Our Commitment to Privacy
Collection of Information
S3 is required under various legislation and codes of practice to collect certain information about you in order to provide our range of services. These include, but are not limited to, the Corporations Act, Income Tax Assessment Act as well as certain regulations issued by the Australian Securities and Investments Commission (ASIC). In addition, our ability to provide you with comprehensive and quality services is reliant on us obtaining certain information about you. The staff and representatives of S3 may request personal and sensitive information (as those terms are defined in the Privacy Act 1988 (Cth) from you, which will generally comprise, but not be limited to, the following type of information:
If you do not provide us with the information required, we may elect to terminate our relationship with you, if we believe it will jeopardise our ability to provide you with a complete, accurate and comprehensive service.
When you visit our website, we may collect certain information, which may include information that you voluntarily disclose and information that is automatically collected such as:
It is unlikely that any one piece of this information alone will be able to tell us who you are, but it can still considered to be “personal” information and in conjunction with other information we hold about you may identify you.
You may browse some information-only areas of the Wise-Owl Website without providing any information, however, we may not be able to provide the full range of services through the Wise-Owl Website if you do not provide the information outlined above.
Use and Disclosure of Information
Any personal information about you collected by S3 will be used for the following purposes:
The organisations we may be required to disclose information include, but are not limited to:
From time to time we are required to disclose information to other organisations to comply with the laws and regulations governing our provision of services. The organisations we may be required to disclose information include, but are not limited to:
We will not use or disclose information collected about you other than for a purpose made known to you unless the disclosure is:
S3 undertakes not to sell, rent or trade your personal information with the exception that we may provide your contact details to third party suppliers who we believe have services to market to you which will be of interest to you. In such case, we will provide them with only the information necessary to enable the marketing of services to you (for example your name, location and email address). You will always be given the opportunity to opt out of any such communications.
We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however you may request not to receive such information by contacting the Managing Director as set out below.
Other than as set out in this document, we will not otherwise disclose your l information to other parties without your explicit consent.
Storage and Security
We use a number of mechanisms to protect the security and integrity of your information. Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. So while we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us and ou do so at your own risk.
S3 recognises how important the privacy of your personal information is to you. We will therefore, at all times, seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. Your information is generally held in your personal file. Information may also be held in a computer database. All paper files are stored in secure areas. Computer-based information is protected through the use of access passwords. In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure on/ off-site storage facility for a period of at least 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed or de-identified (in our discretion).
S3 will not adopt as our own any identifiers that you may provide to us such as Tax File Numbers, Centrelink reference numbers, Medicare numbers etc.
Transfer of Information Overseas
Please note also that S3 may use overseas facilities to process or back up its information including cloud based applications and servers located outside of Australia. As a result, we may transfer your information to our overseas facilities for storage. However, this does not change any of our commitments to safeguard your privacy. We strive to ensure that any transmission of information cross border relies on secure servers in nations that have privacy and data protection laws substatntially similar to those in Australia in accordance with our commitments to safeguard your privacy. However there is an inherent risk in the use of the Internet and cloud based applications and accordingly we cannot guarantee that your information will not be transmitted to, or intercepted by, parties located in nations that do not enforce such systems.
Transmission of information overseas may also be required either when information is sent directly to you (and you are residing overseas), or to obtain further information from international organisations to aid services provided. Again, to the extent possible, the information will only be transferred to another country where S3 reasonably believes the other country has privacy laws substantially similar those in Australia.
If you are located in a country that does not have privacy and data protection laws substantially similar to Australia, then we cannot make any warranty or guarantee in relation to the protection of any information transmitted to or from you.
Notifiable Data Breach Scheme
We may be required to make mandatory disclosures of any data breach we experience in accordance with the Notifiable Data Breach Scheme (Australia) established by the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth). If we are required to make a mandatory disclosure under the data breach act and that data breach relates to your information, we will notify you of same as soon as practicable in the manner required by the Scheme.
Access Your Information
You may at any time, request access to your personal information and we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We may, prior to providing access in accordance with this policy, require you to provide evidence of your identity to our satisfaction. To the extent reasonably possible, we will provide that information in a form that is able to be accessed and understood by you.
In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal. We will endeavour to respond to any request for access within 14 days depending on the complexity of the information and/or the request and may charge fees for the request of a significant amount of information to be copied or accessed. If you make a general request for a large amount of information, we may ask you to narrow your request to the specific information you are requiring access to if it is reasonable for us to do so. We are not required to provide you with any information that you already have access to or a copy of.
You may also ask us in writing to erase any information that we hold about you. On receipt of such request, provided that same is not required to be retained by us:-
then we will use reasonable endeavours to comply with your request and confirm compliance to you as soon as practicable. Prior to making any such deletions, we may require you to identify yourself to our satisfaction. If we are unable to delete any information or otherwise refuse to do so, we will provide you with a written explanation as to our reasons.
Quality of the Personal Information
S3 is committed to ensuring that your personal information that we hold is accurate, complete and up to date. To assist us with this, please contact us if any of the details you have provided change. Furthermore, if you believe that the information we have about you is not accurate, complete or up to date, please contact us by emailing us at firstname.lastname@example.org and we will take all reasonable steps to correct the information. If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it unless we need to keep it for legal reasons.
General Data Protection Regulation 2016/679 (“GDPR”)
If you are an individual resident of an EU member state, then the GDPR applies to our collection, storage and use of your information. In addition to the general provisions set out in this document, the provisions in this section will apply to you and to the extent of any conflict with the general provisions, the provisions in this section will prevail.
What to do if you have a problem or question
This website uses Google Analytics/AdWords and third-party remarketing cookies to serve advertisements, through third-party vendors including Google, to previous visitors to our website on sites across the Internet. For example, we might display advertisements to previous visitors who viewed certain pages on our site, or who haven’t completed an action on our site, such as submitting a contact form to make an enquiry.
This website also participates in the Twitter Conversion Tracking Program for purposes of serving ads targeted to users’ interests. You may opt out of Twitter interest-based advertising through an applicable opt-out mechanism described here:https://support.twitter.com/articles/20170405 (or any successor URL). Our participation in the Conversion Tracking Program is subject to Twitter’s Policies for Conversion Tracking and Tailored Audiences, at https://support.twitter.com/articles/20171365 (or any successor URL).
We will not ‘spam’ you
We may contact you via email and/or SMS or other addresses which you provide to us in order to:
During the process of subscribing and registering for these updates, You will be required to give Us certain personal information such as your Name, Address, Email Address, etc. and your preferences regarding the updates sent to You from Our website.
We will not send you ‘spam’ (promotional information) without first asking you whether you wish to have promotional information sent to you. All emails sent by S3 will include a suitable method for unsubscribing. Please allow 3 days for this request to be processed.
Our use of Session Recording
S3 at times uses session recording software to capture information regarding how visitors to our websites are interacting with our web pages. This allows us to evaluate and, if necessary or beneficial, modify our website to improve the functions of our website and make it easier and more valuable for visitors to use.
The information collected may include customized data that varies but typically includes information about visitors’ activities on the client’s website, such as how visitors navigate around a web page and the most commonly clicked links on a specific web page.
Your complaint will be responded to within 14 days. It is our intention to use our best endeavours to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.