PRIVACY POLICY

Lotus Folding Doors and Walls Pty Ltd (Lotus) including Concertina Doors Online (Concertina)(“together, “we”) respect your privacy by treating all your personal and sensitive information in accordance with legislation. We are subject to the Privacy Act 1998 (Cth), which contains the Australian Privacy Principles (APPs), as well as other applicable state and territory laws. We may in consultation with each other, and from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to our operations and practices, and to make sure it remains appropriate to the changing business and online environment.

What type of personal information do we collect?

The type of information that we collect and hold will depend on the nature of your involvement with us.

Depending on the reason for collecting the personal information, the personal information that we collect may include (but is not limited to) name, residential address, suburb, postcode, phone number, email address, employment status and images.

If you choose not to provide information as requested, it may not be practicable for us to service your needs.

We sometimes receive unsolicited personal information. In circumstances where we do receive unsolicited personal information we will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.

How do we collect personal information?

Personal information is collected:

• online via our registration form;
• online via a business transaction; and
• via email, post and phone.

We will endeavour wherever practicable to collect personal information directly from you. Information is collected in a number of ways including from when you fill in a form, make an enquiry online, attend a face-to-face meeting, provide email correspondence, engage with us on social media, attend an employment interview, phone us, or make a payment.

We may collect personal information from individuals such as customers, contractors, retailers, distributors, suppliers, staff members and job applicants.

We will generally obtain consent from the owner of personal information to collect their personal information. Consent will usually be provided in writing however sometimes it may be provided orally or may be implied through a person’s conduct.

We will endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.

In relation to the collection and disclosure of sensitive information, we are bound by the APPs, which provide for the circumstances in which disclosure is permitted, or required by law.

How will we use your personal information?

We may collect, hold, use or disclose your personal information for the following general purposes:

• to identify you;
• for the purpose for which the personal information was originally collected;
• for a purpose for which you have consented;
• for information for direct marketing, and you will be given an opt-out in such communications;
• for any other purpose authorised or required by an Australian law; and
• for any other purpose authorised or required by a court or tribunal.

Our primary purpose of collecting personal information is to provide flooring, doors and wall services to customers through our online and associated services. The secondary purposes of collection personal information will be either related or reasonably expected to be related to the primary purpose or to which you have consented.

In relation to the personal information of prospective staff members and contractors, we collect the personal information for purposes including to:

• enable us to carry out our recruitment functions;
• administering the individual’s employment or contract;
• correspond with you, provide training and professional development;
• insurance purposes;
• fulfil the terms of any contractual relationship; and
• ensure that you can perform your duties.

Where we receive unsolicited job applications, these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act. We may seek your consent to retain such applications for future opportunities.

If you have any concerns about your personal information being used by us in any of these ways, please notify us.

Direct marketing

From time to time, and in support of our strategic growth and business strategy, we will send direct marketing material if you have consented to receiving such information.

If you do not want to receive any such information, you can contact Lotus and Concertina by email on enquiries@concertinadoorsonline.com.au.

Once we receive a request to "opt out" from receiving marketing information, we will cease sending such information within a reasonable period of time.

How do we store personal information?

We take reasonable steps to protect personal information under our control from misuse, interference and loss and from unauthorised access, modification or disclosure.

We protect personal information in a number of ways including securely storing online records, using professional software systems, and password restricted access.

We also have policies in place in relation to archiving, destruction and storage of personal information.

Who might we disclose personal information to?

Lotus and Concertina may disclose your personal information to third parties for the purposes of conducting telephone interviews from the information contained in our direct marketing database. Our contracts with these third parties impose privacy obligations on these third parties. Are the call centres OS?

How you can update your personal information?

We are always committed to holding accurate and up-to-date personal information. If you would like us to update the personal information that we hold about you, you can contact us via email on enquiries@concertinadoorsonline.com.au.

How can a person access their personal information?

If you wish to access personal information held about you in order to seek correction of such information you may do so by contacting us via email on enquiries@concertinadoorsonline.com.au.

We may refuse access to personal information in a number of circumstances. These might include where:

• giving access to the information would pose a serious threat to the life, health or safety of a person;
• giving access would have an unreasonable impact on the privacy of a person;
• the information relates to existing or anticipated legal proceedings and would not be available under the discovery process; or
• denying access is required or authorised by an Australian law or court order.

If we refuse to provide access, then we will give reasons and we may involve a mutually agreed intermediary. We will seek to handle all requests for access to personal information as quickly as possible.

How long will we keep your personal information?

If we no longer require your personal information, it will be de-identified or destroyed. Notwithstanding this, consistent with business requirements, your personal information may be kept for statistical, research and marketing purposes.

Enquiries and privacy complaints

If you have any questions relating to this policy, or you would like to lodge a complaint you need to contact us by emailing us at enquiries@concertinadoorsonline.com.au.

We will investigate any complaint and will notify the complainant of any decision in relation to the complaint as soon as practicable.

If you are not satisfied with the response you can refer the complaint to the Office of the Australian Information Commissioner.

Definitions

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

Sensitive information is a special category of personal information. Sensitive information means:

• information or an opinion about an individual’s (i) racial or ethnic origin, (ii) political opinions, (iii) membership of a political association, (iv) religious beliefs or affiliations, (v) philosophical beliefs, (vi) membership of a professional or trade association, (vii) membership of a trade union, (viii) sexual orientation or practices, (ix) criminal record, that is also personal information;
• health information about an individual,
• genetic information about an individual that is not otherwise health information;
• biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or
• biometric templates.

Biometric information includes information based on personal attributes such as fingerprints, DNA, iris, facial features, hand geometry and voice.

Last Updated: 21st January 2018