- 1. Introduction
Under the Privacy Act, “personal information” means information which identifies you as an individual or from which your identity can be reasonably ascertained (and regardless of the form of the information, and regardless of whether it is true or not).
- 2. What types of personal information do we collect?
We only collect personal information if it is necessary for one of our functions or activities. The types of personal information we collect will depend on the reason for collection. Generally, the information we collect about distributors, customers and suppliers includes name; contact details, e-mail addresses and records of communications with us. We may not be able to provide our products or services without having collected personal information.
In addition we collect personal information relating to:
- our suppliers and their employees. This information is collected for business-related purposes but contains some limited personal information contact details of the people that we deal with;
- people who correspond with us, including through our website, in which case we may keep a copy of that correspondence and relevant contact details;
- visitors, contractors and suppliers who come onto any of our sites (in case of emergency);
- job applicants: employment and academic histories, the names of their referees and, in some cases, limited health information based on testing undertaken by or for us. We will collect this information directly, from organisations that provide recruitment related services to us, and from third parties who provide job applicants with professional or personal references;
When you visit our website we collect information using cookies, server logs and Google Analytics. When you visit our sites to read, browse or download information, our system will record/log your IP address (the address which identifies your computer on the internet and which is automatically recognised by our web server), date and time of your visit to our site, the pages viewed and any information downloaded. This information will only be used for the purpose of site analysis and to help us offer you improved online service. We may automatically collect non-personal information about you such as the type of internet browsers you use or the site from which you linked to our websites. You cannot be identified from this information and it is only used to assist us in providing an effective service on our website.
Our site may contain links to other sites. We are not responsible for the privacy practices or policies of those sites and recommend that you review their privacy policies.
- 3. How we collect and hold personal information
ModWood collects personal information in a number of ways from individual persons in different situations. In particular, personal information is collected from people in the following situations by ModWood:
- when they visit, call or email us or otherwise correspond with us;
- when they apply for a position with us;
- when they purchase products from us or our distributors;
- when they enter into (or apply to enter into) a supply agreement with us, or provide products or services to us.
Where it is reasonable and practicable to do so, we collect personal information directly from the individual when they correspond with us, enter into arrangements with us, or provide feedback to us. Depending on the nature of our interactions, we may collect personal information from third parties – for instance information about job applicants is collected in the manner set out above. We will also, from time to time, collect personal information from our related companies, customer’s trade creditors, reporting bodies or (where consent is obtained) your accountants or professional advisers and from publicly available information.
We hold personal information electronically and, in some cases, hard copy form, both at our own secure premises and with the assistance of our service providers. We take all reasonable steps to ensure that the personal information that we hold is protected from loss, misuse, unauthorised access by ensuring that this information is held on secure servers in controlled facilities and that information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.
- 4. Why we collect, hold and use personal information
We may use personal information for the primary purpose for which it is collected (eg. provision of our services, including administration of our services), or for purposes related to the primary purpose where it would reasonably be expected that we would use the information in such a way, or in other limited circumstances set out in the Privacy Act.
We collect, hold and use personal information to:
- provide, deliver, source, administer our products and services,
- process transactions and collect monies owing to us;
- process credit applications and credit checks;
- conduct product and market research to develop and improve our products and services and to better understand and evaluate the needs of our customers;
- undertake and administer promotions, competitions, and other marketing activities including direct marketing communications about our products and services (whether by phone, email, SMS, post or facsimile), unless you inform us that you do not wish to receive such direct marketing communications;
- communicate with customers and suppliers;
- source products for sale, transport products and ensure our suppliers comply with our sourcing policies;
- recruit and assess potential employees;
- maintain and update our records;
- enable third party service providers to provide us and our related companies with services such as legal, accounting and auditing services; information technology, credit checking and debt collection, marketing, printing and mailing services;
- investigate feedback and complaints;
- correspond with people who have contacted us, and deal with feedback;
- where required or permitted by law, or where we think it is required as part of an investigation, on health or safety grounds.
When we request your information we may give more specific details about the way we use or disclose your information.
- 5. Why we disclose personal information
We do not disclose personal information to third parties unless we are permitted to do so by law or we have obtained consent to do so. We may disclose personal information for the primary purpose for which it is collected or for purposes related to the primary purpose where it would reasonably be expected that we would use the information in such a way. Also, we are permitted to disclose personal information in circumstances set out in the Privacy Act (including but not limited to disclosures to our related companies).
Third parties we may disclose personal information to include:
- our related companies;
- our service providers and professional advisors including IT service providers, auditors, legal advisors, print and mail houses, advertising agencies, transport contractors, marketing research advisers and credit reporting bodies;
- our product distributors;
- Financial institutions;
- Regulatory or government agencies.
We take steps to ensure that our service providers are obliged to protect the privacy and security of personal information and use it only for the purpose for which it is disclosed.
The third parties to whom we disclose personal information may be located in Australia and other countries including New Zealand. We may use cloud computing solutions or data storage located overseas in which case information may be stored, under our control, on computer servers located outside of Australia.
- 6. Credit reporting and credit information privacy
The way in which we collect, hold, store and use credit-related information about customers is similar to the ways in which we collect, hold, store and use other personal information. The types of credit-related information that we collect about customers is detailed in sections 1 and 2 of this Policy, in addition, we may sometimes seek information about assets that customers hold and information about their business trading position and history. We will:
- either collect that information from customers directly, or we will obtain it through third parties or the credit reporting system as set out in section 3 of this Policy;
- use that information for several purposes, including establishing customer accounts with us to enable us to provide goods and services and collect monies owing to us; and
- disclose that information for several purposes and to several people including legal advisors, print and mail houses, marketing research advisers, credit reporting bodies, mercantile agents debt collectors and (where you give your consent) people guaranteeing the payment of your account.
We participate in the credit reporting system. If you apply for credit with us, we may request a credit report about you from a credit reporting body or a trade reference from your trade creditors. These credit reports contain information about customers which assists us to assess customer applications, including information about credit history with other credit providers.
Credit reporting bodies can provide credit providers with credit reports in certain circumstances, including when an individual makes an application for credit, or when a credit provider is seeking to help an individual avoid defaulting on their credit. Credit reports are designed to assist credit providers to accurately assess an individual’s ability to repay credit.
To request a credit report, we will provide identification information to the credit reporting body, as well as information about the credit application – including the name of the customer and its ABN.
We will often combine the information obtained from a credit reporting body with information that we already hold about the person. For example, when we assess your application for credit, we may combine the information provided on an application for credit with the information contained in the credit report obtained from a credit reporting body to calculate a rating or score. This will determine whether the person qualifies for the credit applied for.
We note that:
- Credit reporting bodies may include the information in reports provided to credit providers to assist them to assess your credit worthiness;
- If you believe (on reasonable grounds) that you have been, or are likely to be a victim of fraud , you have a right to request credit reporting bodies not to use or disclose your credit reports they hold about you. You can do this by contacting them directly. If you make such a request, a credit reporting body will not disclose information about you for 21 days. You can request an extension to this period if you believe you are still, or still likely to be, a victim of fraud;
- you may request that credit reporting bodies not use your credit reporting information for the purposes of pre-screening for direct marketing by a credit provider.
The credit reporting body that we typically use is Dun & Bradstreet.
- 7. Accessing and correcting your personal information, and complaints and questions
You can request access to your personal information held by us, or request that it be corrected, by contacting us at the address below. To ensure confidentiality, details of your personal information will be passed on to you only if we are satisfied that the information relates to you. A fee will not be charged for an access request, but you may be charged the reasonable expenses we incur (such as search and copying costs). If we refuse to provide you with access or correct the personal information held about you by us (in accordance with the Privacy Act), then we will provide reasons for such refusal.
If you wish to make a formal complaint, please make your complaint in writing to our Privacy Officer. We will consider your complaint promptly and contact you to seek to resolve the matter. If we have not responded to you within a reasonable time or if your concerns are not resolved to your satisfaction, you are entitled under the Privacy Act to make a complaint to the Office of the Australian Information Commissioner.
ModWood Privacy Officer
ModWood Technologies Pty Ltd
5 Jesica Road
Campbellfield VIC 3061
Phone: + 61 3 9357 8866
Office of the Australian Information Commissioner
Phone: 1300 363 992.
Last updated: March 2022
ModWood Technologies Pty Ltd ACN 094 868 201