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SMIcon SOCIAL MEDIA

Privacy policy
 

Effective date: September 29, 2023

 

1. Privacy generally

This privacy policy applies to the handling of personal information by EPS Ehrhardt + Partner Solutions Pty Ltd of Level 18, 324 Queen St., BRISBANE QLD 4000 (EPS, we us, our).

EPS understands the importance of protecting the privacy of an individual’s personal information.  This privacy policy sets out how EPS aims to protect the privacy of your personal information, your rights in relation to your personal information managed by EPS and how EPS collects, holds, uses, discloses, and otherwise manages, your personal information.

In collecting, holding, using, disclosing, and otherwise managing your personal information, EPS will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.

EPS will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time.  Any updated privacy policy will be made available on the EPS website at www.epg.com/au/ or can otherwise be obtained by contacting us and requesting a copy.

 

2. Kinds of personal information collected

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.  During the provision of our software, services, or as a result of our other interactions or dealings with you including on our website or web application, EPS may collect your personal information.

The kinds of personal information that EPS collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information EPS collects may include:

(a) if you or your company register for an account or submit an enquiry with us, your contact information such as your name, employer, postal address, telephone number and contact email address;

(b) the names of your company’s employees and their job title, department, username or similar identifier, postal address, telephone number and email address;

(c) your account information used for accessing our website application and / or services;

(d) marketing data, such as your preferences in receiving marketing from us, or information about your subscription or the way you use our products;

(e) certain location or geolocation information you provide directly or through automated means, if you choose to enable location-based services from your device or one of our applications;

(f) behavioural data of an internet connected computer or device you use when interacting with our website or web application, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site;

(g) any other information that you provide or otherwise make available to us in connection with our website, web application or services.

(h) when you purchase our services:

(i) information relevant to those services, such as your billing and payment information; and

(ii) information regarding your purchasing history with EPS or your other dealings with EPS in relation to our services.

We also collect internet/technology related information from visitors to our website or web based application, including the referring URL, your IP address, which browser you used to come to the site, the country, state or province, the pages of our website that you viewed during your visit, any search terms entered on our website, the operating system used by accessing systems, the website from which an accessing system reaches our website (so-called referrers), the sub-websites, the internet service provider of the accessing system, and any other similar data and information that may be used in the event of attacks on our information technology systems.

EPS may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.

 

3. How we collect personal information

Generally, EPS collects your personal information directly from you.  For example, EPS may collect your personal information:

  • when you register for an account with us, request information or services or otherwise provide us with your details;
  • where you purchase or otherwise receive our services;
  • where you use our website, web application or other services or otherwise interact with us; or
  • if you post information to our social media or other online sites.

However, there may be occasions when EPS collects your personal information from someone other than you, for example:

  • from our other service providers that help us provide our services;
  • from third parties you authorise to disclose your information to us;
  • from cookies, log files and other similar technologies;
  • from an organisation that you are an employee or other representative of; or
  • from a publicly maintained record or other publicly available sources of information including social media and similar websites.

 

4. Purposes for which personal information is used

Generally speaking, EPS collects and uses personal information so that we can develop, improve and promote our services and provide our software and related services.

Some examples of the purposes for which EPS collects, holds, uses and discloses your personal information include to:

  • enable us to supply you with information you request from us;
  • create and maintain a user or customer account for you;
  • personalise the website or application for you;
  • supply our services to you, including our software and related services; 
  • notify you of new or changed services offered by EPS;
  • personalise your experience with our services and help us better respond to your needs;
  • conduct promotions, competitions, giveaways and events;
  • send updates, security notifications, and administrative communications; 
  • contact you to obtain your feedback regarding products or services or to conduct other market research;
  • improve, modify or enhance the website or web application, including the user experience;
  • optimise the content of our website and web application as well as undertake direct marketing (as detailed in paragraph 5 below);
  • analyse information we collect so that we can administer, support, improve and develop our business and the products and services we offer;
  • ensure the long-term viability of our information technology systems and website technology;
  • conduct internal business analysis or other business purposes;
  • prevent misuse of our services, and if necessary, to make it possible to investigate any offences; and
  • comply with the obligations of EPS under any applicable laws.

In addition to the purposes listed above, EPS may use your personal information for other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.

Where personal information is used or disclosed, EPS takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.  You are under no obligation to provide your personal information to EPS.  However, without certain information from you, EPS may not be able to provide products, services or information to you or may be limited in how we can interact with you.

 

5. Direct marketing

In addition to the purposes outlined in paragraph 4 above, EPS may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products or services that may be of interest to you. This may include EPS disclosing your personal information to related companies of EPS or other entities with which EPS has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.  If you do not wish to receive such communications, you can opt-out by contacting EPS via the contact details set out in paragraph 11 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you. 

 

6. Disclosure of personal information

EPS discloses your personal information for the purpose for which EPS collects it.  As a result, generally, EPS will only disclose your personal information for a purpose set out in this privacy policy.  This may include disclosing your personal information to:

  • related companies of EPS;
  • our service providers and contractors and other third parties that provide products or services to us (including our technology service providers or other business or administration service providers);
  • EPS’s professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers);
  • Government authorities where required by law; and
  • people, entities, or other parties considering investing or acquiring an interest in EPS’s business or assets.

EPS may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent, or the disclosure is required or authorised by law.

If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

 

7. Overseas disclosures

Some of the parties that EPS discloses your personal information to are located outside of Australia, including the United States of America and the European Union. 

We take reasonable steps to ensure that any such overseas recipients do not hold, use, or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act. 

 

8. Links to other websites

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website has its own privacy practices, as described in that site’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party and cannot and are not responsible for any information that you may submit to that site.

 

9. Security of personal information

EPS takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification, or disclosure. These processes and systems include:

(a) the use of identity and access management technologies to control access to systems on which information is processed and stored;

(b) the use of endpoint protection, data encryption, firewalls, and other network security tools to control confidentiality, availability, and integrity of the information processed and stored;

(c) requiring employees to comply with internal information security policies and keep information secure; and

(d) requiring employees to complete training about data protection;

Your personal information will be kept on databases held on servers kept in physically and technologically secured environments. Where personal information is held in hard copy, it will be held in controlled, access restricted premises.

EPS will destroy or de-identify personal information in circumstances where it is no longer required unless EPS is otherwise required or authorised by law to retain the information. 

Where you have an online account with us, you are responsible for maintaining the confidentiality of your username and password. You will be responsible for all uses of your membership, whether or not authorised by you. You agree to immediately notify EPS of any unauthorised use of your username or password.

 

10. Access and correction

EPS takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. 

Under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by EPS.  If at any time you would like to access or correct the personal information that EPS holds about you, or you would like more information on EPS’s approach to privacy, please use the contact details set out in paragraph 12 below.  EPS will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. 

To obtain access to your personal information:

  • you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
  • EPS requests that you be reasonably specific about the information you require; and
  • EPS may charge you a reasonable administration fee, which reflects and will not exceed the cost to EPS for providing access in accordance with your request.

EPS will endeavour to respond to your request to access or correct your personal information within one month from your request.  If EPS refuses your request to access or correct your personal information, EPS will provide you with written reasons for the refusal and details of complaint mechanisms.

If you are dissatisfied with EPS’s refusal to grant access to, or correct your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

 

11. Contacting EPS

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact EPS using any of the following contact details:

Email:    info.au@epg.com
Post:      Ehrhardt + Partner Solutions Pty Ltd, Level 18, 324 Queen St., Brisbane QLD 4000
Phone: (+61) 7 3497 5702

 

12. Privacy complaints

Please direct all privacy complaints to dataprotection@epg.com. At all times, privacy complaints:

  • will be treated seriously;
  • will be dealt with promptly;
  • will be dealt with in a confidential manner; and
  • will not affect your existing obligations or affect the commercial arrangements between you and EPS.

EPS will acknowledge your complaint within 14 days of receipt and endeavour to resolve it within one month unless EPS informs you otherwise and seeks your agreement in writing.

EPS will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation.  In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which EPS will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.