This policy applies to all personal information received by ETL. Personal information means information or opinion about an identified (or reasonably identifiable) individual.
ETL’s website may contain links to third party websites, materials, products, services or activities. ETL is not responsible for the content, privacy practices or policies of such third parties. You should read them carefully before providing any personal information to these third parties (which you may do at your own risk).
How personal information is collected or received
Personal information may be collected or received from you by ETL in different forms (e.g. in hard copy, by email or other electronic communication or verbally over the phone or in person) and in various ways, whenever you interact or transact with ETL, including:
- when you order or request to receive services from ETL, including tracking and other services available online (Digital Services);
- when you seek to provide services to ETL or transact with ETL (as a supplier, contractor, consultant, agent or other);
- when you apply for a job with ETL;
- when you submit an application, form, request, enquiry or complaint to ETL;
- when you provide data, documents or instructions to ETL;
- when you visit or use ETL’s website.
You agree that ETL may also obtain information about you from:
- Anyone acting for you or on your behalf including family members, service providers, consultants, representatives, agents and others;
- Publically available sources, information services providers, credit reporting agencies;
- Third parties who are or were in contact with you in relation to the services to be provided;
- Third parties you permitted or authorised ETL to obtain information from;
- ETL’s services providers (contractors, suppliers, agents) and partners; and
- ETL’s related entities, including parent and sister companies and subsidiaries.
ETL may also collect information by other means and will take all reasonable steps to inform you if and when it does do.
What personal information is collected or received
Examples of personal information that may be collected or received by ETL include:
Customer Information: information you provide for the purpose or in the course of receiving services from ETL or accessing Digital Services, including your name, ABN ,postal address, email address, phone and fax number, and information related to the services provided (such as nature, time and location).
Supplier Information: information you provide for the purpose or in the course of providing services to ETL or transacting with ETL as a supplier, contractor, consultant, agent or other), including your name, ABN ,postal address, email address, phone and fax number, and information related to the services provided (such as nature, time and location).
Financial Information can include trading or financial information provided by you to establish a credit account, details of payments for services provided, billing address, bank account details, payment facility details (including information related to cheques, money orders, letter of credit and credit card).
Digital activity related Information: ETL may receive or collect information produced during or in relation to your activities on ETL’s website or when using ETL’s Digital Services, including the content you access or create, web pages you visit, the time, date and login information of your activities (including browser type and language), the location of the communication device and its internet protocol (IP) address (including phone number used and associated carrier).
Cookies information: When you access ETL’s website or Digital Services through any communication device, a small data file called cookie may be stored on that device. The cookie enables ETL to improve the quality of service provided to you, for example by making it easier for you to login again or by tracking your preferences and personalising the services offered to you. You can block or remove cookies via your browser settings but that may impact on your use of the website or Digital Services.
Third Party Information: ETL may receive from third parties you interacted with or received services from information relating to your communications, activities or transactions with them. Such third parties may include service providers of ETL (contractors, agents, credit reporting agencies, recruiters) and companies related to ETL.
Job Applicants Information: information provided by job applicants or recruiters including in job applications and accompanying communications, resumes, ETL Employee Application forms and police checks done by applicants.
CCTV Footage produced by security cameras installed at ETL’s offices and warehouses.
Use and Disclosure of personal information
Personal Information received and collected by ETL may be used or disclosed, subject to any applicable law, for the following purposes (Primary Purposes):
- To verify your identity;
- To assess or process any request or application submitted by you, including a job application;
- To assess, provide, administer, manage, monitor, review or improve services you have requested to receive, are receiving or have received from ETL;
- To assess, administer, monitor, review or improve services you have agreed to provide, are providing or have provided to ETL;
- To enable third parties (in Australia and overseas) to provide to you products or services you have requested, or receive from you products or services you have agreed to provide;
- To personalise, customise or improve services or products offered to you (directly or through third parties) and your use of ETL’s website and any Digital Services;
- To provide to you from time to time offers or updates in relation to products, services or benefits that may be of interest to you (including direct marketing materials), unless you indicate that you do not wish to receive such communications;
- To provide, develop, maintain, monitor, measure, protect and improve ETL’s services in general;
- To facilitate marketing and promotional activities;
- To handle any complaint or respond to any feedback received from you or others;
- To protect, defend or enforce the rights, property or safety of ETL or third parties (including defending ETL against potential or existing legal claims);
- In connection with the sale or transfer of shares or assets of ETL;
- For any purpose you agree to;
- For any purpose related to the above purposes that can reasonably be expected by you.
- You have no obligation to provide personal information to ETL, but if you choose not to provide certain information it may prevent, limit or affect ETL’s ability to provide services to you, receive services from you, process an application or form submitted by you or address a complaint lodged by you.
Occasionally, ETL may use or disclose your personal information to communicate to you special offers and promotions relating to products, services or benefits which ETL believes may be of interest to you. Such direct marketing communications may be verbal (by phone) or written (by email, text, or via the Digital Services). You can request ETL not so send you such communications by using any opt-out method outlined in these communications or by contacting ETL at any time (see Contact details at the end of this policy).
Disclosure or transfer of personal information
ETL may use or disclose to third parties your personal information if and as needed for:
- the Primary Purposes;
- purposes related to the Primary Purposes that you would reasonably expect;
- any other purpose you agree to; or
- as permitted by law.
Third parties to whom ETL may disclose personal information include, without limitation:
- Entities that are or become affiliated with ETL, such as parent or sister companies, subsidiaries or entities acquiring control of ETL or merging with ETL;
- Law enforcement, government and regulatory agencies (such as customs and quarantine agencies), and anyone instructed by them;
- Your authorised representatives and advisors if requested by you;
- Third parties you or ETL have contacted in relation to the services to be provided to you or by you;
- ETL’s agents, contractors, service providers or advisors who are acting for or on behalf of ETL in Australia and overseas in connection with the Primary Purposes, including without limitation:
- Customs agents;
- Transport, storage and warehousing service providers;
- Credit reporting agencies;
- Debt collectors;
- Marketing and customer service providers;
- Providers of ICT services including servers, storage, routing and website related services;
- Recruiters; and
- Lawyers, accountants, tax advisors and professional advisors.
ETL may retain your personal information for as long as it is needed for any of the Primary Purposes or any other permitted purpose.
Transfer to overseas recipients
Some of the entities mentioned above which may receive, use or access the personal information may be located overseas, including in Israel, New Zealand, the Indian sub-continent, Africa and South East Asia.
If required by law ETL will take reasonable steps to ensure that the receiving third parties are committed to protect personal information through applicable privacy and confidentiality obligations.
Protecting personal information
ETL is committed to the protection of personal information and has put in place various security measures (physical, electronic and procedural) to secure the personal information held by ETL and protect it from unauthorised access, disclosure or use.
While such measures reduce the risk of security breaches, no method of transmitting or storing data provides absolute or perfect protection. ETL cannot guarantee that personal information will never be accessed, used, or released in a manner that is inconsistent with this policy. To the fullest extent permitted by law, ETL will not be responsible for any such unauthorized access or use or its consequences.
To protect the security and privacy of your personal information, you must safeguard any username or password you may have been assigned with in connection with accessing or using the website or Digital Services (“User Details”). You must keep such User Details strictly confidential and not allow anyone to access them and/or use them. You are fully responsible for all activities which occur under your User Details including any security breaches or privacy violations.
Please contact ETL without delay to inform it of any security concerns you have or violations you become aware of, including any unauthorised use of your User Details (see Contact details at the end of this policy).
How to access or correct personal information
You may contact us at any time and request to access or correct any personal information ETL holds about you (using the Contact details at the end of this policy). ETL will need to verify your identify and may ask for further details before processing your request, and may charge you a fee to cover the reasonable administrative costs involved.
ETL may refuse your request to access or correct personal information in certain circumstances permitted by law. In such case ETL will notify you in writing of the reasons for the refusal and advise you of any complaint mechanisms available.
ETL may retain a copy of any personal information before and after any changes, updates or deletions to it for internal back up, administration, compliance, enforcement, protection and defence purposes. You can ask ETL to notify any correction made to any entity which the information has previously been disclosed to.
Policy variation and enforcement
No failure or delay by ETL in exercising any right, power or remedy conferred by this policy will operate as a waiver of or otherwise prevent the exercise of the right, power or remedy.
Post – PO Box 596 Rose Bay NSW 2029
Phone: (02) 9666 0125
ETL will endeavor to deal with any complaint within 30 days of duly receiving it. If further information or investigation is required to resolve your complaint we will advise you of what is required and will keep you updated as to the progress of the investigation and the expected time for response.
You can also obtain information at the Office of the Australian Information Commissioner’s website at www.oaic.give.au.
Last updated: 1 April 2017
© EPL Trading and Logistics Pty Ltd 2017