contain such a breach and reduce the risk of unauthorised access, disclosure or loss of personal information.
5. Use
5.1 We will use your personal information for the purpose for which we collected it, and for related purposes we consider will be within your reasonable expectations. If we use your personal information for any other purpose we will first obtain your consent before we use your personal information, unless we are required or permitted by law to do so without obtaining your permission.
5.2 We generally collect, hold and use your personal information to:
5.2.1 provide the service requested, respond to your inquiries, send you information that you request, or otherwise achieve the purpose for which the information was submitted to us;
5.2.2 contact you to ask about your experiences with, or impressions of, our products or services.
5.2.3 contact you from time to time to advise you of new products, promotional offers, or services offered by us or our dealers that we consider may interest you;
5.2.4 conduct market research or monitor product demand (although where possible we will use “de-identified” information that does not refer to particular individuals when conducting these activities);
5.2.5 contact you about other matters relating to products or services that you have acquired from us;
5.2.6 streamline and personalise your experience within our website, or tailor our information, services or products;
5.2.7 create aggregate data about our web site visitors and other statistics to allow for more efficient operation of our website;
5.2.8 engage in other activities where required or permitted by law; and
5.2.9 undertake any purpose related to any of the above.
5.3 We may use personal information to contact you for direct marketing and promotional purposes. You may at any stage opt-out from receiving these communications by contacting our Privacy Officer or using the opt-out function provided for in the communications. If you do not opt-out in either of these ways you will be taken to have consented to receiving such communications from us.
5.4 There are no consequences for opting out of receiving our marketing and promotional communications and you may elect to rejoin our marketing list at a later stage.
6. Disclosure of Personal Information
6.1 We do not routinely disclose your personal information to any other person or organisation unless you agree to it. Your personal information will only be used for the purpose for which we collected it, or related purposes we consider within your reasonable expectations. We may disclose your personal information to:
6.1.1 our authorised agents, contractors or subcontractors that provide administrative or promotional services (for example, mail processing businesses, printers, or market research companies or other service providers). We typically enter into contractual agreements with these organisations to ensure that information we disclose is used only for the limited purposes for which we have provided it; and
6.1.2 our related bodies corporate within the Peregrine Group.
6.2 If we propose to disclose your personal information for any other purpose, we will first obtain your consent, unless we are required or permitted by law to do so without seeking your permission.
6.3 If we need to disclose personal information to overseas recipients (for instance storing data via a cloud service or where delivery address information for online orders is managed via a third party located overseas), we will comply with the APPs in disclosing your personal information overseas including taking such steps as are reasonably necessary in the circumstances to ensure that the overseas recipient does not breach the APPs.
7. Online Privacy
This part of our Privacy Policy sets out the manner in which we handle your personal information in respect of online services provided to you. Online collection includes any services we provide via the internet, mobile applications and email.
7.1 Automatic collections and cookies: Our website server automatically collects various items of information when you use our website and may attach a “cookie” to your computer’s memory. A “cookie” assists us to store information which is used to improve our website and your online experience by monitoring your usage of our website and to provide information on items you may be interested in. This information is used for statistical analysis, system administration and similar related purposes; we do not use this information to identify you. Third parties may also use these “cookies” to collect non-personal information about your use of our website and may use it to deliver online advertising to you. You may of course choose to configure your computer to disable “cookies” and you may choose to accept “cookies”. The settings in your internet browser software can be adjusted to prevent cookies being stored on your computer, if required. However, some of the features of our website may then not be available to you. If you choose not to have “cookies” placed on your computer, please set your browser preference to reject “cookies” before accessing our website.
7.2 Third party advertising: We may at times use “Remarketing” (https://support.google.com/adwords/answer/2453998?hl=en-AU) to advertise online. Third party vendors, including Google may show our ads on sites across the Internet.
7.3 Email and Message Forms: We may collect personal information from you (such as your name, address, telephone number and email address, and any other personal information you volunteer) if you send us an email or if you submit information to us using a message form, or brochure request form or feedback form. We will use this personal information to contact you and provide you with a response to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations. We will not use or disclose any such information for any other purpose without your consent.
7.4 Social networking sites: We use social networking services such as Twitter, Facebook and YouTube to communicate with the public about our products and services. When you communicate with us using these services we may collect your personal information, but we only use it to help us communicate with you and the public. The social networking service may choose to handle your personal information for its own purposes and should have their own privacy policy in place, which we encourage you read before making use of the social network service.
7.5 Storage and Transmission of Personal Information Online.
7.5.1 If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
7.5.2 If we receive your personal information, we will take reasonable steps to store it such that unauthorised access, modification, disclosure, misuse and loss are prevented.
7.6 Mobile applications
7.6.1 When you use our On The Run App or other applications in place from time to time (App) we collect and use technical information about the mobile device used to access the App and its related software and hardware for services that are internet based or wireless in order to improve the App and to provide services to you.
7.6.2 The App may make use of location data sent from your mobile device. You can turn off this functionality at any time by turning off the location service settings for the App on your mobile device.
7.7 Other Online Services: If any of our online services (including any email messages we send to you) contain links to other online services that are not maintained by us (other services), or if other services link to our online services, we are not responsible for the privacy practices of the organisations that operate those other services, and by providing such links we do not endorse or approve the other services. This Privacy Policy applies only in respect of our online services.
7.8 Third Party Advertising
7.8.1 We may allow third parties to use cookies or other tracking technologies to collect non-personal information about your use of our website, including your IP address, pages viewed and conversion information. This information may be used, among other purposes, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and other websites tracked by these third parties.
7.8.2 This Privacy Policy does not apply to, and we are not responsible for, third party “cookies” or other tracking technologies. We encourage you to check the privacy policies of advertisers and/or ad services to learn more about their privacy practices.
8. Collection via Careers Section
8.1 Personal information collected via our website careers/jobs section will only be used for the purpose of recruitment by recruitment companies we appoint from time to time.
8.2 The information you submit to us may be disclosed to referees, those of our staff who are involved in recruitment, security organisations, recruitment agencies and other third parties who assist us in the recruitment process. If you choose not to provide any of the information requested, we may be unable to send you information, fully process your application or properly consider you for employment.
8.3 Any information we collect about you via our website, or otherwise in relation to the recruitment process, will be used and disclosed in the same manner as described in this Privacy Policy unless we tell you otherwise.
8.4 Personal information received from successful applicants will be stored in our staff records file. Personal information received from unsuccessful applications will be destroyed within a reasonable time from assessing the application.
9. Access to and Correction of Personal Information
9.1 You may contact our Privacy Officer to request access to or correction of your personal information held by us. Contact details for our Privacy Officer are set out in section 13 below. You will be required to verify your identity before we will allow you to access your personal information, for the protection of your privacy and the privacy of others.
9.2 Making such a request is free, but we may require you to pay a fee in order to access your personal information held by us. We will advise the amount of the fee payable (if any) once we have assessed your application for access. This fee is based on the cost of providing you with access to your personal information (for example, photocopying costs). It is not a fee for lodging a request for access to or correction of your personal information.
9.3 We may refuse to allow you to access or to correct your personal information if we are legally required or entitled to do so. If this is the case, we will provide you with written reasons for the refusal (unless it is unreasonable to do so) and the options available to complain about the refusal. We will endeavour to respond to your request for access or correction within 30 days from receiving your request.
9.4 If you lodge a request for access, we may provide you with access to your personal information in any of a number of ways (including, for example, supplying you with a copy or providing you with the opportunity to inspect our records).
9.5 We will take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, up-to-date and complete. If we are satisfied that any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will amend our records accordingly.
9.6 Please notify us if our records need to be updated.
10. Dealing with us Anonymously
You may deal with us anonymously or using a pseudonym, but this may limit our ability to provide products and services to you.
11. Changes to our Privacy Policy
We reserve the right to amend this Privacy Policy at any time by uploading the updated Privacy Policy to our website. You may also obtain a copy of the current version of our Privacy Policy by contacting us. We encourage you to read our Privacy Policy each time you deal with us so that you are aware of any changes made to it.
12. Complaints
If you believe that a breach of your privacy has occurred or you otherwise have a complaint about our use or management of your personal information, we encourage you to contact our Privacy Officer to discuss your concerns. Contact details can be found in Section 13 below. Your complaint will be considered and dealt with by our Privacy Officer. Please allow us a reasonable time to respond to your complaint. If you are not satisfied with our resolution, you may make a complaint to the Office of the Australian Information Commissioner whose contact details can be found at: www.oaic.gov.au .
13. Further Information
You may contact our Privacy Officer if you require further information about the ways we manage your personal information.Privacy Officer [email protected]
