Tom Waterhouse Holdings Pty Ltd and its related bodies corporate (together “Tom Waterhouse” or “we” or “us” or “our”), acknowledges the importance of protecting the privacy and rights of individuals in respect of their Personal Information. Set out below is our policy relating to the ways we collect and manage your Personal Information.
Your rights to privacy as well as the requirements relating to collection, management and disclosure of your Personal Information are set out under the Privacy Act 1988 (Cth) (“Act”). Please visit www.oaic.gov.au for more information.
Your Personal Information
The term “Personal Information” (when used in this policy) has the meaning given to it under the Act. It generally includes any information that can be used to identify you personally. Such information may include your name, occupation, address, telephone number or email address. Information will be considered Personal Information if the information collected by us identifies you personally, or you are reasonably identifiable from it.
Types of Personal Information collected
Types of Personal Information we may collect includes:
name, telephone, residential, mailing and email addresses;
date of birth, gender, age, purchase history, income, occupation, hobbies/interests;
details of products and services you have either enquired about or purchased from us, any further information given in order to respond to your enquiries or deliver the relevant products and services;
any other information relating to you and provided by you either directly or indirectly to us or our representatives from time to time.
Other information we may collect
We collect anonymous information on website activity. We use this data to evaluate our website’s performance and to improve the content we display to you. To evaluate the effectiveness of our website, we may utilise the services of third parties for the purposes of collecting statistical data. On these occasions no Personal Information is collected. IP addresses (the electronic address of a computer connected to the internet) may also be logged to analyse trends, administer our website, track users’ movements, and gather broad demographic information.
Our website uses Google AdWords, Google Analytics, and the Google Display Network together to serve ads to you on other websites after you have visited our website. This practice is known as remarketing and is a tool that Google offers to businesses. If you would like to opt-out of receiving advertising like this from Google, you can manage these settings by visiting the Google Ads Preferences Manager.
Our website also utilises cookies (a tracking technology) to recognise your browser each time it visits our site, and to track which pages you visit whilst on our site. This information is used for site optimisation and to improve the online experience for our customers. Websites generally transfer information from cookies to a computer’s hard disk for the purpose of record keeping. Web browsers are usually set to accept standard tracking technologies like cookies. These tracking technologies do not personally identify users but do identify a user’s browser. If you would prefer not to receive cookies, your browser can be adjusted to refuse them.
Collection of your Personal Information
Personal Information is collected directly from you unless it is unreasonable or impracticable to do so. We may collect Personal information in ways including (but not limited to) through:
your accessing and use of our website;
conversations between you and our representatives;
your online purchases;
your enquiries for further information on products or services, or by registering your details on our website;
participation in surveys and other research modes;
entering of promotions, sweepstakes, or contests hosted by us;
subscribing to our mailing list; or
providing information via our social media pages (eg Facebook or Twitter).
Information from third parties such as credit reporting agencies, law enforcement agencies, and other government agencies may also be collected.
What happens if we can’t collect your Personal Information?
If you do not provide us with the Personal Information described above, the following instances may happen:
we may not be able to provide the requested products or services to you, at a specific standard or at all;
we may not be able to provide you with information about our specific products and services; or
we may be unable to tailor the content of our website as you would like, and you may find our website less useful.
Reasons for collecting, holding, using and disclosing your Personal Information
We use, collect and hold your information to understand your needs better and provide you with better service. We may share your Personal Information amongst Related Bodies Corporate as defined in the Corporations Act 2001 (Cth). We may also use, collect, hold and disclose your Personal Information:
for the purposes of completing a transaction online via our website, and deliver products and services to you;
to address your queries or customer service issues via various communication methods.
to carry out business processes including providing Personal Information to our Related Bodies Corporate, contractors, service providers or other third parties;
when responding to social media;
in order to keep you updated about our products, services, events or promotions we think may be of interest. You can “opt-out” from this marketing activity at any time;
to improve your online experience with us and assist us with completing your transactions faster;
to give you access to specific areas of our website; and
for planning, marketing or research purposes.
Disclosing your Personal Information
Your Personal Information may be disclosed by us to:
Related Bodies Corporate, our employees, contractors or service providers for the purposes of operating our business and website, fulfilling requests made by you, and to otherwise provide products and services to you including, without limitation, IT systems administrators, web hosting providers, mailing houses, payment processors, data entry service providers, electronic network administrators and professional advisors (eg lawyers, accountants and business advisors);
other third parties and suppliers that we have commercial relationships for business, marketing and other related purposes;
any organisation for any authorised purpose with your express consent; and
to comply with relevant laws.
Personal Information may be disclosed to our Related Bodies Corporate and third party suppliers and service providers who may be located overseas for some of the purposes listed above. All reasonable steps are taken to ensure that overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information.
Direct marketing materials
From time to time direct marketing communications and information about our products and services that you may have an interest in, may be sent to you. These communications may be sent via mail, SMS, social media, fax and/or email and in accordance with applicable laws, such as the Spam Act 2003 (Cth). We will endeavour to utilise your preferred communication method where you have indicated it, whenever it is practical to do so.
You can elect to be removed from all marketing communications at www.tomwaterhouse.com/optout.
We do not provide your Personal Information to other organisations for the purposes of direct marketing.
Access and correction of your Personal Information
Requests for access to any Personal Information we hold about you at any time can be made by contacting our Privacy Officer via the contact details below. Where you are entitled to access information that we hold, we will endeavour to provide you with the relevant information in a suitable format (eg by email or mail). A maximum fee of $20.00 may also be charged by us to cover our reasonable costs in providing the information to you. There will be no charge for you to simply make a request or to make any corrections to your Personal Information.
There may be instances where access to the Personal Information we hold may not be granted. In some instances, we must refuse access if granting access would potentially interfere with the privacy of others or a breach of confidentiality could result. In these instances, you will be provided with written reasons for such refusal.
If you believe that we are holding incorrect, inaccurate or incomplete Personal Information about you, then you may ask us to amend it. If after consideration, we believe the information requires amendment, we will do so. However, should we not agree that there are grounds for amendment then we will add a note to the Personal Information stating you disagree with it.
Breach of privacy
In the event that you believe your privacy has been breached, please contact the Privacy Officer (below) providing details of the incident so that it can be investigated. An investigation of a privacy breach may involve: assessment; immediate action to contain the breach; coordinating a response by a designated person or team; consideration of the Personal Information involved; determining whether the context of the information is important; determining the cause and extent of the breach; identifying what the risk of harm is (if any); performing a risk analysis (if required) and determine whether notification is required.
Third party websites
Links to any third party websites on our website are provided solely as a convenience to you. Using these links will result in you leaving the relevant Tom Waterhouse website. We hold no responsibility for any third party websites, their content or their usage of your Personal Information.
We will take all reasonable precautions to ensure the security of your Personal Information and protect this information from loss, alteration or misuse.
Contacting us / Privacy Officer
If you have any questions about this Policy, or any concerns or complaints relating to your Personal information or a possible breach thereof, please contact our Privacy Officer using the details set out below. All requests or complaints will be treated confidentially, and you will be contacted by a representative within a reasonable time after receipt of your request or complaint to discuss your concerns and options for resolution. We will endeavour to resolve any complaint in a timely and appropriate fashion.
Tom Waterhouse Holdings Pty Ltd Privacy Officer contact details:
Tom Waterhouse Holdings Pty Ltd
Level 6, 73 Walker Street, North Sydney NSW 2060