Privacy Policy

 

Application of this Privacy Policy

Op2ma Pty Ltd (“we”, “us” or “our”) will endeavour to comply with the principles specified in this Privacy Policy with
respect to the privacy of any personal information collected through our web sites or any other personal information
which is submitted to us in any form by you or by any person on your behalf.
In this Privacy Policy, references to “you” are references to the individual who is the subject of personal information
submitted to us.
Personal information is any information or an opinion about an identified individual or an individual who is reasonably
identifiable.
This Privacy Policy applies with respect to personal information collected or received by us in relation to individuals
located in Australia or New Zealand.
By accessing and using our sites or by submitting information to us or providing information to third parties which is then
submitted to us, you consent to our collection, use and disclosure of information in accordance with this Privacy Policy.
You may elect not to submit personal information to us but this may mean that we are unable to provide you with any
information, products or services.

Data breaches

We take reasonable security measures to protect personal information in order to minimise the risk of unauthorised
access to that information. Notwithstanding these precautions, data breaches may still occur. We have a data breach
policy which sets out the details of our policy with respect to the handling of any actual or suspected data breach. Our
data breach policy includes commitments to comply with the relevant privacy law requirements relating to notifiable data
breaches (Australia) and mandatory data breach reporting (New Zealand). A copy of the current version of our data
breach policy may be made available to you if we consider you have a reasonable need to review the policy.

Collection and use of submitted information

We may collect and retain personal and other information about you (“submitted information”) when (a) you provide us
with personal information in an email, letter, by telephone, by facsimile transmission, during a meeting or by other
means; or (b) you complete and submit an online form or (c) you access and use our services; or (d) a third party
submits information about you to us; or (e) information is submitted to us automatically as a result of the exchange of
data between systems.
We will only collect information by lawful and fair means.
As long as it is reasonable and practical to do so, we will endeavour to collect personal information about you from you
rather than from a third party.
If we receive unsolicited personal information that could have been lawfully collected by us as solicited information, we
will treat that submitted information in the same way as we treat solicited information.

If we receive unsolicited personal information that could not have been lawfully collected by us as solicited information,
we will destroy or de-identify that information as soon as practicable.
The submitted information which we retain may include your name, address, email address, employer or business name
and address, employment position or work/business role, phone number(s), purchases, product and service enquiries
and other information where it is reasonably necessary for our functions or activities.
If you submit personal information to us, you warrant that you have obtained all necessary consents from the relevant
persons to allow our collection, use and disclosure of that information in accordance with this policy.
You consent to our disclosure of personal information as necessary in order to provide products and services to you.
We may use the submitted information for our normal internal business purposes and to communicate with you
regarding our products and services or the products and services of third parties or for any other reasonable purpose
connected with the operation of our business. You may elect not to receive such communications from us, either at the
time you submit the information or at a later time. If you elect to opt out of any direct marketing, we will comply with that
election. Opt out notifications can be sent to privacy@op2ma.com.au. Our use of submitted information may include
disclosures to the extent necessary to fulfil State and Commonwealth Government reporting and statistical obligations.
We will not sell submitted information to third parties or intentionally disclose submitted information to third parties except
as specified in this policy, as required by law or to the extent that you have consented to such disclosure. This provision
does not apply to the extent that any submitted information has been de-identified before any such use, disclosure or
sale.
We may use a third party to provide hosting or other services such as data integrations and as a result your submitted
information may be collected and stored using physical infrastructure owned by third parties. In these circumstances (a)
we will retain logical control of the submitted information that is stored and processed in our services; (b) the third party
may be permitted to access, use or disclose the submitted information to provide the services (e.g. creating data
back-ups, performing maintenance services or other business functions deemed necessary by the third party service
provider; and (c) the privacy policies applying to any information collected and stored by the third parties are specified
by the third parties and are outside our control. You consent to the collection and use of the submitted information by
third party hosting or other services providers.
We will not disclose private or sensitive information to overseas countries except Australia and New Zealand. To the
extent that personal information is collected.from New Zealand and disclosed by us to any other party in Australia, we
will ensure that the recipient of that personal information is obliged to comply with data protection obligations comparable
to those required by New Zealand law. To the extent that personal information is collected.from Australia and disclosed
by us to any other party in New Zealand, we will ensure that the recipient of that personal information is obliged to
comply with data protection obligations comparable to those required by Australian law.
It is not practicable for information submitted electronically to be provided to us anonymously or using a pseudonym and
it is a requirement that you accurately complete any data fields that require insertion of your name and personal details.
If you do not wish to provide any required personal information then you should not proceed with the completion of the
relevant process. Where appropriate you may communicate with us by telephone on an anonymous basis.
We will take reasonable steps to implement and maintain security precautions and to protect personal information from
misuse, interference, loss and unauthorised access, modification and disclosure. However, we are unable to guarantee
that unauthorised access to submitted information will not occur, either during transmission of that information or after we
receive that information.
If we no longer require your personal information, we will take reasonable steps to permanently destroy or de-identify
that information. You acknowledge that our back-up procedures may make it impractical to locate and destroy or de-identify copies of your personal information which are stored off-line or in a form which does not readily permit
location and modification of data and you consent to our continued retention of submitted information in these
circumstances.
If you submit information to any other site accessed through a link from our sites, the privacy principles applying to any
information you submit to that site are outside our control. You should check the privacy policies of any other site before
submitting information to that site.

 

Collection and use of cookies & clickstream data

We may use cookies in connection with your use of the Site. A cookie is a small amount of data that some websites
place on your computer when you visit them. A website may use cookies to track the pages you have visited.
When you visit our sites, our servers may record a range of information relating to your access and use of the sites
(collectively called “clickstream data”). We may examine clickstream data to determine the traffic through the server as
well as access levels to specific pages. No attempt will be made to identify you or your browsing activities from
clickstream data except in the circumstances specified below.
If we or any authority suspect that unauthorised access or use of the sites has occurred or may occur or be attempted,
we may gather, use and disclose more extensive information than indicated above regarding access or attempted
access to the sites for the purposes of prevention, detection, investigation or prosecution.

 

Correction of errors and access to personal information

We will take reasonable measures to ensure all personal information held about you is accurate, complete, relevant and
up-to-date.
We will provide you with access to your personal information on reasonable request and subject to your agreement to
pay our access charges and adequate proof of your identity if (a) it is practicable for us to do so and we have no other
reasonable grounds for refusing access, (b) the request is not frivolous or vexatious, (c) access will not have an
unreasonable impact on the privacy of others, (d) the information does not relate to existing or anticipated legal
proceedings (other than information accessible through the discovery process), (e) access will not reveal our intentions
in relation to any negotiations with you, (f) access is not unlawful (g) denying access is not required or authorised by law,
and (h) access will not prejudice any prevention, detection, investigation or prosecution of possible unlawful or improper
activity.
You have the right to require us to correct errors in your personal information.
We will correct any errors in your personal information upon receipt of written evidence from you which satisfies us that a
correction is required.

 

Privacy related complaints, concerns and questions

If you have any concerns, complaints or questions relating to this Privacy Policy or submitted information relating to you,
please contact our Privacy Officer (who represents Op2ma Pty Ltd) by email to privacy@op2ma.com.au.