Document Description
We take your privacy extremely seriously and are committed to ensuring that your personal information is protected in compliance with all applicable Australian laws. This policy describes what, why and how we collect and use your personal information, how we protect it and how you can contact us.
Field Solutions Holdings Limited (ABN 92 111 460 121) and all its related bodies corporate (Field Solutions, the Company, Group, Services, Products) online presence.
We are registered and have our head office in Belrose, Sydney.
This policy explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about this information. Some of our services also have their own privacy policy which provide details of the use of your information by that service. These service-specific policies may apply in addition to or instead of this policy.
PRIVACY POLICY CONTENTS
Privacy Policy
Document Description
Privacy Policy Contents
1. Information that we collect
1.1 The types of personal information that we collect and hold
1.2 Ways we collect personal information
1.3 Parties from whom we collect personal information
2. Purposes of collecting personal information
2.1 General 5
2.2 Marketing communications
2.3 Personalised and targeted content, recommendations and advertisements
2.4 Statistics
2.5 Product Improvement
2.6 Publish your reviews, comments and content
2.7 Secondary purposes
2.8 Other
2.9 Combining the information we collect
3. Disclosure of personal information
3.1 Disclosure of information by Field Solutions Australia
3.2 Sharing of information by you
3.3 Overseas disclosure
4. Marketing communications
5. Security of your information
5.1 What we do to protect your information
5.2 What you should do to protect your information
6. Cookies and web beacons
7. Access to your information and your rights
8. Complaints
9. Links to other sites
10. Children’s privacy
11. Contact us
12. Glossary
PRIVACY POLICY
1. Information that we collect
We need to collect personal information from you in order for us to provide products, services and support to you. If you do not provide us with certain personal information when prompted, we may be unable to sell you products and/or provide certain services, including after sales services.
may collect personal information which is necessary for our functions or activities in several different ways. Please take care when submitting personal information to us, in particular when completing free text fields or uploading documents and other materials. Some of our services are automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.
1.1 The types of personal information that we collect and hold
We may collect the following types of personal information:
- name, address and contact details;
- date of birth;
- gender;
- interests;
- account and newsletter preferences;
- delivery date for a product you purchased from us, the place of purchase and information about your ownership of the product;
- information about any call to us, including a recording of the call, details about the product(s) you bought, the reason why you contacted us and the advice we gave you;
- information relating to your use of any of our loyalty programs and the rewards that you claim;
- your business contact details, place of employment and position;
- product reviews, comments, photos and forum posts that you have submitted;
- credit and financial checks;
- information about your social network profile such as your social network ID, profile picture, gender and location;
- the fact that you have clicked on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services or on of our pages on a social network site, and information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you;
- information about your visit to our website, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket;
- service, product or server logs, which hold technical information about your use of our service, product or websites, such as your IP address, domain, device and application settings, errors and hardware activity
- information about where your device is physically located (for example, when you are using a geo-location service or application and you have provided consent to your location being shared);
- interests and preferences that you specify during setup of an Internet enabled product or service;
- (in the case of candidates seeking employment with us) information relevant to your employment history.
1.2 Ways we collect personal information
We collect personal information directly from you, from publicly available sources of information and from third parties:
- by using written forms;
- through contact in person or over the telephone, mobile or other messaging technology; and
- via the internet (including social media websites, online forms, our website).
1.3 Parties from whom we collect personal information
There are a range of people, organisations and sources from whom or from which we collect your personal information. These may be parties related to Field Solutions Group or third parties. Some examples of the parties and sources from whom or which we collect your personal information are:
- other related bodies corporate within the Field Solutions Group;
- Field Solutions retailers;
- your linked Field Solutions accounts; and
- publicly available sources of information.
2. Purposes of collecting personal information
2.1 General
Field Solutions may use information it collects for a wide range of purposes, including to:
- make changes to your account details, including to your Field Solutions linked accounts;
- fulfil obligations under any sale and purchase contract and/or any other contract between you and Field Solutions;
- provide you with a product or service you have requested, including checking that a payment is not made fraudulently, delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and fulfil its obligations under any other agreement it may have with you);
- render services related to Field Solutions business such as providing customer care, warranty, returns, servicing Field Solutions products and other after sales services;
- provide information about products, services and/or special offers;
- train staff and for quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other support centres obtain opinions or comments about Field Solutions products and/or services, including conducting product surveys;
- facilitate and process your searches and requests for information when you contact us about Field Solutions and its products and services;
- conduct prize draws, contests and other promotional offers;
- consider employing you if you contact us via one of Field Solutions Australia’s job application websites; and
- record statistical data for marketing analysis.
2.2 Marketing communications
Field Solutions may use your information to provide you with newsletters and other communications by post, email, telephone and/or text message (SMS), if you have provided your prior consent or we are otherwise permitted to do so under applicable law. See the Marketing Communication section below for more details.
2.3 Personalised and targeted content, recommendations and advertisements
Field Solutions may use the information it collects to personalise and more effectively target its stores, services, content, recommendations, adverts and communications. You may notice this personalisation and targeting when you use Field Solutions products and services, when we contact you with marketing communications and when you visit our and third party websites and services that show advertisements from us or our advertising partners (for example, you might see an advertisement for a product that you have recently viewed on one of our websites).
The personalisation and targeting that you see on our websites or in our online advertisements and communications may make use of cookies set by us or our third party advertising partners. In other cases, our services may have specific settings to control personalised content and you should consult the privacy policy of the relevant service for more information.
2.4 Statistics
Field Solutions may use your information to create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programs, which we may share with third parties and/or make available to the public.
2.5 Product Improvement
Field Solutions may use your information to develop and improve new and existing Field Solutions products and services, recommendations, advertisements and other communications and learn more about customers’ shopping preferences in general.
2.6 Publish your reviews, comments and content
Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, Field Solutions may link to, publish or publicise these materials elsewhere including in our own advertisements.
2.7 Secondary purposes
We will also use and disclose your personal information for a secondary purpose related to a purpose for which we collected it, where you would reasonably expect us to use or disclose your personal information for that secondary purpose. For example, we will disclose your personal information to third party service providers so that they can provide certain contracted services to Field Solutions Group, such as information technology support or programming, hosting services, telephony services, mailing or sending of document to you digitally or otherwise.
2.8 Other
There will be other instances where we may use and disclose your personal information, including where:
- you have consented to the use or disclosure;
- we reasonably believe that the use or disclosure is reasonably necessary for an enforcement activity conducted by or on behalf of an enforcement body; or
- we are required or authorised by law to disclose your personal information, for example, to a court in response to a subpoena or court order.
2.9 Combining the information we collect
We may link or combine the information that we collect from the different sources outlined above in the “Information that we collect” section above (including information received from other Field Solutions Group companies about your use of other Field Solutions Group products and services). Information may be linked via a unique identifier, such as a cookie or account number . Alternatively, we may decide to combine two or more databases into a single database of customer information.
We may do this for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to provide a more seamless customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts.
3. Disclosure of personal information
3.1 Disclosure of information by Field Solutions Australia
In general, Field Solutions does not sell, rent or otherwise disclose information about you to third parties without your consent. However, there may be exceptions within other Field Solutions’ companies.
We will share your personal information with all companies that form a part of the Field Solutions Group. If one Field Solutions Group company collects your personal information, other Field Solutions Group companies may use and disclose that personal information for the purposes for which we collected it, described in section 2.
Other Field Solutions Group companies to whom we have disclosed your personal information for one of these purposes may combine this information with other details they hold about you. Unless that Field Solutions Group company provides you with their own privacy policy, they may use your personal details for the purposes explained in this policy.
3.1.1 Our service providers
We may use third party service providers to process information on our behalf for the purposes outlined above. For example, fulfilling orders, delivering packages, sending postal mail and emails, sending text messages (SMS), providing marketing assistance, processing credit card payments, providing fraud checking services and providing customer services.
Our service providers operate only in accordance with our instructions, in line with this policy, and are subject to appropriate confidentiality and security obligations.
3.1.2 Our business partners
If you request or agree to receive information or newsletters from one of our business partners, we may provide that third party with your details so that they can respond to your request.
3.1.3 Legal and business purposes
We may disclose to third parties information about you:
- to government bodies and law enforcement agencies to prevent fraud, to comply with the law and to meet a reasonable request from such bodies;
- to third parties (including professional advisors) to enforce or defend the legal rights of any Field Solutions company or the terms and conditions of any Field Solutions product or service; and
- to a third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation.
3.1.4 Anonymous statistics
We prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes, including for product and service development, business promotion and research purposes. As we consider that this is not personal information, we may share it with any third party (such as our partners, advertisers, industry bodies, the media and/or the general public).
We will also disclose your personal information as described in sections 2.7 and 2.8 above.
3.2 Sharing of information by you
A number of our online services allow you to upload and share messages, photos, video and other content and links with others and/or create a publicly accessible profile for your account. For example:
- the communities and forums area of our website, allows you to post comments (with your account name), which are visible to other users of that service; and
- other services allow you to share a link which if clicked on may allow the recipient to access your uploaded content.
You should not expect any information that you make available to others via Field Solutions Australia’s online services to be kept private or confidential. Content and links that you share might, for instance, be forwarded by your recipients to others. You should always exercise discretion when using such services.
3.3 Overseas disclosure
Field Solutions Group is the corporate entity of Field Solutions Holdings, which is an Australian organisation. For the purposes explained in this policy, your information may be transferred to Field Solutions companies (including service providers operating on their behalf) and other third parties in countries which do not have the same level of privacy laws as those in the country where you are located.
We may send your personal information overseas. Instances when we will do this include:
- when or if required for any development, updates, bug reporting, or account functionality changes or additions;
- when you have asked us to do so or we have your consent; and
- when we are authorised or required by an Australian law or a court/tribunal to do so.
We will need to from time to time disclose your personal information to parties oversees. This will be on an ad hoc or case by case basis and for the purposes for which we collected your personal information.
4. Marketing communications
When you provide us with your contact details, such as when you purchase a product, contact our customer support call centres or create an account for one of our services, you may be given the opportunity to opt-in to receiving various direct marketing communications. Direct marketing involves the use and/or disclosure of personal information to communicate directly with an individual to promote goods and services. This includes newsletters and other communications by post, email, telephone and/or text message (SMS) from Field Solutions and/or other Field Solutions Group companies, sending you details about the latest Field Solutions products and services, such as upgrades and special offers in which you may be interested.
Field Solutions may also give you the opportunity to opt-in to receiving more targeted direct marketing communications.
You can change your marketing communication preferences at any time:
- if you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the email. But note that:
- if you use more than one e-mail address to shop or contact Field Solutions Australia, you will need to unsubscribe separately for each email address; and
- this method will only unsubscribe for the newsletter or other communication that you have received and you should use one of the other methods if you wish to opt-out of all our marketing communications,
- if you have registered with Field Solutions online and have a “My Field Solutions” account, you may log-in and amend your marketing communication preferences in the account settings; and
- you can contact us using the details in the “Contact us” section 11 in order to change your marketing communication preferences.
Please note that we may occasionally send you important information about Field Solutions products and services that you are using or have used (such as order confirmations, product safety announcements and service changes). These emails are not affected by your marketing communication preferences.
5. Security of your information
5.1 What we do to protect your information
We hold your personal information in:
- computer systems;
- electronic databases;
- digital archives;
- telephone recordings; and
- hard copy or paper files.
These storage mechanisms may be managed in a number of ways. These may be managed or administered internally by a company in the Field Solutions Group and may be held locally in Australia, or, they could be managed by a third party storage provider with whom the Field Solutions Group has a contractual relationship and be either managed locally or overseas. We will take all reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. The ways we do this, include:
- using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us);
- limiting physical access to our premises;
- limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access);
- requiring any third party providers to have acceptable security measures to keep personal information secure;
- putting in place physical, electronic, and procedural safeguards in line with industry standards; and
- destroying or de-identifying personal information pursuant to the law and our record retention policies.
5.2 What you should do to protect your information
As general best practice on the Internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:
- Do not use trivial passwords (such as single dictionary words).
- Do not use the same password for multiple accounts.
- Do use very long passwords (at least 10 characters, but preferably much longer).
- Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
- Do keep passwords securely (never written down, or shared with anyone).
Passwords should be changed on a regular basis.
6. Cookies and web beacons
Our websites use tracking technologies, such as “cookies”, “web beacons”, and or “website analytics” to make use of the website and services as convenient as possible and to collect information about the use of our websites and email communications. For instance, these technologies may tell us which visitors clicked on key elements (such as links or graphics) on a website or email and recognise your browser the next time you visit our websites.
Most web browsers are set to accept tracking technologies such as cookies or web beacons. These tracking technologies do not themselves personally identify users, although they do identify a user’s browser. These tracking technologies allow Field Solutions to monitor the items an individual may want to purchase as they move through the shopping site, and to record how many people are using the different parts of the site. It is possible to set your browser to refuse tracking technologies, however, this may limit the services provided by Field Solutions’ website.
7. Access to your information and your rights
Individuals have the right to request access to personal information we hold about them, and request us to correct any inaccurate, out-of-date, incomplete, irrelevant or misleading personal information. If you would like to request access to the personal information that we hold about you in our customer databases, please contact us using the details given in section 11 below. You will be asked to provide some proof of identification so that we can verify that it is you making the request.
8. Complaints
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).
We will deal with complaints as follows:
Step 1: let us know
If you would like to make a complaint, you should let us know by contacting our Property Information Memorandum (PIM) Officer as it details in section 11 below.
A response will be provided within a reasonable period.
Step 2: investigation of complaint
Your complaint will be investigated by our PIM Officer.
A response to your complaint will be provided in writing within a reasonable period.
Step 3: contact OAIC
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing:
Mail
Director of Compliance
Office of the Australian
Information Commissioner
GPO Box 5218
Sydney NSW 2001
Web
www.oaic.gov.au
Phone
1300 363 992
9. Links to other sites
Some of our websites may contain links to other websites that are not operated by Field Solutions.
While Field Solutions tries to link only to sites that share Field Solutions high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those other websites. You should view the privacy and cookie policies displayed on those websites to find out how your personal information may be used.
10. Children’s privacy
Field Solutions considers a child to be anyone under the age of 18. We do not knowingly seek or collect personal information from or about children without the consent of a parent or guardian.
If Field Solutions becomes aware that personal information that has been submitted relates to a child without the consent of a parent or guardian, Field Solutions will use reasonable efforts to:
- delete that personal information from its files as soon as possible; and
- ensure, where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third party.
Any parent or guardian with queries regarding our processing of personal information relating to their child should contact us using the details provided in section 11.
11. Contact us
If you need further assistance or would like to make a comment, you can contact us in a number of ways:
via our website: http://www.fieldsolutions-group.com/#contact
By mail:
Field Solutions Group
38/23 Narabang Way
Belrose NSW 2085
AUSTRALIA
By telephone:
Please dial
1300 000 488
By email:
admin@fieldsolutions-group.com
12. Glossary
While we try our best to use plain and simple language, we recognise that there will be some jargon. This section aims to provide simple definitions for some of the common privacy terminology.
Applicable law
The legislation with which any personal information processing must comply.
Cookies
These are small pieces of data that are placed on your device (e.g. your browser when you access a website). Cookies are used for a variety of purposes, including enabling features on a website, helping us to understand which parts of our websites are the most popular, where website visitors are going, and how much time they spend there.
Encryption
Encryption, such as Secure Sockets Layer (SSL) encryption, is a system for protecting data, used when collecting or transferring sensitive data, such as credit card details or other personal information. Encryption is designed to make the data unreadable by anyone but the intended recipients.
Portals/Forums/ONLINE SYSTEMS
Some or all Field Solution Group websites where you can register a Field Solutions product, maintain a profile, purchase products, edit account, or any other type of website that requires field entries (eg. modify your newsletter preferences).
Personal Information
Refers to information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Examples include name, address, phone number, email address, credit card number, bank account number, physical traits, hobbies, usage patterns, family members and income.
Personal Information Management
Personal Information Management or PIM, is the set of processes and controls used to ensure that personal information is handled appropriately, to meet our internal and legal requirements.
Privacy Act
Refers to the Privacy Act 1988 (Cth).
Privacy policy
is a statement or a legal document that discloses how a company gathers, uses, discloses and manages the personal information provided by an individual (such as a customer, partner, employee or potential employee). While this is a legal document, a privacy policy aims to provide transparency about these information handling practices, so should ideally be written in clear and simple language.
Field Solutions Holdings Limited
Field Solutions Holdings Limited is the Field Solutions Group company responsible for Field Solutions consumer electronics products and services.
Field Solutions Holdings companies
Refer to Field Solutions Group, and any other directly associated companies and any entity, firm or corporation, whereupon the majority of whose shares or equity is owned or controlled directly or indirectly by Field Solutions Holdings.
Online Store
The online store of any Field Solutions Group, where you can purchase our products and or services.
Third parties
These are non-Field Solutions Group companies contracted to perform functions on our behalf, such as fulfilling orders, delivering packages, sending postal mail and e-mails, sending text messages (SMS), providing marketing assistance, etc.
Unsubscribe link
If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the mail. If you use more than one e-mail address to shop or contact us, you need to unsubscribe from each e-mail account that you use.
Web Beacons
Web beacons, also known as single pixel or clear gif technology, or action tags, tells us which visitors clicked on key elements (such as links or graphics) on a Field Solutions web page or email.
Dated: 11-Oct-2017