1. What is this Policy About?
HulkPack Pty Ltd (“HulkPack”) recognises the importance of ensuring that its customers and stakeholders have confidence in the way handles personal information.
HulkPack is bound by, and committed to, the terms of the Privacy Act 1988 and the Australian Privacy Principles which govern the way in which HulkPack manages personal information. This policy sets out how HulkPack collects, uses, discloses and otherwise manages personal information about its customers and other third parties from whom personal information is collected.
Unless a client states otherwise, HulkPack may use the personal information that a client has provided, so that HulkPack’s related entities and other business partners can promote and market products, services and special offers that may be of interest to HulkPack customers. In addition, this policy also applies to HulkPack with respect to how HulkPacks handles the personal information of its employees and contractors.
2. What is Personal Information?
Personal information is any information about an identified individual, or an individual who is reasonably identifiable. Common examples of personal information are names, addresses, telephone numbers, dates of birth and bank account details.
· HulkPack will only collect information about a client that is reasonably necessary in order to adequately provide the services the client has requested.
· The use or disclosure of personal information collected by HulkPack is subject to approval by its Corporate Communications Department.
· HulkPack may be requested by regulators and/or government agencies to provide certain personal information about customers and is by law obligated to provide such information.
· Customers can request to review personal information held by HulkPack by contacting the Media Communications Department.
3. What Kinds of Personal Information does HulkPack Collect and Retain?
HulkPack only collects personal information that is necessary for one or more of its functions or activities.
HulkPack is subject to certain legislative and regulatory requirements which necessitate it obtaining and holding detailed and accurate information which personally identifies the customers and/or contains information or an opinion about customers (“Personal Information”).
Customers will not collect any Personal Information about a customer except when the information provided to HulkPack is authorised by a customer or a third party to provide that information. Generally, collection of personal information will be obtained in either face-to-face interviews, over the telephone or by way of an electronic subscription form. From time to time additional and/or updated personal information may be collected through one or more of those methods.
The type of information collected by HulkPack may include the customer’s name, date of birth, contact details (including address, email address and phone number), financial information and information about how the customer will use the products and services being provided. This is not an exhaustive list and HulkPack may need to collect additional information in order to assist HulkPack in providing services to its clients.
4. How is Personal Information Collected?
Information may also be collected over the phone or via the internet. Sometimes, information about an individual is collected from other people or organisations.
Unless otherwise permitted by law, or unless it is obvious from the circumstances that you would know or expect the information to be collected, HulkPack will take reasonable steps to ensure that you are aware that HulkPack is collecting the information, the reason why the information is being collected and how the information will be used.
Regardless of how it is collected, all personal information is handled in accordance with this Privacy Policy.
5. Use and Disclosure of Personal Information
HulkPack uses the personal information it holds in order to provide its customers with the products and services they request. No company within HulkPack will use or disclose Personal Information collected for any purpose other than:
(a) the purposes for which it was provided or secondary related purposes in circumstances where the client would reasonably expect such use or disclosure; or
(b) where the client has consented to such disclosure; or
(c) Where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.
HulkPack may disclose clients’ Personal Information to external contractors (service providers) for the following purposes:
(a) maintenance and support of HulkPack’s information technology systems
(b) in the course of reviews by external consultants
(c) financial or legal advice
It is a condition of our agreement with each of HulkPack's external contractors that they adopt and adhere to this privacy policy. Customers can be assured that their personal information will be maintained by any contractor to whom it is disclosed in accordance with this policy. If clients have any concerns in this regard, they should contact HulkPack by any of the methods detailed below (refer paragraph below entitled contact details).
External service providers are only authorised to use personal information for the purpose for which we supplied it. Those organisations are not authorised to use that personal information for their own purposes.
If HulkPack is unable to collect personal information from or about an individual, it may not be able to do business with that individual or the organisation with which the individual is connected.
If the personal information provided to HulkPack is incomplete or inaccurate, HulkPack may be unable to provide that individual or the organisation with the services that they are seeking.
HulkPack may use the Personal Information collected from customers for the purpose of providing them with direct marketing material such as research that may be of interest, to inform them about new products and services or special offers from time to time. However, customers may, by contacting HulkPack by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for the request to be actioned. Please note that personal information will not be used for marketing purposes where the Do Not Call Register Act 2006 or the Spam Act 2003 applies or where it is contrary to any other Australian legislation or regulations.
6. Document Storage and Security
HulkPack will at all times seek to ensure that the Personal Information collected and held is protected from misuse, interference, loss, unauthorised access, modification or disclosure. At all time’s Personal Information is treated as confidential and any sensitive information is treated as highly confidential and stored securely. Sensitive information will only be collected and stored with the individual’s consent and only if the information is reasonably necessary for HulkPack to carry out its functions or is required or authorised by law to be collected.
Access to HulkPack’s premises is controlled by only allowing HulkPack employee and contractors with security passes to access the premises. Unauthorised persons are strictly prohibited from entering our premises. All electronic information is stored on password protected computers.
Any hardcopy Personal Information which holds about you will be maintained in a secure off-site storage facility for a period of 7 years in order to comply with legislative and regulatory requirements, following which time the information will be destroyed.
7. Clients’ Access to Personal Information
Customers may at any time request access to personal information.
HulkPack will, subject to the exceptions listed below, provide access to that information either by:
· providing copies of the information requested;
· allowing clients to inspect the information requested; or
· providing an accurate summary of the information held.
HulkPack will prior to providing access in accordance with this policy, require clients to provide evidence of identity. HulkPack will not provide access to a customer’s personal information if:
(a) providing access would pose a serious and imminent threat to the life or health of a person;
(b) providing access would have an unreasonable impact on the privacy of others;
(c) the request for access is frivolous or vexatious;
(d) the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
(e) providing access would reveal evaluative information generated within HulkPack in connection with a commercially sensitive decision-making process;
(f) providing access would be unlawful;
(g) denying access is required by law;
(h) providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body’s requests that access not be provided on the grounds of national security; or
(i) Providing access could prejudice the prevention, detection or investigation of seriously improper conduct,
either within or external to HulkPack’s operations.
In the event HulkPack refuses customer’s with access to personal information, reasons will be provided.
8. Correction of Personal Information
HulkPack will endeavour to ensure that, at all times, the personal information about customers is up to date and accurate. In the event that customers become aware, or believe, that any personal information which HulkPack holds is inaccurate, incomplete or outdated, clients may contact HulkPack and provide evidence of the inaccuracy or incompleteness. HulkPack will, subject to the exceptions under section 7 above, take all reasonable steps to correct clients’ personal information.
9. Website
HulkPack has implemented procedures and installed equipment to safeguard the security and confidentiality of personal information collected via our website. While it is not necessary to register a client’s personal details to use HulkPack’s website, HulkPack do offer a registration service which will enable a client to receive additional services and information. In the event that clients do register with HulkPack, personal information including the name and e- mail address will be collected.
HulkPack continually reviews these arrangements to ensure that we are doing all that is reasonably and technically feasible at the time to protect your information. Due to the nature of the Internet, HulkPack cannot guarantee that it is totally protected from hackers or misuse.
The HulkPack website contains links to other Web sites whose operator may or may not adhere to a privacy policy or be governed by the Australian Privacy Principles. This privacy policy does not apply if clients access another website through a link from HulkPack’s website. In this case the privacy policy of the owner of the other website (if any) will apply. HulkPack cannot and will not make any warranty or representation as to the practices of any linked websites in the handling of personal information.
If clients have registered with HulkPack and decide, at any time, that they do not wish to receive any further information from any company within HulkPack, they can send an email to the address listed below requesting to be removed from the online registration database. Please allow two weeks for the request to be actioned.
Cookies: HulkPack’s website uses cookies that allow HulkPack to identify user browser while you are using HulPack’s site. Cookies do not identify users, they simply allow HulkPack to track usage patterns so that we can measure the level of interest in various areas of our site. All browsers allow users to be notified when they receive a cookie and elect to either accept it or not. Your internet service provider should be able to assist you to set your preferences.
10. Trans-border Data Flows
HulkPack will not transfer data internationally unless:
(a) we believe that the recipient is governed by laws or rules that would uphold the Australian Privacy Principles similar to the privacy guidelines in the Privacy Act 1988 (Cth);
(b) we have taken reasonable steps to assure us that the information transferred will not be collected, held, used or disclosed inconsistently with the Privacy Act 1988 (Cth); and
(c) the transfer is necessary to disclose information for the purpose for which it was obtained and for any reasonable secondary purpose arising of the primary purpose.
11. Resolving Clients’ Concerns about Access to Personal Information
If clients believe that the privacy of their personal information has been compromised, customers are entitled to complain. Complaints can be made by contacting HulkPack Corporate Communications Department. HulkPack will respond to complaints as soon as possible. It is our intention to use our best endeavours to resolve any complaint to the customer’s satisfaction, however, if you are unhappy with HulPack’s response, customers are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.
12. Contact Details
HulkPack Pty Ltd
3/304 Boundary Street
South Townsville QLD 4810
Phone: 1300 708 235
Email: [email protected]
13. Privacy Commissioner
If an individual is not satisfied with our response to their complaint, they can complain to the Privacy Commissioner online at www.privacy.gov.au or call 1300 363 992.
