Dated 30th July 2018
UCBT Pty Limited (ACN 619 182 688) (“UCBT”) and its related bodies corporate are committed to protecting and maintaining the privacy, accuracy and security of the personal information you provide to us. We abide by and are bound by the Australian Privacy Principles as articulated in the Privacy Act (Cth) 1988 and any other relevant privacy rules and legislation as enacted from time to time. This includes the EU General Data Protection Regulation (GDPR) for persons located in the European Union.
the kind of personal information UCBT may collect about you and how we collect the information;
how we use your personal information;
we may disclose your personal information;
how we protect the information we hold about you; and
how you can access and manage, including transfer and delete, the information we hold about you.
Links to other sites
Our App and website may contain links to other sites, including our business partners who are offering products and services via UCBT’s App or website, that are not owned or controlled by the UCBT. Please be aware that we are not responsible for the privacy practices of such other sites and you access these sites at your own risk. You should therefore familiarise yourself with privacy policies of those sites.
What kind of personal information do we collect and hold?
In the process of conducting our business, we are likely to collect a wide range of personal information from or about you. The type of personal information we collect generally includes:
residential, shipping and billing addresses;
telephone or mobile numbers; and
interests and information about your transactions with us or our business partners, including the products and services provided to you though by our business partners through the use of our App or website.
If you utilise our App or website, we may use technology to collect information as to your activities, including the IP address of your computer (or other devices), your browsing history on our App or website and transactional data including your payment history.
We do not collect "sensitive information" (such as information about ethnic origin, religious or political views, health information etc) from you.
Credit card information
How do we collect personal information?
UCBT collects personal information directly from you when you submit it via the App or website operated by UCBT.
We may also collect personal information from publicly available sources or third parties, such as via our business partners, where we are responsible for delivering goods directly to you, or social media platforms such as Facebook or Twitter.
You have the option of not disclosing personal information to us or to use a pseudonym when dealing with us in relation to any matter, unless it is, in our view, impractical for us to deal with you that way or we are otherwise required by law or authorised by a court or tribunal to deal you on an identified basis.
Cookies and web beacons
Information that you disclose publicly or via social media networks
UCBT provides content on a range of platforms (including social media networks) with interactive features to which you may contribute. If you post your personal information in publicly accessible places or social media platforms, your personal information will become publicly available (subject to, where applicable, any privacy settings you have in place in social media platforms). UCBT will not be responsible for the protection of personal information you choose to publish this way.
How do we use personal information?
UCBT may use your personal information for the purposes for which it was initially collected or purposes related to such initial purpose if such purposes would be within your reasonable expectations. For example, to:
provide you with our services and information in relation our business partners’ products (which may include warranty services, repairs and replacement of products and customer care plan services);
respond to questions;
forecast your future needs for our business partners’ products;
keep a record of our dealings with each other and enable us to contact you when necessary;
develop a data profile to enable us to tailor our services to you; or
(where applicable) conduct promotions in which you participated.
We may also use your personal information for purposes authorised by laws or regulations, such as to prevent or investigate alleged crime or fraud.
UCBT may also, from time to time, use your personal information to contact you to identify promotions, competitions, products and services offered by our business partners that may be of interest to you.
By supplying us your information, you give UCBT permission to communicate with you via email, SMS, MMS, social media and telephone to inform you about products and services offered by us or our business partners which are relevant to you. This permission is not limited in time unless you choose to opt out by contacting us using the contact information provided below, or by utilising an 'unsubscribe' facility on a communication we send to you in which case, UCBT will take steps to ensure you do not receive any future such direct marketing information.
Some clients of UCBT advertise with Google. Google may show you our advertisements based on your previous visits to our site. If you do not wish to see these advertisements you can opt-out by visiting the Google advertising opt-out page here: https://policies.google.com/technologies/ads
Disclosure of personal information
our business partners being the product and service suppliers to you;
financial services providers, such as our banks or third-party suppliers for securing payment of the products or services provided to you via our site, such as PayPal, and where applicable credit report agencies or debt collectors;
technology service providers, such as internet service providers, database management services, digital mail providers who send communications on our behalf, live help service providers and service providers for the prevention of fraud and protection of data;
service providers who perform market research or manage or review the services provided to you;
mailing systems and courier companies which organise delivery of the products you have purchased via the site; and
our professional advisers, accountants, lawyers and auditors.
These third parties may be located in Australia or overseas.
We require these organisations to maintain the confidentiality of your personal information and also seek to ensure that they adhere to the Australian Privacy Principles and any other relevant privacy rules and legislation as enacted from time to time, including the EU GDPR. These service providers are not permitted to use your personal information for their own marketing purposes.
In addition, we may release your personal information under the following circumstances:
when required to do so by a court or under applicable laws or regulation (for example, a subpoena) or where requested by a government agency;
where we consider a company or an individual may be engaged in fraudulent activity or other deceptive practices that a governmental agency should be made aware of; and
to appropriate persons, where your communication suggests possible harm to others.
Rate and review
If you provide a review or rating for a product or service procured through our websites, you agree that we may publish part or all of your review or rating together with your first name and suburb.
UCBT takes reasonable steps to ensure that your personal information is protected from misuse, interference or loss and unauthorised access, modification or disclosure. We have systems and procedures in place to protect your privacy whenever we collect, store, and use or disclose personal information. We will regularly upgrade these systems and review our procedures to ensure high standards of security are used to protect your personal information. As a condition of working for UCBT all our employees sign up to express confidentiality obligations. However, since no system is 100% secure or error free, we cannot guarantee that your personal information is totally protected, for example, from hackers or misuse. If you enter personal information on our site, you should exercise due care to safeguard any passwords, ID number, or other special access features associated with your use of our website.
We will take reasonable steps to destroy or permanently de-identify personal information from our systems which is no longer required by us.
How to access and amend personal information
If you become aware that any information we hold about you is incorrect or out-of-date, please let us know immediately. We will be happy to accept updated personal information in writing from the owner of that information at any time. However, in order to protect your privacy and security, we will take reasonable steps to verify your identity before granting you access or enabling you to make corrections to your personal information.
Our objective is to respond to any request within a reasonable timeframe and no later than 30 days. We will inform you if this timeframe is not achievable.
In some circumstances, UCBT may not be in a position to grant access to personal information, such circumstances include:
providing access is likely to pose a serious threat to the safety of an individual or the public;
providing access is likely to unreasonably impact on the privacy of others;
the request for access is frivolous or vexatious;
providing access would reveal information which relates to existing or anticipated legal proceedings or otherwise impact on any negotiations;
providing access is unlawful (including being unlawful as directed by a court or tribunal order) or is likely to impact on actions being taken in relation to alleged unlawful activities relating to the functions and activities of UCBT; or
granting access would impact on a commercially sensitive decision-making process.
Our contact details are:
UCBT Pty Ltd
94 Beattie St
Balmain NSW 2041
If you believe the UCBT has not adequately dealt with your complaint, you may complain to the Privacy Commissioner, whose contact details are found at www.oaic.gov.au