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Privacy Policy

Privacy Policy

1. Aim

Jet Technologies Australia Pty Ltd as trustee for the J O T Trust (we, our or us) is committed to complying with its obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).

We are committed to respecting your privacy and protecting your personal information.  Our staff are trained to protect your personal information in accordance with our policies, procedures and systems.

2. Policy

This policy explains how we manage and secure your personal information.  It also describes the kinds of personal information that we hold and for what purposes, and how that information is collected, held, used and disclosed.

This policy also includes our credit reporting policy.  It contains additional information on how we manage your personal information collected in connection with a credit application, or a credit facility. We refer to this credit-related information as credit information.

This policy is easy to access and is available on our website at www.jet-ap.com.  You may request a copy of the policy by contacting the Privacy Officer in accordance with paragraph 15.1 of this policy.

Please read this policy carefully before you provide us with any personal information.

We will review this policy from time to time.  We encourage you to check our website regularly as any updated policy will be available on our website.

3. Types of information that we collect and hold

3.1 General information

We may collect and hold the following types of personal information about you:

(a)             identification information including your name, date of birth, postal address, email address, fax number and telephone number;
(b)             billing and payment details;
(c)             any complaint details;
(d)             name, address and telephone number of 4 references if you make a credit application;
(e)             information about the goods you may order;
(f)              information about any enquiries you may make;
(g)             credit information such as details relating to credit history, eligibility for credit and credit capacity; and
(h)             any other information that we consider to be reasonably necessary.

3.2 Credit reports

When you apply for credit, we need to know if you will be able to meet repayments under your credit contract with us.  As such, we may need to obtain a credit report about you.
Credit reports contain information about your credit history which help us to assess your credit application, verify your identity and manage any accounts you hold with us. We can collect from and disclose this information to credit reporting bodies and other credit providers in certain circumstances, including when you make an application for credit.
The Privacy Act limits the information that credit providers can disclose about you to credit reporting bodies, as well as the ways in which credit providers can use credit reports.

3.3 Credit information

In order to assess your credit worthiness we may need to collect certain information about you from, and give it to, credit reporting bodies.  This information may include:
(a)             identification information (including your full name, an alias or previous name, sex, date of birth, current or last known address, 2 previous addresses (if any), name of current or last known employer and drivers licence number);
(b)             information request details (e.g. where a credit provider has asked a credit reporting body for information in relation to a credit application, including the type and amount of credit applied for);
(c)             payment information (if a credit provider has disclosed default information about you to a credit reporting body and the overdue amount is paid, a statement that the payment has been made); and
(d)             court proceeding information, personal insolvency information and publicly available information that relates to your credit worthiness.

Please note that information we obtain from credit reporting bodies or information we derive from such information is known as credit eligibility information.

3.4 Sensitive information

We may need to collect sensitive information about you.  Unless the information is required or authorised to be collected by law, we will only collect sensitive information with your consent where that information is reasonable necessary for our functions.
In respect of customers, we may collect and hold health information, but only to the extent it is relevant to our business relationship.
In respect of employees, we may collect and hold criminal records, but only to the extent it is relevant to our employment relationship.

3.5  Information required by law
We may also collect personal information about you because the collection of the information is required or authorised by law or a court/tribunal order.

4. Collecting your information

4.1 Collecting personal information

We will, if it is reasonable and practical to do so, collect personal information directly from you.

We may collect your information when:

(a)  you fill out a form (i.e. credit application or an electronic form);
(b) you give us paper correspondence;
(c) you give us information over the telephone, via fax or post;
(d) you interact with us electronically or in person;
(e) you access our website;
(f) we supply goods to you.

4.2 Collecting personal information from other sources

Sometimes we collect personal information about you from other sources where it is necessary to do so. This may happen where:

(a) you have consented to the collection of the information from someone else;
(b) we are required or authorised by law to collect the information from someone else; or
(c) it is unreasonable or impracticable to collect the information from you personally.

Examples of other sources that we may collect personal information from  include, but are not limited to:

(a) accessing information that is publicly available on telephone directories;  
(b) our related entities;
(c) other trade organisations; and
(d) our suppliers, agents and representatives.

4.3 Collecting credit information from third parties

Sometimes we collect credit information about you from the following third parties:
(a) credit reporting bodies;
(b) other credit providers;
(c) debt collection agencies; and
(d) references listed in your credit application.

4.4 What happens if you do not provide us with your personal information?

If you do not provide us with your personal information, we may not be able to:

(a) provide you with the goods you want; and
(b) verify your identity.
4.5 Unsolicited personal information

If we collect personal information about you that we did not ask for, we will check whether we could have collected that information ourselves.  If we could have collected the information, we will handle it in the same way we handle other information we collect from you.  If:

(a) we could not have collected the personal information; and
(b) the information is not contained in a Commonwealth record,

we will destroy the information or de-identify the information provided it is lawful and reasonable to do so.

4.6 Notification of collection of personal information

When we receive personal information directly from you, we will take reasonable steps to notify you of the collection and the circumstances that surround the collection.

Sometimes:

(a) we collect your personal information from third parties; or
(b) you may not be aware that we have collected your personal information.

If we collect information that can be used to identify you, we will take reasonable steps to notify you of the collection and the circumstances that surround that collection.

5. Storing personal information

5.1 Storing personal information

We store your personal information (including credit eligibility information) in different ways, including paper and electronic form and via third party data storage providers. 

We treat all personal information as confidential.  We will take reasonable steps to ensure personal information is protected from:

(a) misuse, interference and loss; and
(b)  unauthorised access, modification and disclosure.

Some of the ways we do this are:

(a) confidentiality requirements for employees;
(b) limiting access to personal information to those people who need to know that information;
(c) control of access to buildings; and
(d) electronic security systems, such as firewalls and data encryption, passwords or other access codes, antivirus, antispyware, backup and recovery of systems.
5.2 What happens if we no longer need your personal information?

If we no longer need your personal information for any purpose, we will take reasonable steps to destroy or permanently de-identify the information, unless:

(a) the information is contained in a Commonwealth record; or
(b) we are required by law, or a court/tribunal order, to retain the information.

6. Purposes for collecting, holding, using and disclosing information

We collect, hold, use and disclose your personal information (including credit information) for the purpose it was collected and related purposes, including:

(a)             to identify you;
(b)             to give you information about goods that we or our partner or affiliate may provide;
(c)             to consider your request for us to supply goods;
(d)             to obtain a credit report;
(e)             to consider your credit worthiness;
(f)              to process and assess your credit application;
(g)             to enable us to supply goods to you;
(h)             to tell you about other goods that may be of interest to you, unless you tell us not to;
(i)               to participate in the credit reporting system;
(j)               to manage your accounts;
(k)             to comply with any applicable laws, regulations or code of practice;
(l)               to collect overdue payments;
(m)           to manage and deal with any possible legal actions, including dispute resolution purposes; and
(n)             for any other purpose for which you have given your consent.

7. Use and disclosure of information

7.1 Personal information

Personal information we hold about you that was collected for a particular purpose will not be disclosed for another purpose unless:

(a) you have consented to the use or disclosure of the information for another purpose; or
(b) the access, use or disclosure is otherwise permitted under the Privacy Act (e.g. you would reasonably expect us to use or disclose the information for another purpose or the use or disclosure of the information is required or authorised by law or a court/tribunal order).

7.2 Disclosure of personal information

Sometimes we may disclose personal information about you to third parties.  Examples of third parties that we may disclose your personal information to include, but are not limited to:

(a) our suppliers, agents and representatives;
(b) our related entities;
(c) other trade organisations;
(d) credit reporting bodies;
(e) other credit providers;
(f)              debt collection agencies;
(g)             the references listed in your credit application;
(h)             as required or authorised by law or a court/tribunal order; and
(i)               any other person where you have given your consent.

7.3 Credit information

We will not disclose credit information unless the use or disclosure is permitted under the Privacy Act.

7.4 Disclosure of credit information to credit reporting bodies

As outlined above, we may disclose your credit information to one or more credit reporting bodies.  The contact details of the credit reporting body we currently use are outlined below:

Dun & Bradstreet (Australia) Pty Ltd (D&B)

Phone: 1300 734 806

Mail: PO Box 7405 St. Kilda Road

Melbourne, Victoria 3004

Email: pac.austral@dnb.com.au

Web: www.checkyourcredit.com.au

D&B has a credit reporting policy about how it deals with your credit information.  For more information, or to request a copy of D&B’s credit reporting policy, you can contact D&B directly.

7.5 Overseas recipients

We may need to disclose your personal information to recipients outside Australia in limited circumstances, including to our overseas suppliers. Click below if you would like to see a list of the countries in which our overseas suppliers are currently located.
- Print and Finishing
- Packaging
- Industrial

7.6 Third party data storage

We may store your personal information via third party data storage providers.  As data storage can be accessed from various countries via an internet connection, it is not always practicable for us to know what country your personal information may be held in.  As such, disclosures may sometimes occur in countries other than those listed.

7.7 Disclosure

Where your personal information is disclosed, we will:

(a) take reasonable steps to ensure that our overseas suppliers do not breach the APPs, unless an exception in the Privacy Act applies; and
(b) seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.

8. Direct marketing

8.1 Direct marketing

We may use or disclose your personal information (excluding sensitive information) for direct marking purposes. 

8.2 Sensitive information

We will only use or disclose your sensitive information for the purposes of direct marketing if you have consented to the information being used or disclosed for the purposes of direct marketing.

8.3 Method of direct marketing

We may conduct direct marketing via email, telephone, or any other electronic means.

8.4 Opt out

If at any time you decide you:

(a)             do not want to receive any more marketing material from us;
(b)             do not want us to use or disclose the information for direct marketing in the future; and/or
(c)             want to know where we obtained the information,

you may:

(d)             contact the Privacy Officer in accordance with paragraph 15.1 of this policy; or
(e)             opt-out of receiving any more marketing material via any opt-out mechanism contained in our marketing correspondence.

All our marketing correspondence will display a clearly visible and user-friendly opt-out mechanism. We may imply consent to receive direct marketing material if you do use the opt-out mechanism.

8.5 Processing requests

If you request to no longer receive direct marketing material we will process your request within a reasonable period after the request is made.

8.6 Pre-screening

A credit reporting body may use credit information it collects about you to pre-screen you for direct marketing at the request of a credit provider, unless you ask them not to.  The credit reporting body uses this information to assess whether or not you are eligible to receive direct marketing from the credit provider. At any time you can ask a credit reporting body not to do this.

9. Quality of personal information

We must take reasonable steps to ensure that any personal information (including credit information) we collect, use or disclose is accurate, complete, up-to-date and relevant to our functions or activities.

If you believe that your personal information is not accurate, complete or up to date, please contact the Privacy Officer in accordance with paragraph 15.1 of this policy.

10. Access to personal information

10.1 Requesting access

You can access your personal information (including credit eligibility information) unless an exception in the Privacy Act applies.

You can request access to your personal information by contacting our Privacy Officer in accordance with paragraph 15.1 of this policy.

10.2 Access fees

Depending on the nature of the request, we may charge you a small fee to access that information.

10.3 Dealing with access requests

We will respond to a request for access within a reasonable time (usually 30 days), and give access in the manner requested by you, if it is reasonable and practicable to do so.

We may need to verify your identity before we give you access to your personal information.

10.4 Refusal to give access

Sometimes, it may not be possible for us to give you access.  If we refuse to give you access, we will:

(a)             take reasonable steps to give you access in a manner that meets our needs as well as yours;
(b)             provide you with written reasons for the refusal provided it is reasonable to do so; and
(c)             provide you with the mechanisms available to complain about the refusal.

11. Access to credit eligibility information

11.1 Dealing with access requests

If you request access to credit eligibility information, we will:

(a)             take reasonable steps to provide you with an easy way to obtain access to the information;
(b)             provide you with access within 30 days of the request (unless unusual circumstances apply);
(c)             make the information clear and accessible;
(d)             provide reasonable explanations and summaries of the information; and
(e)             ask you to check with credit reporting bodies what information they hold about you to ensure that you have access to the most up-to-date information.

11.2 Refusal to give access

If we refuse to give you access to your credit eligibility information, we will give you a written notice that:

(a)             sets out the reasons for the refusal provided it is reasonable to do so; and
(b)             states that, if you are not satisfied with the response to the request, you may complain to the Australian Information Commissioner.  

12. Correcting personal information

12.1 Requesting correction

If you think that any personal information we hold about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request us to correct the information by contacting the Privacy Officer in accordance with paragraph 15.1 of this policy.

12.2 Correcting information

We will take reasonable steps to correct that information to ensure that, having regard to the purposes for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

12.3 Dealing with correction requests

We will respond to a correction request within a reasonable time (usually 30 days).

We may need to verify your identity before we correct your personal information.

12.4 Notification of correction to third parties

If we correct personal information (including identification information) that has been disclosed to another entity and you ask us to tell the other entity about the correction, we will take reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.

12.5 Refusal to correction information

If we refuse to correct the personal information, then we will give you a written notice that sets out the:

(a)             reasons for the refusal, provided it is reasonable to do so; and
(b)             mechanism available to complain about the refusal.

13. Correction of credit information

We are required to do some additional things if you ask us to correct credit information. 

13.1 Dealing with correction requests

We will take reasonable steps to correct your credit information within 30 days (or such other period as you have agreed in writing).

13.2 Consultation

Where necessary to resolve the correction request, we will consult other credit reporting bodies or credit providers.

13.3 Correction

If we correct credit information we have previously disclosed to a third party, we will give each recipient of the information written notice of the correction within a reasonable time, unless it is impracticable and unlawful to do so.

If we correct your credit information, we will provide you with a written notice of the correction within 5 business days.

13.4 Correction fees

We do not charge you a fee for making a request to correct information.

13.5 Refusal to correct

If we refuse to correct the credit information, then we will provide you with a written notice that:

(a)             states that the correction has not been made;
(b)             sets out the reasons for the refusal provided it is reasonable; and
(c)             states that, if you are not satisfied with the response to the request, you may complain to the Office of the Australian Information Commissioner,

unless we are required by law or a court/tribunal order, not to give this notice.

14. Anonymity

You have the option to remain anonymous, or to use a pseudonym when dealing with us where it is lawful and practical to do so.

15. Complaints or disputes about personal information

15.1Complaints

If you:

(a)             have any issues about the way we handle your personal information after reading this policy;
(b)             become aware of a potential breach of privacy; or
(c)             wish to make a complaint,

please contact our Privacy Officer.

Complaints can be made in writing or orally to:

Privacy Officer

Telephone: +61 02 8399 4999

Mail: Locked Bag 5010, Alexandria, New South Wales, 2015

Email: info@jet-ap.com

Web: www.jet-ap.com/contact.

15.2 External complaint mechanism

If you are not happy with the outcome of the Privacy Officer’s investigation, then you can raise your concern with the Office of the Australian Information Commissioner (OAIC).

Complaints can be made to OAIC in the following ways:

Office of the Australian Information Commissioner

Telephone: 1300 363 992

Email: enquiries@oaic.com.au

Mail: GPO Box 5218 Sydney NSW 2001

Web: www.oaic.gov.au

16. Additional considerations for complaints about credit information

16.1 Access and correction requests

If your complaint relates to how we have handled your access and correction requests, you may take your complaint directly to the Office of the Australian Information Commissioner.

16.2 Complaints about credit information

If you make a complaint about credit information (other than access or correction requests), we will give you a notice outlining how we will deal with it within 7 days.

16.3 Extensions of time

If a decision about the compliant cannot be made within 30 days, we will ask you for an extension of time to resolve the compliant.

A decision must be made in relation to the complaint within 30 days or longer period agreed to by you in writing.  If you have any concerns you may complain to the Australian Information Commissioner.  

Last updated in June 2014