This policy sets out how and why Conpago Pty Ltd and its related entities, including Conpago Trading Co Pty Ltd ACN 658 846 916 (we,us, or our) collect, use, hold and disclose your personal information (which we call information).
However, this policy does not apply to any information that is not ‘personal information’ as defined in the PrivacyAct 1988 (Cth) (Privacy Act), despite us using the term ‘information’ in this policy.
We are committed to being transparent about our management of your information and take all reasonable steps to ensure our practices and procedures relating to our activities comply with any applicable requirements in the Privacy Act, including complying with this policy.
We do so by striving to adhere to the following principles:
We will not use or disclose your information for purposes unrelated to our business’ services and activities, unless we first obtain your consent or where doing so would not breach applicable privacy laws.
By engaging with our business or by providing your information to us, you consent to our collection, storage, use and disclosure of your information, in accordance with this policy.
Your information is important to us as we may require it in order to conduct our business and provide our products and services to you. We refer to our business activities(including the supply of our goods/products, our support services such as product training and customisation of our goods/products) as our Products in this policy.
In order to conduct our business and provide our Products most effectively, we will be required to rely on the collection of information that is provided to us. Some of the reasons for why such information may be required include the following:
- to process your orders for our Products, including accepting your orders, arranging for you to access our systems (whether via our website or otherwise), providing proposals for potential engagements, arranging for the delivery of Products (if agreed),liaising with you in respect of our Products or any defects in our Products and any similar matters;
- to make our website available to customers to facilitate a customer-friendly platform whereby we can showcase our Products, in which case we will collect information regarding your interaction with our website so we can improve it and to handle enquiries, and complaints placed via our website;
- to enable us to provide accurate advice and our Products to you, including to allow us to tailor our Products and provide more personalised Products;
- to add value to our services especially when we are dealing with you and provide assistance with the selection of our Products and the like;
- to continually enhance and improve our services to our customers and our Product offering, as well as allowing us to notify our customers and those we deal with regarding newProducts that are available where we consider they may be interested in those new Products;
- to allow us to better understand the needs of our clients, business partners and those that we deal with as part of our Products;
- to provide updates, promotional communications and the like to you where you have subscribed for same;
- to comply with all applicable laws and regulations in fulfilling our obligations to our customers and other businesses and persons we deal with.
We refer to the above matters and the other purposes for which we may collect and handle your information as our Activities in this policy. Our Activities also include any functions or purposes that we may specify to you at the time of requesting the information, as well as any other functions or purposes for which you provide us the relevant information.
We may also need information to perform functions that are incidental to, or are otherwise reasonably necessary for us to, operate our business, conduct our Activities or provide our Products.
In order to achieve the above, we rely on you to provide us with accurate information to enable us to provide you with continually improving Products and to continually improve our services and support.
The types of information we may collect, hold, use or disclose will depend on your interactions with us. Examples of the types of information we collect are set out below.
Personal Information you provide to us directly: we may collect and hold information you provide to us directly. For example, such information may include:
Sensitive information you provide: We will generally not collect ‘sensitive information’ (as defined in the Privacy Act)from you, unless you provide that information to us directly. However, we may collect sensitive information directly from third parties in order to conduct our Activities. For example, if you are resident at an aged care facility or the like that we service, then we may obtain your health information and other sensitive information from third parties to enable the functioning of our Products and enabling high-quality, personalised care to you.
Information from third parties: We may collect information about you from third parties, such as where your accountant, agent or a person purchasing products on your behalf provides us with your information or where us or our insurers are investigating a claim in respect of our Products.
Information we create using your information: We may develop information using your information. For example, where you make a complaint, we may develop and keep a record of the complaint which may contain your information. We may develop information in the form of internal quality assurance reports, evaluative reports regarding our sales target and customer satisfaction data or record of interactions, file notes and/or any recorded phone conversations with you that may be kept for quality assurance purposes.
Information we collect automatically: We may collect information about you automatically when you visit our websites, such as your IP address and device type. Some of this information may be collected using cookies and similar tracking technologies.
Public information: We may collect information from publicly available sources such as ASIC records, credit history details(provided we have your consent to obtain the relevant credit report).
Our general practice is to collect information directly from you, as and when required, such as when you contact us expressing a desire to purchase ourProducts or conduct business with us or where you provide the information in response to requests in connection with our Activities and in other situations.
We may also collect information from you during your discussions with us either via, email (i.e. when you email us with your queries), telephone (i.e.when you might call us with your queries), web queries (i.e. when you interact with our website), through in person discussions, through online forms, contracts, and/or social media networking platforms (such as Instagram, LinkedIn and Facebook).
You have the option not to provide any information that we request. Depending upon what information you do not wish to provide, we may not be able to deal with you or your requests further on a particular matter. For instance, if you make a complaint but refuse to provide your contact information, then we may not be able to process or escalate your complaint. Where you provide us with information on request, we do so on the understanding that you consent to our collection because you have this option to refuse to provide that information.
You may have the option not to identify yourself or identify yourself by a pseudonym. However, this is not generally practical for us as we need to know who you are to contact and liaise with you and to process your orders, to ensure that you are authorised to provide credit card information to us and in order to best provide you our Products or conduct our Activities. For example, if you are a customer needing our Products, we will need to know who you are so that we know who we are entering into a contract with, so we can contact you to clarify any information that may have been provided and so that we can contact you to clarify any information that may have been provided. Further we may need your legal name when you propose to enter into a contract with us, as we are generally required to know who we are dealing with in those circumstances.
Where we collect information about you from someone other than you, this is generally because it would be unreasonable or impracticable for us to do so.
Sometimes you may voluntarily provide us with information that we have not requested. If this happens, we may use and disclose the information to determine whether we could have collected the information had we requested it. If we consider that we could not have collected the information, then we may either destroy or de-identify that information as soon as reasonably practical where required bylaw.
Your information may be stored in hard copy, electronically or both. We do not adopt or use any identifiers that a government agency may have assigned to you.
Electronic information may be stored on our computer systems and networks and on our customer relationship management platforms, our accounting platforms and our email platforms. Our digital systems are protected by mechanisms which may include passwords, firewalls, antivirus software, scheduled password changes, internal access limitation processes and internal monitoring, depending on the relevant system.
Where we store your information, we take reasonable steps to ensure it is protected from misuse, interference, loss or unauthorised access, modification or disclosure. However, we cannot guarantee that this will never occur. If a serious data breach occurs, and we believe your information has been compromised, we will assess the breach as soon as we become aware of it and take all reasonable and necessary steps as prescribed under Australian privacy laws.
We also take reasonable steps to destroy or permanently de-identify information that we no longer need for any purpose required by law.
The amount of time we may keep your information will depend on the circumstances and whether we have an ongoing business need to retain it (such as whether we have agreed to provide you with Products and the Products are still within a warranty period offered by us or under law or whether we need to retain it due to legal requirements such as financial reporting legislation, product defect laws or the like).
We will retain your information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our internal retention policies and practices. Following that period, we will make sure such information is deleted or anonymised where required by law.
We may use your information to perform our Activities (as outlined above) or any activities that are related (or in the case of sensitive information, directly related) to the performance of our Activities. We may do these things without your prior consent where the law allows or requires us to do, including where it is impracticable for us to obtain your consent.
We may provide your information to regulatory authorities where required from time to time. We may also provide your information to third parties such as our professional advisors, third-party service providers, any payment providers or any sub-contractors, where they are providing services to us and such information is necessary for them to provide those services.
We may use your information to directly market our Products to you. This marketing material may be sent by email, SMS, MMS phone or post. We may also use information collected about you from other individuals for these purposes where it is impracticable to obtain your consent in advance.
You may ‘opt-out’ or raise any concerns you may have regarding these messages by contacting us through our website available at www.Conpago.com.au or by emailing us at Hello@conpago.com.au or by ‘unsubscribing’ to such emails, SMS messages or any such marketing, where such an option is made available.
We may disclose your information to perform our Activities or any functions that are related (or in the case of sensitive information, directly related) to the performance of those Activities. This may include disclosing information to:
- our related entities where reasonably required to operate the irrespective businesses, including to facilitate the collection of debts on behalf of our related entities or enforce their rights under any agreement between our related entities and us;
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you that relates to our Products;
- third-party service providers or contracts that we engage, such as those that provide our cloud-based computing systems, transport and delivery services or our IT contractors, but we will usually only do this where those third parties are accessing our records generally to help us with any issues we are having, or where specifically needed in connection with any supply of our Products to you;
- analytics and search engine providers that assist us in improving and optimising your use of our website.
We will not otherwise disclose information unless we believe we have reasonable grounds todo so or that we reasonably believe you have provided your authorisation for us to do to. You should be aware however, that we may be required to disclose information without your consent in order to comply with any court orders, subpoenas or any other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will attempt to notify you if we are required by law to disclose your information.
We do not intend to disclose information overseas, unless you have provided the information to us for that purpose, where we are sending Products to you overseas, where you have placed an order or contacted us from oversea or where required by law.
However, there are some circumstances where we may disclose information overseas such as where we use secure cloud storage services that may have servers located overseas or when you communicate with us through a social network service (e.g. Facebook, LinkedIn), and the social network provider and its partners may collect and hold your information overseas.
We may also need to comply with overseas authorities in the event you (or those who you represent) also carry on business overseas and an overseas authority issues us with a valid court order, subpoena or other such legal demand to cooperate with their legal investigations with respect to you.
It is primarily your responsibility to ensure that the information you provide to us is accurate, complete and up-to-date. We may periodically, review your information to ensure that it is accurate, up-to-date, complete and relevant. Where we have reason to believe that your information may not be accurate, up-to-date, complete or relevant then we may either attempt to contact you to correct the information or de-identify or destroy the information as required by law.
You may request access to the information we hold about you, or request that we update or correct any information we hold about you or ask us to restrict or cease processing your information or even delete your information, by setting out your request in writing and sending it by contacting us through our website.
Where you make a request to access your information, we will do our best to respond within a reasonable period. While we may allow access and provide the means by which you can access your information, we may refuse the request where we are entitled to do sounder the Privacy Act or at law. In this event, we will tell you the grounds for this refusal as well as suggested steps which may allow you to access your information in the circumstances of our refusal. You may complain about this refusal by making a complaint as set out below.
Our website uses persistent and session cookies. Persistent cookie allows a website to recognise users when they return to a site and keep certain information on user preferences. These cookies may stay on a computer until they are deleted by the user. Session cookies allow a website to carry over information from one page to another so that a user does not have tore-enter information. These cookies deleted themselves at the end of the session or at a certain time.
We also use traffic log cookies including third-party partners such as google and Facebook to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. These cookies also allow us to display promotional material on other sites you visit across the internet. You can manage your preferences in relation to targeted online advertising directly through digital platforms such as Google or Facebook.
If you would like details of the specific cookies we use on our website, please contact us via the details below.
If you have any concerns or are unhappy about how your information is handled, please contact us at:
Post: 2/35Amelia St, Fortitude Valley QLD 4006
Upon receipt of your concerns we will designate an appropriate individual within our organisation who will liaise with you regarding the complaint and how it can be resolved. We will do our best to provide a response to your complaint within 30 days of receipt. If it will take longer, we will contact you to let you know why and ask for more time.
If you would like more information regarding Australian privacy laws, or to make a complaint, refer to the Office of the Australian Information Commissioner who can be contacted at:
Address: GPO Box 5288, Sydney NSW 2001
Phone: 1300 363992
This policy will be routinely reviewed to ensure it is accurate, up-to-date and complies with any and all updates under Australian privacy law.The current policy is published on our website or can be obtained by contacting us using the information above.
Where we amend the terms of this policy from time to time, we will notify you of any changes by posting an updated version of this policy on our website. It is your responsibility to check the website periodically for any changes.
This policy was last reviewed and updated on 13 March 2023.
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