MHG ASIA PACIFIC - PRIVACY POLICY
Background
MHG Asia Pacific and its associated entities (Us, Our, We or the Company) understands the importance of the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and are committed to ensuring the privacy of your personal information. The following Privacy Policy is a plain English explanation of how We manage your personal information. Our specific legal obligations in respect to the collection and handling of personal information are outlined in the Privacy Act.
Personal Information, as defined in the privacy legislation, is information, or an opinion, in any form, and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. We will only use the information that We collect about you lawfully. Generally We will only collect Personal Information where the information is necessary for Us to perform one or more of Our functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
By providing your personal and any other information to Us, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy. Personal Information includes information about an individual who is reasonably identifiable.
If you do not agree to the Privacy Policy, please do not provide Us with personal information.
We may amend this Privacy Policy from time to time. The current version of our Privacy Policy is available on the following site www.mhgasiapacific.com and you may request a copy by contacting Us at privacy@mhgasiapacific.com or +61 (0) 3 5279 6234.
What types of personal information do We collect?
The amount and type of personal and/or sensitive information that We collect and hold about you depends on the dealings you have with Us and may include your name, age, date of birth, contact details such as phone, fax, email address and mobile phone number, physical address and delivery address, email address, tax file number, financial affairs including bank account and credit card details, product interests, company details, details of your contact person, the names of all directors, officers and senior management staff, the names of employees, the name of the contact person at your bank or financial institution, along with general personal and financial information such as the type and quantity of assets that you purchase or own, records of your communications and interactions with Us and behaviour relating to transactions, products, services and activity with our services.
We may not be able to provide our services without your personal information.
How personal information is collected and held.
We may collect your personal information, and that of other persons using Our products or services, from your interactions and transactions with Us including:
- When you make a telephone communication,;
- When you make an email communication;
- When you complete a transaction with Us;
- When you request our services;
- When you register or subscribe to our services including our website and mailing list;
- When you visit our office as a part of the services we provide;
- When you visit certain parts of our website where you are invited to provide content, submissions and suggestions, visitorship data or participate in interactive online activities (i.e. community postings, voting, rating, reviewing, rewards programs, chat, my account or bulletin boards);
- When you apply for a job with Us or seek to become a service provider or seek Us to provide you services;
- When you contact our partners, suppliers, associates or others within the group;
- From third parties, including public sources, information service providers, credit reporting agencies or anyone authorised to act on your behalf.
We may also collect information by other means and will take all reasonable steps to inform you if and when We do.
We collect Personal Information in a number of ways, including:
- In person;
- Over the telephone including by way of monitoring and recording telephone calls;
- Through our websites;
- On hard copy forms;
- Through written communications including letters, facsimiles and emails;
- From third parties, including
- Publically available sources, information service providers, credit reporting agencies or anyone authorised to act on your behalf;
- Agents, employees, subcontractors, suppliers and services providers;
- Our partners and related entities.
Should you choose to purchase or acquire products or services from Us, We will also collect specific personal and sensitive information about you including your full name, address and details about your credit card to process a sale to you.
Please note:
- Before We can provide any service, We will ask your permission to collect and use the information needed.
- If you don’t provide us with all required information, We may not be able to provide you with the service requested;
- There may be times when it is lawful and practical for you to work with us anonymously; however, by doing so, We may not be able to provide you with the service requested.
If it is practical We will notify you of the matters listed below at the time of collecting any Personal Information:
- The main reason that We are collecting Personal Information (this reason will be the Primary Purpose);
- Other related Uses or Disclosures that We may make of the Personal Information(Secondary Purposes);
- Our identity and how individuals can contact us, if this is not obvious;
- That individuals can access the Personal Information that We hold about them;
- That individuals should contact us if they wish to access or correct Personal Information collected by Us or have any concerns in relation to Personal Information;
- Where applicable, any law that requires the Personal Information to be collected;
- The consequences (if any) for the individual if all or part of the Personal Information is not provided to Us.
Where it is not practicable for Us to notify individuals of all of the collection information before the collection of Personal Information, We will ensure that individuals are notified of the collection information as soon as possible after the collection. We will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
We also collect general statistical information from our website, such as the number of visitors to the website, the number of pages viewed, the date, time and duration of visits and how the visitor came to the website. We may also collect Internet Protocol (IP) addresses and internet browser type. This information will not identify you. For more information, please read the section on cookies below.
Website Analytic, session and cookie tools
We use a range of tools provided by third parties, including Google, Office365, Bing and other service providers including our web hosting company to collect or view website traffic information and site visitorship data. These sites and providers have their own privacy policies. We also use cookies and session tools to improve your experience when accessing our websites. We use the information to maintain, secure and improve our websites and to enhance your experience when using them.
Site visitorship data is information about the way a website is used that is not associated with an individual’s identity. We use anonymous data regarding online behaviour to better understand how people use our products and services. To that end, We may use aggregated, anonymous online traffic behaviour, along with information from third parties to track usage trends and thereby improve our services. We may also use this aggregated, anonymous information to develop reports that We may share with third party marketing partners and affiliates. The kind of information We may collect includes:
- The date and time you access the services;
- Your internet service provider, mobile carrier, or data services provider;
- Your Internet Protocol (IP) address;
- The pages you visit;
- The links you click;
- The features you use;
- How and when you interact with the services;
- The content, images and advertisements you select; and
- How you arrived at the products and where you go when you leave.
Most site visitorship data is collected using data collection tools such as web beacons, cookies, embedded web links and other software (together “Data Collection Tools”). Data Collection Tools are typically small data files or software that are sent to your browser and stored on your computer or mobile device. Most browsers and display software can be set to inform you when Data Collection Tools are being used or other tracking software is being sent to your computer or Personal Communication Device. They also provide you with the option of refusing such Data Collection Tools. However, refusing to allow the use of Data Collection Tools may, in some cases, preclude you from using, or negatively impact the display or function of, certain areas or features of our services, including preventing you from purchasing products or acquiring services from Us.
Why We collect personal information
We collect, hold, use and disclose your personal information so that We may:
- Provide you with the services you purchase or obtain from Us;
- Provide you with information about the services;
- Respond to your requests for information;
- Process data you provide;
- Internal management purposes;
- Send you information you order or request;
- Facilitate Our marketing and promotional activities;
- Open, maintain and administer client files; and
- Any other purpose to which you have consented or which is required or permitted by law.
If permitted by law, We may disclose information collected about you as an asset of the company in conjunction with the purchase and potential purchase of Our company or a portion of Our assets. Any personal information that is disclosed to such a third party will remain subject to the protections in the Australian Privacy Principles.
Digital Services
We provide information and services through a range of digital and online services including websites, email and social media profiles. Some information We collect, for example is not related to an individual. In many cases, the information relates only to a device or is of an aggregated or statistical nature, and We will have no way of knowing the identity of the user. In other cases, We may associate information about your use of our digital services over time with your personal information, for example, when on any occasion you have logged in, followed a link sent to you by email, or We have otherwise been able to identify you.
How do We use and disclose Personal Information?
We use Personal Information to process orders and reservations made by you, provide services to you or to contact you about services that are relevant to you or to send you information that may be of interest to you. We will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
Unless otherwise disclosed during collection, We will not provide any Personal Information to any third party for any purpose whatsoever, other than:
- In the event of a sale of our business or company (then to that purchaser);
- To enable us or our suppliers or partners to fulfil an service that you have requested from us; or
- To a regulator or authority;
- To one of our related body corporate, partners or service providers.
Please note, if you provide your credit card information to us in order to conduct an e-commerce transaction on the website or otherwise, We will provide your information to participating merchants in order to process that transaction. We are not responsible for how that information may be used by participating merchants.
Sharing of Personal Information and cross-border disclosure
We may share your personal information with third parties where appropriate for the purposes set out in the Privacy Policy, including:
- Our other companies;
- Where you are an employee or service provider of Our customer, We may share information collected about you in respect to the services We provide to the customer with them;
- Merchants for payment processing;
- To our suppliers or partners to fulfil a service that you have requested from us;
- Service providers engaged to assist with services including sales, distribution, logistics and delivery, data processing and storage, data analysis, information broking, credit reporting, online computing, printing, contact centre, legal, accounting, business consulting, marketing, research, auditing, archival, delivery, security, investigation, mailing services and analysis.
We will generally send information overseas. The third parties to whom We disclose and who collect personal information on our behalf may be located in Australia and other countries including Thailand and China. We take reasonable steps to ensure that all our service providers agree to protect the privacy and security of your personal information, and use it only for the purpose for which it is disclosed, subject to their obligations of compliance to the Privacy Act. If at anytime We are required by law or legal process to release Personal Information about you, We must cooperate fully.
Access to, and correction of, personal information
You are entitled to access your own personal information being held by us. This information is generally provided on request. So that We can respond to your request quickly and efficiently, if at any time you want to know what personal information We hold about you, correct such information or have any questions or complaints you are welcome to contact us by:
- Email at privacy@mhgasiapacific.com
- Phone on +61 (0) 3 5279 6234
- Writing to our Privacy Officer at:
Human Resources Manager
MHG Glass Pty Ltd
24 Mackey Street
North Geelong
Vic 3215
Australia
We aim to respond to most requests for access within thirty (30) days subject to some exceptions permitted by law. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that We hold about you, or if We are satisfied that the personal information We hold is inaccurate, out of date, incomplete, irrelevant or misleading, We will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If We correct personal information about you, and We have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, We will take reasonable steps to do so, unless this would be impracticable or unlawful. Where We decide not to make a requested correction and you disagree, you may ask us to make a note of your requested correction with the information.
In most cases, We expect that complaints will be investigated and a response provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, We will contact you and tell you when We expect to provide our response.
How do We keep your personal information secure?
We hold personal information in a number of ways, including electronically, in hard copy form, in electronic databases and files, both at our own premises and with the assistance of our service providers including at archive facilities and external data management facilities. We implement a range of measures to protect the security of that personal information. The steps We take to secure personal information include website protection measures, security restrictions on access to our premises and computer systems together with our service provider’s facilities. The Personal Information we hold will be held securely in accordance with our internal policy and the law. We take steps to protect the Personal Information We hold against loss, unauthorised access, use, modification or disclosure, and against other misuse. We also take measures in respect of destroying or de-identifying personal information that is no longer needed for any lawful purpose.
We cannot guarantee, in every circumstance, the security of the Personal Information you provide on the website or via any electronic form of communication with us. All incoming encrypted information is routed through our firewall, which serves as a gatekeeper for our system. Only data containing the correct authorisation is permitted past the firewall. Attempts to pass the firewall are constantly monitored for suspicious activity.
Where data is held overseas or by third parties, We require third parties to store such data in restricted access premises and provide appropriate protection against unauthorised disclosure. As a minimum security requirement, password authentication is required to access those databases in all cases.
Complaints
If you have a complaint about how We have collected or handled your personal information, please contact Us by:
- Email at privacy@mhgasiapacific.com
- Phone on +61 (0) 3 5279 6234
- Writing to our Privacy Officer at:
Human Resources Manager
MHG Glass Pty Ltd
24 Mackey Street
North Geelong
Vic 3215
Australia
We will endeavour in the first instance to deal with your complaint and take action to resolve the matter. If your complaint cannot be resolved at the first instance, We will ask you to lodge a formal complaint in writing, explaining the issues of your complaint, how you believe your privacy has been interfered with and how you believe your complaint should be resolved.
Upon receipt of a formal complaint, We will acknowledge receipt and indicate the timeframe that you can expect a response. We will endeavour to resolve the complaint as quickly as possible, but if the matter is complex and our investigation may take longer, We will let you know when We expect to provide our response
If you are unhappy with Our response, you may refer your complaint to the Office of the Australian Information Commissioner or other appropriate body.
Last updated 28th April 2016