Last updated: 3/06/2022.
In this policy we, our or us means:
- AD1 Holdings Limited, ABN 29 123 129 162; and
- any related entities of AD1 Holdings Limited, including its holding company and any subsidiaries.
For the purposes of this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
In general, we will only use your personal information for the purpose(s) that you gave it to us for.
We review this policy periodically to ensure it is kept relevant and up to date and we may make changes at any time by publishing the amended version on our website.
1. Information we collect
In the process of conducting our business, we may collect a range of personal information from current and prospective customers, clients, users, service providers, job applicants and other individuals where it is necessary in order to operate our business. The kind of information collected will depend on the nature of your dealings with us, but may include:
- contact information and identification such as your name, date of birth, contact number, e-mail address, residential and/or business address, demographic information (such as your postcode, age and gender) and driver’s licence or other identification document details;
- payment details (such as account or credit card details) and payment related information in connection with
- your purchase of our goods or services; or
- information collected from marketing campaigns, member surveys and your interactions with us, including via social media.
We will only collect sensitive information about you with your consent (unless we are otherwise allowed or requiredby law to collect that information). If you provide us with sensitive information, such as health information, information about your race, gender, sexual orientation, ethnic origin and religious beliefs, on your own accord, we will treat it with the highest confidence and only disclose it as instructed by you.
2. How we collect information
Information collected from you
Most of the personal information we collect will be collected directly from you. This may occur when you:
- contact or interact with us in person, by e-mail, phone or other forms of communication, or via forms on our website, or social media accounts;
- sign up to purchase any of our services;
- respond to any of our job advertisements;
- visit our premises;
- sign up to purchase any of our services; or
- attend events hosted or operated by us.
Information collected from third parties
We may sometimes collect your information from third parties such as:
- information held by online third-party services, that you have granted us access to (e.g. Google, Facebook, etc.);
- parties you refer us to, or who refer us to you, including personal referees when you apply for a job with us;
- where you are employed or engaged by an entity that purchases services from us, from an authorised representative of that entity;
- contractors that we engage to provide services to us;
- third party recruitment agencies you have provided your details to; or
- marketing agencies or providers of similar lists or information which have been legally acquired by us.
Information collected automatically
When you visit or interact with our website, our online platform, or any other online platform operated by us (Platforms) we (as well as any of our third party service providers) may use a variety of technologies that automatically or passively records information about how the Platform is accessed and used (Usage Data). Usage data may include your IP address or other unique identifier for the device used to access a Platform, browser type, device type, date and time of visit, pages viewed and your use of features or applications on the Platform. Usage Data helps us to keep the Platforms relevant for our guests and members. Usage Data is usually non-identifying, but if it can be used to identify you, we will treat it as personal information.
3. Purpose of use or disclosure
We collect, use and disclose your personal information for a variety of purposes, including:
- to provide you with our services;
- for any purpose which we notify you about when we collect your information, or to which you have provided your consent;
- to provide various business support services to our customers and/or users;
- to notify customers and/or users of news and event information;
- for security and safety purposes;
- responding to your enquiries, concerns or complaints;
- to consider and assess your application for as a potential job applicant or contractor;
- to distribute promotional material and inform you about products, services, special offers and events;
- to customise, measure and improve our services;
- improving your experience with us and our marketing, including through data analytics, product planning and research;
- to process or verify payments authorised by you;
- to comply with the law, including a lawful request from law enforcement; and
- other purposes related to the provision of our services.
4. Disclosing your personal information
We may disclose your information to third parties, including:
- our agents or contractors who perform a particular function or service on our behalf;
- your employer or former employer as part of conducting a reference check.
Examples of our third-party agents or contractors include:
- mail distribution providers;
- secure data storage providers;
- information technology service providers;
- debt collection agencies; and
- accountants, lawyers and other professional advisors.
We may also disclose your information to third parties where required or authorised by or under law.
We will not sell or provide your information to a third party for the purposes of direct marketing without your informed consent.
5. Direct marketing
Direct marketing is the promotion of goods and services directly to you including through emails, SMS, phone calls and the post. We will only send you direct marketing materials if you would reasonably expect to receive them, or you have consented. If it is impractical to gain your consent, we will always provide a simple and easy means for you to request not to receive the material.
6. Cross-border disclosure
Our preference is to use third party service providers who are based in Australia, however we may use overseas service providers to process your personal information if we reasonably believe that the overseas entity is subject to the same or similar privacy laws to those found in Australia, or you have otherwise consented to us disclosing your personal information to the overseas entity.
The security of your personal information is important to us and we take reasonable steps to protect your information from unauthorised access or disclosure and ensure the accuracy and proper use of your personal information, including using a range of physical, technical and administrative measures such as:
- using SSL encryption to store and transfer personal information on our Platforms;
- hosting of our Platforms on servers located in secure third-party centres, who use best-practice procedures to ensure the security of data;
- reviewing the adequacy of technical and physical security measures used by any third-party suppliers who will be processing or storing your personal information; and
While we take all reasonable steps to ensure that your personal information is protected from misuse, interference
or loss, no method of transmission over the internet, or method of electronic storage, is 100% secure. Each
individual that provides personal information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorized access to, personal information where the security of the information is not within our control.
If a data breach occurs, and there is a real risk of harm to you as a result of such breach, we will notify you as soon as possible.
In addition to the measures we take to protect your personal information, you should ensure that you keep secret and regularly change any access passwords to any accounts on our Platforms, and always logout of any secure pages at the end of your session.
When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information, or to ensure that the information is de-identified.
9. Access and Correction
Upon your written request we will provide you with a copy of your personal information that we hold, unless there is a legitimate reason at law not to do so. We will take reasonable steps to correct your personal information if we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading. This extends to third parties that we have provided your personal information to unless it is impracticable or unlawful to do so.
10. Resolving concerns
If you have a concern or complaint relating to our handling of your personal information, or if you feel that we have breached the privacy laws, please contact us in writing using the contact details provided below, outlining the nature of the complaint. We will endeavour to respond to your complaint within 30 days of receipt.
If your complaint is not satisfactorily resolved, you can contact us to discuss your concerns or the complaint may be taken to the Office of the Australian Information Commissioner.
11. Contact Us
If you have questions or suggestions, please contact us at:
Mailing address: Suite 102, 697 Burke Road, Hawthorn East, Melbourne, VIC 3123, Australia
12. Updating this Policy