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Red Planet Software

PRIVACY POLICY

 

OUR PHILOSOPHY

This following document sets forth the Privacy Policy for the Red Planet Software Pty Ltd website, www.redplanetsoftware.com.

Red Planet Software is committed to protecting and respecting your privacy by handling all personal information securely and with care, in accordance with the Australian Privacy Principles (the APPs) as set out in the Privacy Act 1988 (Cth) (the Act). The APPs regulate the manner in which personal information is collected, used, disclosed, stored, accessed, corrected and disposed of.

We have adopted this Privacy Policy to ensure that we comply with the APPs. The Policy provides an overview of the types of information held by us, as well as our information handling practices, procedures, and systems.

Please read the Policy carefully to ensure that you understand our practices regarding the management of any information you disclose to us.

 

WHAT IS ‘PERSONAL INFORMATION’ AND ‘SENSITIVE INFORMATION’?

‘Personal Information’ is any information or an opinion about you that identifies you or that could reasonably identify you. This could include information such as your name, contact detail, date of birth or employment details.

‘Sensitive Information’ is any information or opinion about you which is health information or which relates to your racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record. The APPs place more stringent obligations on us when we handle your sensitive information.

 

WHAT INFORMATION DO WE COLLECT?

The Personal Information and Sensitive Information that you disclose to us or which we obtain from third parties enables us to provide and facilitate services to you. We will only collect and retain information that is reasonably necessary for the performance of our activities and functions so that we are able to provide you with the services you require or which we recommend to you.

The kinds of Personal Information and Sensitive Information we collect and hold depends on the specific services provided to you, but will generally include basic personal contact information, as well as other information that is deemed relevant. This will usually include the following:

  1. your contact details (name, postal address, email address, etc.)
  2. non-personally identifiable information (browser type, version and language, operating system, page access times etc).

If you do not provide us with the required information, we may not be able to perform the services which you require us to provide.

 

HOW WE COLLECT AND HOLD PERSONAL AND SENSITIVE INFORMATON

During the course of providing our services to you, we will collect Personal Information and Sensitive Information from you by asking you verbally for that information, or requiring you to complete forms or documents necessary to enable us to provide you with our services.

We will take reasonable steps to store information in a secure manner, protected by a combination of physical and technical measures. Information that we store electronically, is stored in a local server/secure cloud-based facility based in Australia. This information is secured and access is limited to necessary employees and subcontractors of Red Planet.

We will take all reasonable steps to protect the security of your Personal Information and Sensitive Information held by us. This includes appropriate technology to protect your Personal Information and Sensitive Information stored electronically, such as passwords, as well as limiting the number of personnel who have access to your Personal Information and Sensitive Information, whether stored electronically or in hard copy.

To limit the possibility of human error, we will regularly provide training to our staff regarding the collection, storage and handling of your Personal Information and Sensitive Information.

When we no longer require your Personal Information and Sensitive Information, it will be destroyed or permanently de-identified. However, we will retain information for as long as the law requires.

 

WHAT HAPPENS IF THERE IS A DATA BREACH?

A data breach is when Personal Information and/or Sensitive Information held by us is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference. Examples of a data breach are when a device containing personal information of clients is lost or stolen, an entity’s database containing personal information is hacked or an entity mistakenly provides personal information to the wrong person. A ‘data breach’ may also constitute a breach of the Privacy Act, however this will depend on whether the circumstances giving rise to the data breach also constitute a breach of one or more of the APPs.

We have a data breach response plan. Our actions in the first 24 hours after discovering a data breach are crucial to the success of our response. A quick response can substantially decrease the impact on the affected individuals.

However, despite our reasonable efforts, we cannot guarantee that the security of your Personal Information and Sensitive Information will not be breached. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to a data breach, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.

 

HOW WE USE YOUR PERSONAL AND SENSITIVE INFORMATION

We may use your Personal Information and Sensitive Information for the following purposes:

  • to confirm your identity;
  • to contact you directly about our services;
  • to share it with our related entities, subsidiaries or other specialist providers as required to perform functions on our behalf;
  • for other purposes communicated to you when your information is collected;
  • for disclosures required by law, regulation or court order; and
  • to provide data to Government departments and agencies as required when providing you with the services;
  • to conduct internal client research and assessment; and

This includes us using this information to communicate with you about our services, for internal administration, direct marketing and planning purposes. We will also use your personal information for purposes related to those described above which would be reasonably expected by you. You may request not to receive direct marketing communication from us.

We will not use your Personal Information and Sensitive Information for purposes other than those described above, unless we have your consent, or there are specified law enforcement or public health and safety reasons (as permitted under the Act).

 

TRANSFER OF PERSONAL AND SENSITIVE INFORMATION

We may outsource business functions to other organisations and as such, it is possible that your Personal Information and Sensitive Information will, as required from time to time, be disclosed or transferred to other organisations to allow them to assist us to provide you with services. In doing so, we will take reasonable steps to ensure that any outside organisations are bound by privacy obligations protecting your personal information, and that they will only be provided with the personal information required to deliver their services.

We will disclose your Personal Information and Sensitive Information to overseas recipients as and when required in order to provide you with the services. If we transfer your Personal Information outside Australia, we may endeavour to comply with the requirements of the Act that relate to transborder data flows, but we cannot guarantee compliance and you specifically agree that you understand this. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to our non-compliance with APP 8.1, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.

You should also be aware that:

  • any overseas recipient may not be subject to any privacy obligations or to any principles similar to the APPs;
  • you may not be able to seek redress in the overseas jurisdiction; and
  • any overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

While we will not directly disclose your Personal Information and Sensitive Information to overseas recipients without your consent, the entities to which we may disclose your Personal Information and Sensitive Information may do so. We are unable to say what countries, if any, those recipients are likely to be located in as the locations will differ from time to time.

 

THE EUROPEAN GENERAL DATA PROTECTION REGULATION

When we receive Personal Information or Sensitive Information from individuals in the European Union (the EU), we will be required to comply with the European General Data Protection Regulation (GDPR).

The GDPR applies to data processing activities of processors and data controllers outside of the EU, regardless of size, where the processing activities are related to:

  • offering goods or services to individuals in the EU (irrespective of whether payment is required); and/or
  • monitoring the behaviour of individuals in the EU, where that behaviour takes place in the EU.

The GDPR requires us to comply with seven principles with regards to processing Personal Information and Sensitive Information. To that end, we can confirm that we:

  • process your Personal Data lawfully, fairly and in a transparent manner as outlined in this Privacy Policy;
  • only collect Personal Information for specified, explicit and legitimate purposes and not further process in a manner that is incompatible with the purposes as disclosed by us in this Privacy Policy;
  • only collect Personal Data that is adequate, relevant and limited to what is necessary in relation to the purposes outlined by us in this Privacy Policy;
  • will take every reasonable step to ensure that Personal Information is accurate and up to date and any inaccurate data is erased or rectified without delay;
  • will not store Personal Information for longer than is necessary for the purposes as outlined in this Privacy Policy;
  • will process your Personal Information in a manner that ensures appropriate security of the information, as outlined in this Privacy Policy, as such processing methods are sufficient in protecting the information against accidental loss and destruction or damage; and
  • take full accountability for compliance with all of the above.

We are required, under the GDPR, to obtain your express consent to the processing of your Personal information in the form of a signed document. We confirm that we will require you to physically sign and return any document that we require in this regard. If you do not sign and return such document, we will not be able to collect your Personal Information which may mean we cannot provide you with certain goods or services.

 

COOKIES AND WEB BEACONS

If you are accessing this Privacy Policy via our website, we may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our website with personal information, this information may be linked to the data stored in the cookie. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing our website.

If you are accessing this Privacy Policy via our website, we may use web beacons on our website from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

 

LINKS TO OTHER WEBSITES

If you are accessing this Privacy Policy via our website, our website may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites will not be governed by this Privacy Policy and we recommend that you seek out their privacy policy when redirected to a third party website to ensure that you are aware of how they may use your personal information.

 

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy discloses our current privacy practices. From time to time and in line with client expectations and legislative changes, this Privacy Policy will be reviewed, and, if appropriate, updated at any time without notice. We will endeavour to provide you with notice of the changes as soon as reasonably practicable to do so.

 

HOW TO CHANGE OR ACCESS THE INFORMATION WE HOLD ABOUT YOU

You can access the Personal Information and Sensitive Information we hold about you.

We will take reasonable steps to ensure that any Personal Information or Sensitive Information that we collect, use, store or disclose, is relevant, accurate, complete and up-to-date. If you believe the information we hold is inaccurate, incorrect, or incomplete, you may request that your information be corrected and we can then take reasonable steps to correct this information.

Please contact our Privacy Officer (details below) to access or request updates to any Personal Information and/or Sensitive Information which we hold or to request erasure of the information we hold.

 

COMPLAINTS

If you have a complaint about the way we have dealt with your Personal Information or Sensitive Information, or about this Policy itself, we invite you to provide written details of your complaint to our Privacy Officer (contact details below).

Our Privacy Officer will contact you within 14 days of the date we receive the written details of your complaint to acknowledge that we have received it. Our Privacy Officer will then:

  1. review the way we dealt with your Personal Information and/or Sensitive Information;
  2. conduct an internal investigation (if necessary) into how your Personal Information and/or Sensitive Information came to be handled in the way that it was; and
  3. provide a report to you within one month of the date we acknowledged receipt of your complaint.

If you believe we have breached the APPs, you may also lodge a complaint with the Office of the Australian Information Commissioner.

 

CONTACT US

Should you have any queries, complaints or comments about this Privacy Policy, please contact our Privacy Officer in writing by post or email at:

POST: Attention: The Privacy Officer
Red Planet Software Pty Ltd (ABN: 52 104 371 280)
Level 26, 44 Market Street
Sydney NSW 2000
AUSTRALIA
EMAIL: This email address is being protected from spambots. You need JavaScript enabled to view it.
TELEPHONE: +61 2 9091 8095

 

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