The Lamson Group
1. Purpose and Scope
The Lamson Group is committed to managing your personal information openly and transparently and to keeping your personal information safe. We will take all necessary measures to fulfil this commitment, including to:
- comply with the APPs and IPPs;
- ensure that we manage your personal information openly and transparently;
- only collect personal information from you which is reasonably necessary to provide our services;
- tell you how we might use your personal information;
- let you know if we need to disclose your personal information to anyone else (including anyone overseas) and if so, in what circumstances this might occur;
- keep your personal information secure;
- promptly respond to any request by you not to receive direct marketing material from us;
- make sure your personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by us; and
- ensure that, where appropriate, you can access and correct your personal information.
2. What is your Personal Information?
The definitions we use are intended to also capture the definitions used in New Zealand (for example, “personal information” means information about an identifiable individual).
3. What personal information do we collect and hold?
We collect personal information in order to provide our services, to conduct our business and to improve customer service. The types of personal information we collect will depend on how you interact with us. Depending on the exact nature of our relationship with you, the personal information we may collect and hold include your name, age or birth date, current and previous addresses, phone numbers, facsimile numbers, email addresses, profession, preferences for using our website, occupation, job title, credit card information, bank account information, customer service issues or details of your credit worthiness and credit history.
We may also collect:
- details of the products or services you have purchased from us or which you have enquired about together with any additional information necessary to deliver those products and services or to respond to your enquiries;
- any additional information relating to you that you provide us directly through our websites or indirectly through use of our websites or online presence, through our representative or otherwise;
- information you provide us through customer surveys or visits by our representatives from time to time; and
- any additional information that is provided by our customers that have outsourced a business process and related function to us.
We do not normally collect sensitive information about you such as information relating to your health, religion, political beliefs or race. If we do collect sensitive information which is reasonably necessary for the operation of our business functions or activities, we will obtain your consent to do so.
You can be anonymous or use a pseudonym when dealing with us, unless:
- the use of your true identity is a legal requirement; or
- it is impracticable for us to deal with you on such basis.
We will notify you whether the giving of the personal information is compulsory or voluntary for our primary purpose for collection.
There is no obligation for you to provide us with any of your personal information or sensitive information but if you choose not to provide us with your personal information, or remain anonymous, or use a pseudonym when providing your personal information, this may limit our ability to provide the goods or services that you require.
4. How do we collect personal information?
We collect personal information directly from you unless it is unreasonable or impracticable to do so. We may collect your personal information in the following ways:
- when you purchase our goods and services;
- when we respond to your inquiries and requests;
- during conversations, letters or email exchanges between you and our representatives;
- when we obtain feedback from you about our goods and services;
- when we conduct our administrative and business functions;
- when you register for our events, or subscribe to our mailing lists and newsletters;
- when we market our solutions and services to you; and
- through your access and use of our website.
We may at times obtain personal information that relates to you through third parties. Where we do so, we will ask any third parties to confirm in writing that they have legally obtained your personal information and that we have the right to acquire it from them and to use it.
From time to time we may receive personal information about you that we have not requested or taken steps to come to know. In these circumstances, we will only hold onto such information where the information is necessary in our dealings with you. If we determine that the information received is not necessary to our relationship with you then we will take steps to de-identify or destroy the information as soon as is practicable.
5. Our Website, Cookies and Links
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.
Our websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
6. Purposes for which we collect, hold, use and disclose your personal information
We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.
We collect, hold, use and disclose personal information for the following purposes:
- to send communications;
- to manage and maintain our business relationships;
- to respond to inquiries and requests;
- to improve the services and products we provide;
- to inform you about our services and products;
- to obtain feedback from you on our services and products;
- to prevent fraud and other criminal activities;
- to conduct administrative and business functions;
- to provide our services and products;
- to update our records and keep contact details up to date;
- to enable you to subscribe to our website, newsletters and mailing lists;
- to assess the performance of our website and to improve its operation;
- to process and respond to privacy complaints; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
We may also use your personal information for the other purposes related to those described above which would be reasonably expected by you.
We may disclose your personal information to our employees and related bodies corporate for the purposes of operating our businesses, fulfilling requests by you, and to provide products and services to you. We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.
We may also disclose your personal information to various third party service providers who may assist us with a variety of functions including with administration, professional advisory (including legal, accounting and auditing advice), banking, payment processing, credit reporting or technology services. Where we engage third party service providers to perform services for us, those third parties may be required to handle or deal with your personal information. Under these circumstances, those third parties must safeguard this information and must only use it for the purposes for which it was supplied and we will make all reasonable enquiries to try to ensure that this is the case.
Wherever possible, we will limit the information provided to independent third parties to that information required for those third parties to properly perform their functions. Further, our contracts with these third parties will always require the third parties to comply with the APPs and IPPs (or equivalent standards).
Except as set out above, The Lamson Group will only disclose personal information if this is required by law or a court/tribunal order or otherwise permitted under the Privacy Acts.
7. Direct Marketing
We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). At any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list (or where we are using a mailing list provided by our client, we will pass your request on to our client).
We do not provide your personal information to other organisations for the purposes of direct marketing.
8. Accessing and correcting personal information
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
9. Disclosure of Personal Information outside the relevant jurisdiction
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. However, we will only do so where:
In the Australian context:
- it is necessary to complete the transaction you have entered into; and
- you have provided consent; or
- we believe on reasonable grounds that the overseas recipient is required to deal with your personal information by enforceable laws which are similar to the requirements under the APPs; or
- it is otherwise permitted by law.
In the New Zealand context:
- the overseas recipient is subject to the New Zealand Privacy Act as they do business in New Zealand;
- the overseas recipient will adequately protect the information;
- the overseas recipient is subject to privacy laws that provide comparable safeguards to the New Zealand Privacy Act;
- you have provided consent; or
- it is otherwise permitted by law.
Our overseas affiliates are located in the Philippines
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hardcopy form. Personal information is destroyed or de-identified when no longer needed.
As our websites are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information communicated online.
We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
If your personal information is no longer needed, we will take reasonable steps to either delete it from our systems or de-identify it, except where we are required by law or a court/tribunal order to retain the information.
11. Contact us and Complaints
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Please contact our Privacy Officer at:
The Privacy Officer
Lamson Group of Companies
2- 8 Marjorie Street
Sefton NSW 2162
Tel: 02 9743 8577
Fax: 02 9644 1183
The Privacy Officer will respond to you in writing within 30 days of receiving your complaint, setting out what action we will take as a result of your complaint or alternatively providing an explanation to you if there has been no breach of the law.
If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) or New Zealand Privacy Commissioner (whichever is applicable), to have the complaint heard and determined.