Privacy Policy

This document is the Privacy Policy of Appliance Tagging Services Pty Ltd (ABN 42 118 273 788) and its related bodies corporate and franchisees (“ATS”, “we”, “us” or “our”).

recognise the importance of protecting the privacy of all information provided by users of our websites, recipients of our email newsletters and all other customers of our products and services. We created this policy with a fundamental respect for our customers’ right to privacy and to guide our relationships with our customers.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (“Privacy Act”) and we comply with all of the Privacy Act’s requirements in respect of the collection, management and disclosure of your personal information.

When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, personal information is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation, amongst other things. If the information we collect personally identifies you, or you can be reasonably identified from it, the information will be considered to be personal information.

This Privacy Policy covers Personal Information collected, used, held and disclosed by ATS (including by ATS franchisees) in relation to any of the following:

• franchisees or prospective franchisees;
• customers;
• suppliers or prospective suppliers;
• independent contractors or any person who applies to become an employee or independent contractor; and
• employees, except where the use or disclosure is directly related to the relationship between us as employer and you as the past or present employee and relates to an “employee record” about you.

Information Collection and Use

ATS collects personal information from our customers, website and app users, franchisees and prospective franchisees, employees (as outlined above), and subscribers. In this section of our Privacy Policy, we describe the type of personal information we collect and how we use it.

The type of information we may collect includes, but is not limited to:

• Information provided by you on the New Client Detail Form as updated from time to time;
• Information provided by you when you acquire goods or services from us or our franchisees such as, but not limited to, the number and type of assets at your premises, your name , your address, your email, and actual method of payment;
• Information you may provide from time to time through contact with us, our franchisees and/or that you provide on our website at www.appliancetaggingservices.com.au, www.datatransformation.com.au and www.ats.com.au, or through our intranet, or mobile phone and tablet apps;
• Information regarding your payment preferences;
• if you are an employee or contractor of ours, any additional information necessary for us to manage and administer our employment or contracting relationship with you (including tax file numbers, Australian Business Number, superannuation details, bank account details, emergency contact details and other relevant information);
• if you are an employee or contractor of any of our franchisees or customers, any additional information necessary for us to manage and administer our business relationship with your employer or the party that is engaging you (including the name of your employer, your job title and role description and any other relevant information); and
• if you are an employee or contractor of ATS or any of our franchisees and use our mobile phone and tablet app, any information captured about you by the app, including location data and the time and date the location was recorded.

Registration

When attending our trade shows and other in-person events, using some of our websites and signing up for certain selected services, users must first register. During registration, users are required to give their contact information (such as name, email address, mailing address and phone number). For internal purposes, we use this information to communicate with users and provide requested services, and, for our website visitors, to provide a more personalised experience on our sites.

We also may collect demographic information (such as job title and purchasing responsibilities, company information and professional certification). We use aggregate demographic information about our audience to improve our service, for marketing purposes and/or industry reporting purposes.

Emails

When you email us, we will record your e-mail address. We will only use your email address for the purpose for which you provided it. It will not be added to a mailing list unless you have specifically requested this, and we will not use your email address for any other purpose. We will not disclose your email address without your consent.

Email Newsletters

If users wish to subscribe to our email newsletters, we ask for contact information (such as name, email address and, occasionally, demographic information). We use this information in the same manner as we use contact information in the registration process described above.

Recipients of our newsletters can unsubscribe using the instructions listed at the end of the email newsletter.

Surveys and Contests

From time to time we invite website users and other customers to provide information via surveys or contests. Participation in these surveys or contests is completely voluntary and the website user or other customer therefore has a choice whether to disclose requested contact information (such as name and mailing address) and demographic information (such as post code or job title).

In addition to the other uses set forth in this policy, contact information collected in connection with surveys and contests is used to notify the winners and award prizes and to monitor or improve the use of, and satisfaction with the website or other ATS product or service.

Subject to the given customer’s preferences (as described in the "Permission" section following), such information also may be shared with third party sponsors of such surveys or contests.

Communications with Us

We have features where our customers can submit information to us (such as our feedback forms). Where such submissions include requests for service, support or information, we may forward them to our franchisees, as needed, to best respond to the specific request.

In addition, we may retain emails and other information sent to us for our internal administrative purposes, and to help us to serve customers better.

Please note that letters to the editor, feedback and similar submissions may be made public.

Communications from Us: Service Updates, Special Offers

In order to best serve our customers, we may send updates that contain important information about our products and services. For example, we send new members a welcoming message, and verify password and username for our password-protected websites. We may also communicate with a customer to provide requested services and for account-related issues via email, phone or regular mail.

In addition to such service and product-essential messages, we offer our customers the option to receive information about our company, related products, services and special deals. Users, however, can choose not to receive these communications from us, as set forth in the "Permission" section following.

Automatic Data Collection

Our websites, mobile phone and tablet apps, newsletters and, from time to time, certain other products and services have features that automatically collect information from customers, to deliver content specific to customers’ interests and to honor their preferences. This information assists us in creating products and services that will serve the needs of our customers.

For example, we use "cookies," a piece of data stored on the user’s hard drive containing information about the user. Cookies benefit the user by requiring login only once, thereby saving time while on our website. If users reject the cookies, they may be limited in the use of some areas of our website. For example, the user may not be able to participate in contests. Additionally, we may note some of the pages the user visits on our websites and via our email newsletters through the use of pixel tags (also called clear gifs) and web beacons. The use of cookies, pixels and web beacons enable us to track and target the interests of our users to enhance the experience on our sites and via our email newsletters.

For our internal purposes, we gather date, time, browser type, navigation history and IP address of all visitors to our websites. This information does not contain anything that can identify users personally. We use this information for our internal security audit log, trend analysis and system administration, and to gather broad demographic information about our user base for aggregate use.

We may combine demographic information supplied by a customer at registration with website usage data to provide general profiles, in aggregate non-personally identifiable form, about our customers and their preferences in the content of the site and advertising. We may share this composite information with our advertisers and business affiliates to help them better understand our services.

Our website, and our mobile phone and tablet apps, may collect your location data from sources such as GPS, Wi-Fi and cellular towers once you install the app and you consent to the app tracking your location. The app will store this information on your device and communicate that information to us and the responsible franchisee (if applicable).

Other collections

Where relevant, we may also collect personal information from third parties including:

• your employer or the party that is engaging you as a contractor;
• in relation to our employees and contractors, from recruitment agencies that we deal with or which you have engaged or from your former employer(s) or any referees that you provide; or
• from third party companies such as credit reporting bodies, law enforcement agencies, telecommunications providers, technology companies and other government entities.

We generally do not collect sensitive information about you, unless you have consented to the collection of this information by us or we are required by law to collect this information. “Sensitive information” includes health information, racial or ethnic background, sexual orientation or practices, criminal record, biometric information, religious, political or philosophical beliefs and membership of a union or political or professional association.

What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide our services to you (or your employer or the party that is engaging you), either to the same standard or at all;
• we may not be able to provide you with information about services that you may want, including information about special promotions;
• if you are an employee or contractor of ours or you apply for a position with us, we may not be able consider your application for employment or engagement as a contractor or provide you with any benefits or otherwise administer our employment or contracting relationship with you;
• if you are an employee or contractor of any of our franchisees or customers, we may not be able to transact with you, your employer or the party that is engaging you as a contractor; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service. We collect, hold, use and disclose your personal information for the following purposes:

• to provide our services to you (or your employer or the party that is engaging you) and to send communications requested by you;
• to answer enquiries and provide information or advice about existing and new services;
• if you are an employee or contractor of ours or you apply for a position with us, to consider your application for employment or engagement, to manage your employment or contracting relationship with us (including to pay you any salary, fees or benefits), to administer any training or education that you may require as part of your role and to assess your performance and provide you with performance feedback, including to undertake disciplinary action if necessary;
• if you are an employee or contractor of any of our franchisees or customers, to transact with you, your employer or the party that is engaging you as a contractor and to manage our relationship with you, your employer or the party that is engaging you as a contractor;
• to assess the performance of our website, mobile phone and tablet apps and to improve the operation of those services;
• to allocate and track the status of jobs, and monitor the performance of our employees and contractors, our franchisees, and their employees and contractors,
• for business administration purposes (including human resources, client management, job management and debtor management);
• for marketing purposes (including to create and maintain subscriber databases, including for client profiling or events management purposes);
• to conduct business processing functions including providing personal information to our related bodies corporate, franchisees, contractors, service providers or other third parties;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of us and our related bodies corporate, contractors or service providers;
• if applicable, to consider your application for employment or a contract role with us and to manage the application process;
• if you are or become an employee or contractor of ours, to manage and administer your employment or contracting relationship with us;
• to provide your updated personal information to our related bodies corporate, franchisees, contractors or service providers;
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.

Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

To whom your Information is disclosed

We do not share personal information with other companies; apart from those acting as our agents in providing our product(s)/service(s), and which agree to use it only for that purpose and to keep the information secure and confidential. We may also disclose personal information to our parent, subsidiary and affiliate companies, our franchisees, entities into which our company may be merged, or entities to which any of our assets, products, sites or operations may be transferred, will be able to use personal information.

We will also disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency’s request, or in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property. Users should also be aware that courts of law might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.

We may share aggregate information, which is not personally identifiable, with others. This information may include usage and demographic data, but it will not include personal information.

Do we hold or disclose your personal information to anyone outside Australia?

We do not hold or disclose personal information to overseas recipients.

Direct marketing and Permission

We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

We do not provide your personal information to other organisations for the purposes of direct marketing.

Our customers are given the opportunity to choose whether to receive information from us not directly related to the product or service for which they registered (or which they otherwise agreed to receive). Customers can go to our "Feedback" page at any time, at http://www.appliancetaggingservices.com/contact to change their preferences.

In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (using the details in the ‘Contacting us’ section below) or by using opt-out facilities provided in the marketing communications. We will then ensure that your name is removed from our marketing distribution lists. Please note that we will endeavor to implement your permission requests within a reasonable time (and in any event within the time required by applicable laws), although for a time you may continue to receive mailings, etc., transmitted based on information released prior to the implementation of your request.

In addition, please note that even after such request is implemented, you will continue to receive factual massages and similar information directly related to the product or service for which you registered (or which you otherwise agreed to receive), so you are always kept informed.

Security

We use reasonable precautions to protect our customers’ personal information and to store it securely. We may hold your information in either electronic or hard copy form.

Sensitive information that is transmitted to us online is encrypted and is transmitted to us securely. In addition, access to all of our customers’ information, not just the sensitive information mentioned above, is restricted. Only franchisees and employees who need the information to perform a specific job (for example, an accounts clerk or a customer service representative) are granted access to personally identifiable information.

You should note, however, “perfect security” does not exist on the internet and there are risks associated with the transmission of information over the internet. While we and our franchisees strive to protect your personal information, we and our franchisees cannot ensure the security of any information that you transmit to us over the internet and you do so at your own risk. Once we receive your transmission, we take all reasonable steps to ensure that your information is secure on our systems.

Also, due to technical limitations, we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. For example, we may be forced to disclose information to the government or third parties to comply with our legal obligations. Other parties may intercept or access transmissions or private communications without our consent and outside our control. As such we cannot and do not guarantee that your personal information or private communications will always remain private.

Finally, the servers on which we store personally identifiable information are kept in a secure environment.

Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later).

Links

websites contain links to other sites. ATS is not responsible for the privacy practices or content of other such sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website to which we may link that may collect personally identifiable information.

Children

ATS websites are not directed at individuals less than 15 years of age, and ATS does not intend to collect any personally identifiable information from such individuals.

Accessing or Correcting your Personal Information

You may access and correct your personal information at any time by contacting us using the contact details below.

• by calling us on 1300 287 669; or
• by emailing us on office@ats.com.au; or
• by writing to ATS, PO Box 4066, Patterson VIC 3204; or
• by facsimile: 1300 795 287.

We will provide you with access to your personal information held by us except to the extent that:

• providing access would pose a serious or imminent threat to the life or health of any individual or unreasonably impact upon the privacy of other individuals;
• the request is frivolous or vexatious;
• the information relates to existing or anticipated legal proceedings between us and you and the information would not be accessible by the process of discovery in those proceedings;
• the access would prejudice negotiations between us and you;
• providing access would be unlawful; or
• denying access is required or authorised by or under law.

If access is denied the reasons for denying access will be explained and where appropriate we may consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties. We reserve the right to charge a nominal fee to cover retrieval costs in the event of a complex and comprehensive request for access.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we correct it. We will consider if the information requires correction and take appropriate steps.

What is the process for complaining about a breach of privacy?

If you believe that we have breached your privacy, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Privacy Act, if applicable).

If our response to your complaint does not address your concerns to your satisfaction, you have the right to make a complaint to the Office of the Australian Information Commissioner.

The contact details for the Office of the Australian Information Commissioner are:

• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Post: GPO Box 5218, Sydney NSW 2001
• Fax: +61 2 9284 9666

Contacting us

If you have any questions comments about this policy, please contact our Privacy Officer, Sarah Allen on 1300 287 669 or sarah@ats.com.au. Otherwise, you can contact us:

• by calling us on 1300 287 669; or
• by emailing us on office@ats.com.au; or
• by writing to ATS, PO Box 4066, Patterson VIC 3204; or
• by facsimile: 1300 795 287.

Changes to our Privacy Policy

From time to time we may update our privacy notice. All changes will be announced on our website and we will provide at least 30 days’ notice of any such changes. If you are concerned about how your information is used you should check our website periodically or contact us to discuss any changes.

This privacy policy was last updated on 28 February 2018