Sagentrant believes that privacy is an important individual right and is important to our own business and the businesses of our clients and customers.
This document provides general information about our information handling practices. Where we directly collect information from individuals we endeavour to provide more specific privacy statements or disclosures at the point of collection, including on our Web sites.
This statement sets out Sagentrants privacy policy and the practices that will be followed to respect the privacy of individuals who deal with
Sagentrant. This statement is provided in accordance with the Privacy Amendment (Private Sector) Act 2000
(Cth) and the National Privacy Principles (“NPP’s”) which are set out in that Act.
Sagentrant has sought to adhere to the Privacy Act 1988 and to the Guidelines for Federal and ACT Government World Wide Websites published by the Privacy Commissioner, and provides the following privacy statements.
Collecting Personal Information and Data
Personal information and data that in some way identifies you, the user, is collected during interactions with
Sagentrant web site in the following circumstances:
Collection of information
The type of information collected by Sagentrant
regarding individuals generally includes the following:
names
addresses (including e-mail addresses)
telephone and facsimile numbers
date of birth
occupation, gender, education
details about next of kin including spouse and children’s names
financial details
membership of professional associations
social interests.
The information held by Sagentrant
may come from a number of sources including:
potential employees
independent contractors
existing and new contacts and customers
Sagentrant only collects personal information if it is necessary for our business purposes. The information we collect will depend on the purpose for which it is collected – it may be limited to contact details where we interact with the public
(eg in the case of a Web site request or registration, or when you choose to take part in a survey), or it may include more detailed information where a client relationship exists. We rarely need to collect sensitive information (such as health, ethnicity, religion) and will not do so without consent.
Computer Information
Privacy on Our Web Sites
This policy applies equally to any personal information we collect via our Web sites, including the site at
Sagentrant.com.au. Apart from personal information you provide to us intentionally
(eg. where you make a request or complete a registration form), this section explains some other ways in which
Sagentrant collects information via its Web sites.
In order to properly manage our Web sites, we may log certain statistics about the users of the sites, for example the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our Web sites present the best possible navigational experience for visitors.
Whenever a registered member logs in to our Web sites, they will be identified by their user name and password. The information we collect about members’ use of our Web sites is used purely for measuring site performance and in assisting to resolve any technical difficulties.
Because Sagentrant wants your Web site experience to be as informative and resourceful as possible, we provide a number of links to Web sites operated by third parties. You should be aware that we are not responsible for the privacy practices or policies of those sites. We encourage you to review each Web site’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non
Sagentrant web site is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.
When a user looks at Sagentrant
web site, our server makes a record of your visit in a log. It is a necessary part of visiting any web site that the user's web browser provides the machine's identity (its IP address) to the web server so that the server can address the reply to the correct machine. In addition, your browser provides the following type of information:
the user’s operating system;
the user’s server address;
the user’s top level domain name;
the date and time of the visit to the site;
the pages accessed and the documents downloaded;
the referring web site;
the type of browser used.
Navigation and ClickStream Data
Browsing any web site generates a trail of pages visited and the time spent displaying each page, which is useful in the continual evaluation of the site.
Sagentrants service provider monitors the use of the pages you visit for statistical purposes and to help
Sagentrant improve the web site.
Cookies
Cookies are records kept of use of web sites. They can be either session or persistent based. Session cookies are short-lived and used only during a browsing session and expire when you quit the browser. Persistent cookies are stored on your computer, contain an expiration date and may be used to track your browsing behaviour upon return to the issuing web site.
Sagentrant web site does not employ cookies to track user behaviour and therefore does not keep a history of your activity on this site.
It does, however, use a cookie to authenticate members who are logging in to access the restricted areas of the site. A cookie is then used for security purposes only once the member has been logged in. No cookies are used throughout the unrestricted areas of the site.
Use of Personal Information
Sagentrant will only use personal information you provide for the purpose for which it is provided e.g. mailing a requested publication to you.
We generally use personal information for the primary purpose for which it is collected. That may include supplying our services or responding to an individual's request.
Depending on the purpose for which we have collected personal information
(eg. registration for a Sagentrant event or a request for particular information or material), we may store some of the information in
Sagentrants CRM system. Some or all of this information may be available to partners and authorised staff of
Sagentrant for use in accordance with this policy.
We may use personal information for business purposes which relate to the primary purpose of collection. We may also use contact information to market our related services, however, the individual always has the opportunity to elect not to receive further marketing information from us by writing to us at: The Privacy Office,
Sagentrant, 33 Tulip St, Black Rock,
Australia, 3193 or email us on privacy.office@Sagentrant.com
Sagentrant will use the information for our own direct marketing purposes only where:
it is impractical for Sagentrant
to seek the individual’s consent before that particular use
Sagentrant will not charge the individual for giving effect to a request not to receive direct marketing communications
the individual has not made a request not to receive direct marketing communications
in each direct marketing communication with the individual, Sagentrant
draws to the individual’s attention, or prominently displays a notice, that he or she may express a wish not to receive any further direct marketing communications; and
each written direct marketing communication by Sagentrant
with the individual (up to and including the communication that involves the use) sets out
Sagentrants business address and telephone number and, if the communication is made by fax or email or other electronic means, a number or address at which
Sagentrant can be directly contacted electronically.
Internally, we have controls and procedures to ensure that personal information provided to us remains confidential. Our staff are trained in privacy and are bound by strict duties of confidentiality to the Firm and its clients.
We will not collect or use personal information in ways other than as stated in this policy unless we have obtained an individual's consent. In some cases we may specifically request a consent form to be signed. In other cases consent may be implied (for instance, where an individual gives us information after being fully advised of how it will be used).
Disclosure of Personal Information
We do not sell or trade personal information, or allow third parties to use that personal information for their own purposes.
Sometimes, our business needs require that external contractors or suppliers assist us with information handling. This may include such processes as off-site security storage, website hosting, electronic database management, or management of a
Sagentrant event.
If information needs to be accessed by a third party, we attempt to limit that access to the extent necessary for the third party to provide services to us or to perform its functions. We will ensure that those suppliers and contractors are also bound by duties of confidentiality, and by the same privacy obligations as
Sagentrant itself.
In all other cases, we will only disclose personal information to a third party if the disclosure is permitted by law (including under the National Privacy Principles).
We also ask our clients to confirm that they have made their own disclosures or obtained consents before they pass any personal information to us.
Sometimes we may need to transfer personal information outside of Australia, for example to one of
Sagentrants international offices in order to complete or fulfil a request or for operational efficiency. We may also transfer personal information where permitted under the National Privacy Principles.
Newsletters
If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address. Out of respect for our users’ privacy we provide a way to opt-out of these communications.
Security
Security of Personal Information
Sagentrant will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.
Sagentrant will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.
Access to Information
We will provide access to personal information upon request by an individual, unless a request is unreasonable and the National Privacy Principles would permit us to decline that access (for instance, where granting access would infringe another person's privacy).
Clients who wish to gain access to their personal information should contact their
Sagentrant representative. Non-clients may contact us by writing to: The Privacy Office,
Sagentrant, 33 Tulip St, Black Rock,
Australia, 3193 or email us on privacy.office@Sagentrant.com . When you make a request to access personal information, we will require you to provide some form of identification
(eg. driver’s licence or passport) so we can verify that you are the person to whom the information relates. In some cases we may also request an administrative fee to cover the cost of access.
Openness
Sagentrant has set out in this document its policies on management of personal information and will make this document available to anyone who asks for it.
On request by a person, Sagentrant
will take reasonable steps to let the person know, generally, what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information.
Corrections and Concerns
If you believe that information we hold about you is incorrect, or if you have concerns about how we are handling your personal information then we ask that you contact us and we will try to resolve those concerns.
Sagentrant will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up to date.
As a general rule, Sagentrant
will, on request by an individual, provide them with access to their personal information.
Sagentrant may however choose not to provide individuals with access to such information. This would include cases where:
providing access would have an unreasonable impact on the privacy of other individuals
the request for access is frivolous or vexatious
the information relates to anticipated or existing legal proceedings and would not be discoverable in those proceedings
providing access would reveal the intentions of Sagentrant
in relation to negotiations with the individual in such a way as to prejudice those negotiations
providing access would be unlawful
providing access would be likely to prejudice an investigation of possible unlawful activity
providing access would be likely to prejudice activities which are carried out by
Sagentrant on behalf of an enforcement body.
Sagentrant may decide to impose a charge upon the individual to cover the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested.
Identifiers
Sagentrant will not adopt a government agency identifier (such as a tax file number or Medicare number) as its identifier of an individual.
Anonymity
Wherever it is lawful and practical, Sagentrant
will allow individuals the option of not identifying themselves when entering into transactions with us.
Transborder data flows
Sagentrant will only transfer personal information about an individual to a third party who is in a foreign country in specified circumstances. This would include:
where the individual consents to the transfer; or
where Sagentrant has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the
NPPs.
How can an individual complain about possible breaches of privacy by
Sagentrant?
A complaint by an individual regarding an alleged breach of privacy by
Sagentrant should be forwarded in writing to the following address:
The Privacy Office,
Sagentrant,
PO Box 134 ,Southland
Australia, 3192
Email: privacy.office@sagentrant.com
If you are a client you should contact your normal Sagentrant representative.
Effect of Policy
This policy does not form a contract between an individual and
Sagentrant. The policy may also be subject to change. Whenever you need to refer to this policy you should contact us, or check our Web sites, for the most up to date version.
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