SECTION 1 – WHAT DO WE DO WITH YOUR INFORMATION?
1.1 Interaction When you purchase something from our Web Service, Onsite or Quote, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address.
1.1a Why do we need your personal information? In this policy, personal information is any information that could identify you or be used to establish your identity. We collect, hold, use and disclose customers’ personal information so we can establish, manage and administer the products and services provided by us, and comply with legal and regulatory obligations, this can range from but not limited;
- Being a customer or requesting a service
- Register online for services or submissions
- Send requests such as contact forms or paperwork / contracts
- Engage in services or read non fiction or fiction information on the website
- Opt-in marketing or marketing measures (offline or online)
- Contact us via any various channels
1.2 When you browse our website, we also automatically receive your computer’s internet protocol (IP) address which may link to your Geo location. Headway Information Services does not use this or record it for any purposes. This is irrespective of the fact that in reality the chance of obtaining that extra identifying information from your ISP may be slim to none (as the ISP has to meet its own legal obligations before it just hands over the data), but is based on there being a “mounted chance” of identification. We abide by ePrivacy Regulation that states that processing these addresses is an acceptable activity.
1.3 Email marketing (if applicable): With your permission, we may send you emails about our store, new products and other updates.
1.4 We will collect, process and use the personal data supplied by you only for the purposes communicated to you and will not disclose it to third parties except under the circumstances of data disclosure to third parties.
1.4 You may contact us at any time by using the Contact form on our website also subscribe to the said website headwayservices.com.au and receive all the latest updates and changes to our website via opt-in.
1.6 Facebook Analytics : Facebook s tracking pixel which has been placed on this and other websites owned by headway information services and used to generate data such as lists of visitors who have come to the site and their interests. This is Facebook’s data as the business user does not have access to the specific details it gathers. When we use this data, we are able to target Facebook messages at the people who came to the site but not determine who they are on an individual level. In this instance Facebook is the ‘data controller’. We do not then in theory have to gain specific permission from visitors before you track them with a pixel. The terms regarding the tracking will be laid out in Facebook’s conditions when you sign up for an account.
1.7 For how long we retain your data Via digital marketing and advertising we may process data that you have opted to received from Google or Facebook as examples. Therefore, Headway Information Services has legitimate reason and use for direct marketing to advise potential customers on offers currently available. Headway Information Services can keep re-marketing data/analytics for up to 70 months.
1.8 Data across country borders Headway Information Services does not share your data across boarders unless; you have granted the permission to do, opted in to “shared data services” , “hosting” or bound to a Australian company that you have inter-relationships with as a internal company or shared holding corporation. This is not limited to a person or a company but applied for shareholders, investors, mangers, CEO, CMO and other “inter-relational departments” for I.T services for marketing.
1.9 Compliance We comply with our obligations under applicable privacy laws by keeping personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary data that we need to service you; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
SECTION 2 – CONSENT
2.1 How do you get my consent? When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
2.2 If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no or you can opt out of receiving direct marketing information from us at any time (see 2.3)
2.3 How do I withdraw my consent? If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at email@example.com or mailing us at: Headway Information Services PO BOX 1487, Beenleigh , QLD, 1487, Australia
SECTION 3 – DISCLOSURE
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
SECTION 4 – PAYMENT
4.1 Standard (PCI-DSS) Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction and clear a payment. After that is complete, your purchase transaction information is deleted, however stored by Financial Institutions such as banks on statements for reference of the transaction only and for Tax purposes only.
4.2 All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, BPAY, Bpoint and Direct Debit.
4.3 PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
4.4 Any authorized transactions that are provided by way of Credit Card numbers over the phone are not stored and only used for a once off purchases and strictly used upon customers consent. Unless written consent by Headway Information Services and the customer has agreed to a payment plan or are a part of a manage service for ongoing fees. Credit Card Details are stored securely and adhere to all security protocols with customer pre approval. At the time of transaction Headway Information Services and it financial institute will take a time and date stamp of the transaction for record and security purposes.
SECTION 5 – THIRD-PARTY SERVICES
5.1 In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us and or directly on your behalf. At times we are required to engage third parties to complete jobs required at hand. Any Costs of these are the customers responsibility unless bundled or by way of a means for completion of a job with an embedded price.
5.2 However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
5.3 Policy’s Outside For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
5.4 Providers In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
5.6 Links When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Headway Information Services is not liable for any viruses or other malware that may affect/infect your computer or electronic equipment by way of links or any surfing practices that you the customer perform.
5.7 Legitimate interest or that of third parties, some legitimate interest can include:
- Implementation and operation of a group-wide organizational structure and group-wide information sharing;
- Right to freedom of expression, information & sharing.
- Prevention of fraud & misuse of company IT systems.
- Physical security, IT and network security;
- Internal integration & compliance
- Proposed mergers
SECTION 6 – SECURITY
6.1 HTTPS/ SSL To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Headway Information Services uses HTTPS / SSL technology to secure the website and the computers browser/s for safe industry standard browsing practises.
6.2 Payment Security If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
6.3 Commercial Security Headway Information Services uses Commercial security on all electronic equipment and protects its own and all customers data stored from the outside world such as (hackers, malware,spyware,junkware,keyloggers) and other online and local threats to the best of it ability. Headway Information Services is not responsible for your own security and transmission of information between emails and exchanges for threats, all communications are scanned and protected to the best of commercial grade security.
6.4 Cookies We also receive and store certain types of data whenever you interact with us. For example, we use “cookies,” which are unique identifiers that we transfer to your device to enable our systems to provide features of our services such as personalised advertisements on other websites, provide remote access for you, allow you to visit our website. This assists to improve the functionality and user-friendliness of our services. It also helps us to better understand how you interact with our services and to monitor aggregate usage and web traffic routing on our website. However, if a browser does not accept cookies or if you reject a cookie, some portions of our services may not function properly.
SECTION 7 – AGE OF CONSENT
7.1 Consent By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependants to use this site. We will not be liable for any lost or damage incurred by the unauthorised processing of personal data if you are not of consent age within your country.
8.2 Merging If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
SECTION 9 – PRIVATE INFORMATION
9.1 Headway Information Services will under agreement of General Terms and Conditions keep all personal Login and Password details private and only for use by acceptance of said Terms signed in agreement for Onsite Service or Ongoing Management of any and all Social Media, I.T Managed Services, Google Management & Online Campaign management services agreed upon within said quote or contract.
9.2 Customer You the customer reserve the right to inform us of all Login and Password details to all Social Media, Hosting and Third Party sites you wish us to manage on your behalf and can have optional new passwords for all managed services during your agreement with Headway Information Services.
9.3 Liable Headway Information Services will not be liable for any updates, modifications or comments made not by us during our agreement time.
9.4 Rights We reserve the right to cancel at any time there may be a breach outside of our agreement or payment is not made by the due date.
9.5 Agreeing By agreeing to the said Terms you the customer agree that we will speak on your behalf to Third Party providers and give access to do so.
9.6 Additional Any changes or add on’s requested will need approval by you the customer before going ahead and any additional fees paid at the time.
9.7 Subscription Any subscription agreement is not under any contract and can be cancelled at any time during management of said services. You must give 1mth notice to cancel the ongoing service, Unless a contract is agreed upon by Headway Information and the customer (you).
9.8 Data Loss Headway Information Services will not be liable for any data loss during any transfer, migration or backup of said data, onsite or remotely. We advise to backup any and all data prior to repair or migration. If at your request have advised us of backing up on your behalf, we will keep said data for one week before securely deleting once confirming transfer to be complete and issues to be resolved
10.0 Your Rights & Personal Information / DataUnless subject to an exemption under applicable privacy laws, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which we hold about you.
- The right to request that we correct any personal data if it is found to be inaccurate or out of date.
- The right to request to erase your personal data where it is no longer necessary for us to retain such data, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- The right to withdraw your consent to the processing at any time, where we rely on your consent to process your data. This includes cases where you wish to opt out from marketing communications that you receive from us.
- The right to request that we provide you with your data and where possible, to transmit that data directly to another data controller, where the processing is based on your consent or is necessary for the performance of a contract with you, and in either case we process the data by automated means;
- The right to restrict our processing of your personal data where you believe such data to be inaccurate, our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- The right to object to us using your personal data, where the legal justification for our processing of your personal data is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of legal claims.
- The right to lodge a complaint regarding our processing of your data, with the competent authority where you reside or in which your data is processed.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at firstname.lastname@example.org or by mail at Headway Information Services
ATTN: The Directors
[Re: HR Services]
[PO BOX 1487, Beenleigh , QLD, 1487, Australia]