1. ABOUT THIS POLICY
This site is owned and operated by QDA Pty Ltd (ABN 67 619 753 838) (trading as “Clive Smallman”). Protecting your privacy on the internet is of the utmost importance to us. At Clive Smallman, we want to make your online experience satisfying and safe.
2. COLLECTION AND STORAGE OF PERSONAL INFORMATION
2.1 Why do we collect your personal information?
If you are our customer, at all times we try to only collect the information we need to carry out the particular functions or business activities you’ve asked us to, while providing the highest quality customer service. Reasons for collecting your personal information may include (but aren’t limited to): providing products, services or communications; answering enquiries, assessing the performance of our websites, with a view to improving them where required; giving you access to protected areas of our websites; conducting business processing functions, including with related bodies corporate, contract service providers and other third parties; to update our records; to reply to any complaint you may make; and to comply with any Government law, rule, regulation or direction.
If you are an applicant seeking employment or appointment as a contractor, we collect only the information needed to assess your suitability for the role.
2.2 What personal information do we collect and hold?
The personal information we collect and store depends on why you contact us and which Clive Smallman services and products you enquire about or order, or the role you are applying for with us. The information may include: your name; mailing or street address; email address; website address; telephone number; fax number; ABN; credit card details; bank account details: age or date of birth; profession, occupation or job title; details of products and services you’ve purchased from us or enquired about, and any additional information required to deliver those products and services or reply to your enquires; and any additional personal information you provide us from time to time through our websites, services team or representatives.
2.3 How do we collect personal information?
Unless unreasonable or impracticable, we collect your personal information directly from you. There are several ways we may seek this information, including: through your access and use of our websites and mobile apps; when you complete an online application or form (e.g. “Contact Us” or “Send Enquiry” forms); during conversations between you and our representatives; through your interaction with us via email; through your interaction with us via our social media channels (which have their own Privacy Policies); or if you apply for a job with us.
We may also collect personal information indirectly from third parties including: publicly available sources; third party companies such as credit reporting agencies, law enforcement agencies and other Government entities; our network of partners, resellers and affiliates; or your authorised representative, if you have one.
Aggregate Information, Cookies and Other Tracking Technologies
From time to time, we may collect general, non-personal, statistical information about the use of Clive Smallman’s websites such as tallying page views by users, the length of time they spend on each page and tracking user traffic patterns generally. We collect this information through the use of “cookies” and other tracking technologies. A cookie is a small text file we may place in the browser files of your computer. The cookie itself does not contain personal information (although it will enable us to relate your use of the site to information you’ve specifically and knowingly given). The only personal information a cookie can contain is information you submit yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites.
We use tracking information to determine which areas of our sites users like and don’t like based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This enables us to enhance the website for users and continue building better products and services for you.
We may also group this information into aggregate user data to, for example: analyse trends and track user movements, then present that website data to our existing or potential business partners, sponsors, other third parties; or in reply to a Government request. However, we assure you, this aggregate data will not personally identify you or any other website users. Because we don’t track the usage patterns of individual users, an advertiser or sponsor will never know that a specific user clicked their ad.
Tracking technologies may record information such as: internet domain and host names; internet protocol (IP) addresses; browser types; and the time and date pages on our site are accessed. Clive Smallman does break down overall usage statistics according to a user’s domain name, browser type and MIME type by reading this information from the browser string (information contained in every user’s browser).
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, you may opt-out of participating in certain interactive areas, which completely removes your need to provide us with personal information.
Generally, however, to provide our products and services we usually need your name and contact information and enough information about your particular inquiry or request to enable us to fairly and efficiently handle it.
3. WHAT IF YOU DON’T PROVIDE US WITH YOUR PERSONAL INFORMATION?
If you don’t provide your personal information to us, we may not be able to: properly provide our products or services to you (either to the same standard or at all); let you know about other products and services you may want eg discounts, special promotions; nor provide interactive or personalised elements on our sites to make your use of it more enjoyable.
4.1 When do we disclose personal information?
Your privacy and the protection of your personal information are very important to us. We may share your personal information with related bodies corporate and our employees who have a “need to know” that information. We may also disclose your personal information to our contracted service providers for the purposes of operating our websites or Clive Smallman’s business (including marketing), fulfilling your requests or otherwise providing our products and services to you. Our service providers include (but aren’t limited to) web hosting providers, IT system administrators, payment processors, debt collectors and professional advisors e.g. accountants, lawyers and consultants.
We will take reasonable steps to ensure our service providers are required to protect personal information on our behalf. Clive Smallman never shares personal information with unaffiliated third parties, such as marketing, advertising, sponsors or partners. In the event Clive Smallman or its assets are sold, it’s likely our customer and user information (including personal information) will be one of the assets transferred, and by using our websites, you consent to this. We may disclose your personal information to any person or organisation for any authorised purpose with your express consent.
We reserve the right to use IP addresses and other tracking technologies to identify a user and disclose their personal information only when reasonably necessary to protect our websites, users or the public from damage, injury or harm (either intentionally or not); to enforce compliance with our Terms & Conditions, or to comply with the law or valid legal process.
4.2 Disclosure of personal information overseas
We may disclose personal information to our related bodies corporate and entities situated outside Australia to carry out our business functions, including our data hosting and other IT service providers in Clive Smallman.
If you communicate with us via a social network service such as Facebook, the social network provider and its partners may collect and hold your personal information overseas.
5. QUALITY OF YOUR PERSONAL INFORMATION
To ensure the personal information we collect is accurate, up-to-date and complete we: record information in a consistent format; where necessary, confirm the accuracy of information we collect from a third party or public source; promptly add updated or new personal information to existing records; and verify our contact lists to check their accuracy.
We also review the quality of personal information before we use or disclose it.
6. STORAGE AND SECURITY
The security of your personal information is a high priority for us. We may hold your information in either electronic or hard copy form. We take all reasonable technical and physical secure measures to protect it from accidental or unlawful destruction, misuse, interference and loss, and from unauthorised access, modification or disclosure. Steps include: conducting internal audits to assess whether we’ve adequately complied with security requirements; imposing physical security measures to prevent unauthorised access to rooms or systems storing personal data; requiring all employees to sign a confidentiality clause as a condition of their employment; and electronic security measures in our system including firewalls and data encryption. As our websites are linked to the internet, and the internet is inherently insecure, we can’t guarantee the security of any information you transmit to us online. Accordingly, any information (personal or otherwise) you transmit to us online is transmitted at your own risk.
7. DIRECT MARKETING
We may send you direct marketing communications and information about our products, services, discounts, and special promotions we think you’ll be interested in. Communications may be sent via email, telephone, SMS, mail or any other electronic means, in accordance with the Spam Act 2003 (Cth).
You are free to opt-out of receiving our marketing communications at any time, simply by emailing us at email@example.com or using the opt-out facilities provided in the communications. We’ll ensure your name is removed from our mailing list.
8. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information. You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.
We will ask you to verify your identity before we give you access to your information or correct it, and we’ll try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons.
If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.
If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why.
9. HOW TO MAKE AN ENQUIRY OR A COMPLAINT
submitting an electronic contact form via Contact Us Online page
calling Clive on +61 (0)404 452 076
emailing us at firstname.lastname@example.org
writing to us at Unit 41, 23-35 Crane Road, Castle Hill, NSW 2154, Australia
We are committed to doing the right thing by our customers, by treating your question or complaint confidentially, and replying quickly. If you are not satisfied with our response you may ask for a review by a more senior officer at Clive Smallman (if that has not already happened). If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner: