1.1 Finnigan Investments (Australia) Pty Limited ACN 155 747 765 (StaffPurchase, or we, us or our) recognises the importance of your privacy.
1.2 We abide by the Privacy Act 1988 (Cth), the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth), as well as other applicable laws and regulations. Our policy for the management of personal information is set out in this document.
(a) to corporate information (unless it is also about any identifiable person); or
2. Collection of Information
2.1 From time to time, we may collect the following information from you:
(a) your customer information, including your name, employer, address, phone number and email address;
(b) your profile details, including your organisation size, industry and IT brand preferences;
(c) your preferred bank details, including BSB, account number and account name;
(d) details about your membership of associated industry bodies;
(e) copies of receipts from your IT purchases; and
(f) information regarding products and services you inquire about or purchase from us,
2.2 Your Information may, in certain circumstances, include Personal Information.
2.3 We may collect your Personal Information directly from you through our Site, or when you contact us by email or over the phone. For example, we may collect your Personal Information when you:
(a) register your interest in StaffPurchase or sign-up for our newsletter;
(b) subscribe to our Site or become a StaffPurchase business partner or affiliate;
(c) claim an offer (cash-back or coupon) from our Site;
(d) enter into any competitions on our Site;
(e) provide feedback on the StaffPurchase service or any of the products or services provided through our Site;
(f) participate in polls and surveys on our Site;
(g) register to receive notifications about offers;
(h) contribute to our blog; or
(i) refer a small business or associate to StaffPurchase.
2.4 We may also collect your Information from our retail partners in order to help us process your cash-back claims. We always ask our retail partners to seek your permission before they provide your Information to us.
2.5 We use "cookies" on our Site. A "cookie" is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser but not you. If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our Site, but not all services may be available.
2.6 We use Google Display Advertising for re-marketing purposes. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager.
2.7 We do not provide the option of not identifying yourself, or using a pseudonym, when dealing with us. It is impracticable for us to deal with individuals who have not identified themselves or who have used a pseudonym.
2.8 If you do not provide your Information to us you will not be able to use our Site and we are unable to provide our services to you.
3. Use of Personal Information
3.1 We collect, hold and use your Information, including Personal Information:
(a) to confirm your identity and validate your cash-back claims;
(b) for our own internal purposes, and those of our related companies (as identified on our Site), for example to provide our products and services;
(c) so that we can contact you when necessary or appropriate but only when directly related to StaffPurchase products or services which we may provide to you;
(d) to assist with your IT purchases;
(e) to respond to questions, queries, requests for information and applications;
(f) to manage and record our relationship with you;
(g) to aid in aggregating our subscription database;
(h) to develop a data profile to enable us to tailor services to you and enhance the content of our Site;
(i) to create impersonalised statistical data; and
(j) to send you information about us, including marketing information about our products and services.
3.2 In addition to the matters set out at paragraph 3.1 above, we may collect, hold and use your Information, including Personal Information:
(a) when you give us express or implied consent to do so;
(b) for purposes related to the reason for which you gave us the Information, but only if you would reasonably expect us to use it for those purposes; and
(c) as otherwise permitted or required by or under any law.
3.3 We will take all reasonable steps to destroy or permanently de-identify Personal Information if we no longer need it for any purpose for which we have collected, used or disclosed your information or for any products or services that we provide.
3.4 We will not send any direct marketing to you unless you have opted-in to receive direct marketing. If and when we do send you direct marketing information (for example, emails) we will also give you the opportunity to opt-out of receiving any further direct marketing information from us.
4. Disclosure of Personal Information
4.1 We will not disclose any Personal Information about you, except:
(a) to our related companies (as identified on our Site) or governmental bodies, but only to the extent required to facilitate the products and services we may provide to you (or in the case of certain governmental bodies as required to be disclosed by law or regulatory order);
(b) to IT manufacturers and retailers to provide quotes to you, assist with or fulfil a transaction, provide a quotation or validate the legitimacy of cash-back claims;
(d) in circumstances permitted or required by or under any law.
4.2 We may disclose your Personal Information to recipients in the Philippines, but only for the purpose of maintaining our Site and databases. We will not otherwise transfer your Personal Information overseas unless:
(a) you expressly consent to the transfer; or
(b) we take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the relevant Privacy Principles under the Privacy Act 1988 (Cth) in relation to your Personal Information or an exception is available under the relevant Privacy Principles.
4.3 We will not sell, rent, let or trade your Personal Information to or with any third party.
5. Impersonalised statistical data
We may combine your Personal Information with information from other users of our Site to create impersonalised statistical data. We may provide this statistical data to our business partners or third parties. In no circumstances will you be able to be identified from this statistical data; you will remain anonymous.
6. Security, access and correction
6.1 We will take reasonable steps to ensure that all Personal Information we collect or use:
(a) is accurate, complete and up to date;
(b) is stored in a secure environment; and
(c) is accessed only by authorised personnel for permitted purposes.
6.2 We have implemented procedures to safeguard the security and confidentiality of your Personal Information from misuse or other unauthorised activity, although because of the nature of the Internet, we cannot guarantee that it is totally protected from hackers or misuse.
6.3 Please contact our Privacy Officer, via the contact details below, if you:
(a) wish to access or modify Personal Information which we hold about you;
(b) wish to request the removal of Personal Information about you from our records;
(c) believe Personal Information about you is inaccurate, outdated, incorrect or is misleading because it is incomplete and you wish to change it; or
(d) have any questions regarding or are unhappy with any aspect of our privacy practices or our collection or use of Personal Information.
6.4 Our Privacy Officer can be contacted on 1300 955 523 or by email at admin [at] StaffPurchase.c
If you have a complaint about how we have handled your Personal Information, or about any other privacy-related matter, please contact our Privacy Officer on 1300 955 523 or by email at admin [at] StaffPurchase.c
Within 5 business days of receiving a complaint we will seek to contact you to confirm that we have commenced an investigation, and we will endeavour to complete our investigation within a further 28 days from the date of confirmation. We will let you know the outcome of our investigation once it is complete, including any actions that we will take to address your complaint.
8. Amendments to this policy