Last updated April 04, 2023
1. Our Commitment to Privacy
Clean TeQ Water Limited (Clean TeQ Water) recognises the importance of privacy and is committed to protecting the privacy of its shareholders, employees, and other related parties when handling your personal information. From the outset, it should be noted that all information or opinion about you as an identified, or reasonably identifiable, individual (that is in Clean TeQ Water’s control) is handled and managed with the utmost confidentiality by Clean TeQ Water.
In this policy the expressions ‘the Company’, ‘we’, ‘it’, ‘us’ and ‘our’ are a reference to Clean TeQ Water.
4. What is Personal Information?
The expression ‘personal information’ is used in this policy to refer to information or an opinion about you from which you can be reasonably identified.
5. What is Sensitive Information?
The expression ’sensitive information’ includes personal information about a person’s racial or ethic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record or health, genetic and biometric information.
6. Why we collect Personal Information?
The Company only collects personal information so that it can administer your investment in the Company, carry out its business and comply with its legal obligations (Primary Purpose). Examples include providing and managing the services you request and the distribution of company information and reports. If the Company does not collect your personal information, it may not be able to provide you with the services and products of your choice.
7. What kinds of Personal Information do we collect?
The types of personal information which we may collect and hold include, without limitation:
- your name;
- address and other contact details;
- date of birth;
- tax file number (TFN);
- banking details and credit card information; and
- Billing, credit and payment
Generally, the Company will not collect sensitive information about you. If the Company needs sensitive information, it will seek your consent when it collects this information and comply with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).
8. How do we collect Personal Information?
Collecting information from you
How the Company collects your personal information will largely depend on whose information it is collecting. If it is reasonable and practicable to do so, the Company will collect personal information directly from you.
Depending on how you choose to interact with the Company, the Company may collect your personal information when you contact the Company or its service providers by telephone, by email, through the Company’s website or when you complete a form or document and provide it to the Company.
Collecting information from third parties
Collecting information from visits to the Company’s website
The Company may collect information based on how you use its website including through ‘cookies’, web beacons, and other similar technologies. Cookies are small text files that websites or apps may place on your computer or device to collect non-identified/anonymous information about the users of its website such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to the website.
No attempt is made by the Company to use this information to personally identify you. We record a variety of information from interactions with our online services including IP address, location data (where available and not disabled by the user), dates, times, and other user activity. In most cases, we will not be able to reasonably identify an individual from the information collected. However, if cookie information is linked with personal information we hold about you as set out above, this cookie information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser.
If the Company receives personal information that it has not requested, or it determines that the personal information received is not reasonably necessary to provide its services, the Company will take reasonable steps to de-identify or destroy that personal information.
9. How we hold your Personal Information?
The security of your personal information is of paramount importance to the Company and it takes reasonable steps to protect the personal information it holds about you from misuse, loss, unauthorised access, modification, or disclosure. The Company has a number of safeguards in place to protect the personal information we hold, including password-protected databases, staff training, and system firewalls. The Company maintains password security and restricted access to all electronic documents containing personal information
All employee-related documentation is kept within a secure server, which is only accessible by the Human Resources department.
The Company’s payroll is outsourced to a third-party provider, ADP Australia. Within ADP, the collection and use of personal data is limited to those elements that are reasonably needed only to achieve the specific purposes permitted by the Company or its employees.
Personal Data is retained in accordance with the records retention schedules to ensure that records containing Personal Data are retained as needed to fulfill the applicable Business Purposes, to comply with applicable laws, or as advisable in light of applicable statutes of limitations.
The Company will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purpose for which the information was used or disclosed.
10. How do we use your Personal Information?
The Company will not use or disclose personal information that we collect for any purpose other than the primary purpose of collection unless:
- such use is related to the primary purpose and you would reasonably expect us to use or disclose the information for that other purpose;
- in the case of direct marketing not related to our activities – we have obtained your prior consent (unless it is not reasonably practicable to seek your consent and we otherwise comply with the requirements of the Privacy Act); or
- the use or disclosure is otherwise permitted under the Privacy Act or required to comply with any relevant laws, regulations, codes or practice and court orders.
As a general rule, we do not engage in direct marketing activities. To the extent that we do engage in direct marketing in the future, however, you may at any time request us not to provide you with any further direct marketing communications by contacting us via the details set out below.
By using our website, you will be deemed to consent to us using your personal information collected by our website for the following purposes:
- notifying you about any changes to the information which currently exists on the website;
- notifying you in the future about new information relevant to our services; and
- monitoring your use of our
11. How is Personal Information disclosed to Others?
The Company does not sell, rent or trade personal information to, or with, third parties.
The Company’s website may contain links to other websites. The Company does not share your personal information with those websites, and it is not responsible for their privacy practices.
In some circumstances, your personal information may be disclosed to service providers that perform a range of services on behalf of the Company including:
- mailing houses and printing companies;
- auditors and solicitors;
- share registry providers;
- information technology vendors; and
Personal information may be disclosed to third parties within or outside of Australia.
When making public or disclosing information that was prepared using personal information, where practical we will de-identify, aggregate or anonymise the information to remove the personal information.
If the Company transmits your personal information over the internet (for example to third parties who hold data outside Australia) we will take reasonable steps to maintain the security of any personal information to prevent misuse and unauthorised access. Despite these protection mechanisms, you should be aware there are inherent risks associated with the transmission of data over the internet and we cannot guarantee any transmission will be completely secure.
Where the Company discloses your personal information to its service providers, it will take steps to ensure that they are authorised to only use personal information in order to perform the functions required by the Company or you and in accordance with the Privacy Act 1988 (Cth).
The Company may also disclose your personal information to law enforcement agencies, courts or government agencies where required to comply with specific legal requirements. In particular, the Corporations Act 2001 (Cth) requires certain information about you to be included in the Company’s registers which are able to be accessed by the public.
12. Do you have to provide Personal Information?
You can refuse to provide personal information. However, a refusal may mean that we are unable to provide the service you or an organisation has asked for, for example, if we propose to provide a service and we are unable to complete the process to do so.
13. Data Security
We will take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. Any personal information which is no longer required for any purpose by the Company will be destroyed.
The company will also take reasonable steps to ensure that personal information shared with third-party service providers, such as ADP, has implemented reasonable technical, physical, and administrative safeguards to help protect the sensitive personal data stored within their systems from unlawful use and unauthorized disclosure. Where relevant, the effectiveness of the safeguards and controls in place with third party providers will be reviewed, such as obtaining annual independent System and Organisation Control reports.
14. Ensuring your Personal Information is up to date
It is important that the personal information we collect from you is accurate, complete, and up-to-date.
During the course of our relationship with you, we will ask you to tell us of any changes to your personal information. However, you can contact us at any time to update your personal information or to tell us that the information we hold about you is inaccurate or incomplete.
15. Access, Correction, and Further Information
We will provide you with access to your personal information held by us, unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us on the details below if you:
- wish to have access to the personal information which we hold about you;
- consider that the personal information which we hold about you is not accurate, complete or up to date; or
- require further information on our personal information handling
you may lodge a complaint by writing directly to the Company. We will endeavor to respond to your request within 30 days. All such complaints will be handled with the appropriate discretion.
If you are not satisfied with the result of your complaint to the Company or if your complaint remains unresolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.
Further information on the Act and the Australian Privacy Principles, can be found at www.privacy.gov.au.
16. How to Contact Us?
All correspondence should be directed to the Privacy Officer on:
Tel: +61 3 9797 6700
E-Mail: [email protected]
Mail: Clean TeQ Water Limited PO Box 227 Mulgrave VIC 3170
From time to time, we may change our policy on how we handle personal information or the sort of personal information we hold. Any changes to our policy will be published on our website www.cleanteq.com.
18. Approved and Adopted
This policy was reviewed, approved, and adopted by the Board on 27 February 2023.