WE TAKE YOUR PRIVACY SERIOUSLY

We recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us.

In the course of interacting with you, the collection of personal information in some instances is necessary or unavoidable.  We are committed to protecting the privacy of all personal information that we collect and ensuring that your personal information is handled correctly.

All personal information collected by us will be treated in accordance with the Australian Privacy Principles (“APPs”) as contained in the Privacy Act 1988 (Cth) and, where applicable, the General Data Protection Regulation (“GDPR”) that are in force in the European Union (collectively “the Regulations”).  The Regulations detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.

This policy (“Privacy Policy”) details the type of personal information we may collect from you, how we manage personal information about you, with whom we may share it and the choices available to you regarding our use of the information.  We also describe the measures we take to safeguard your personal information and tell you how to contact us regarding our privacy practices.

What types of personal information do we collect and hold

“Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not. Information where we have removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.

The kinds of personal information that we collect and hold from you may include:

  • contact information, such as your name, postal address and e-mail address;
  • member account information such as username and password;
  • machine or terminal information such as machine name or terminal name;
  • bank account, credit card information and other financial information; and
  • any other personal information submitted to us by you.

We do not collect sensitive information (such as relating to your ethnic origin, religious or philosophical beliefs, membership of a political or trade association, sexual preferences or health), and would not do so without your consent.

You have the right to remain anonymous or use a pseudonym when dealing with us, unless:

  • the use of your true identity is a legal requirement; or
  • it is impracticable for us to deal with you on such basis.
How we collect and hold personal information

We aim to collect personal information only directly from you, unless it is unreasonable or impracticable for us to do so.  For example, we may collect personal information about you from:

  • information you provide us when you make an enquiry;
  • information you submit to us via our website;
  • information you provide when you purchase and use our software; and
  • information derived from other communications between us and you.

However, in some circumstances, it may be necessary for us to collect personal information through other lawful means such as from third parties or from a source of publicly available information.

If we receive personal information that we have not requested (unsolicited information) and we determine that we could not have collected that information under the Regulations if we had requested it, then we will destroy or de-identify the information if it is lawful and reasonable to do so.

Purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us in order to:

  • provide our services and software to you;
  • to carry out and develop our business functions;
  • promote our products and services;
  • develop and improve our products and services;
  • to measure usage by user and time;
  • for such other purposes as specified at the time of collection; or
  • for related purposes that you would reasonably expect.

Periodically, we may advise you of upgrades to existing products, new products and training or other events.  You can stop receiving these notifications at any time by sending an email to the email address noted below, under the Contact heading.

The legal basis on which we rely and which legally permits us to process your personal data is:

  • you have given us consent for the processing of your data;
  • the processing is necessary for the performance of a contract to which you are a party or you have requested us to take the necessary steps so you can become a party to a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary in order to protect your vital interests or of another natural person; or
  • processing is necessary for the purposes of the legitimate interests pursued by us.

We respect the privacy of your personal information and will take reasonable steps to keep it strictly confidential.  We will only disclose personal information to third parties if it is necessary for the established purpose of collecting the information, or for a related purpose that could be reasonably expected.  Where such a disclosure is necessary, we will require that the third party undertake to treat the personal information in accordance with the Regulations.  

It may be necessary for us to disclose personal information to overseas recipients from time-to-time, particularly as it relates to the storage of personal information (see below). However, we will protect that information as described in this Privacy Policy and in accordance with the Regulations.  We will also require that any overseas recipient undertakes to treat the personal information in accordance with the Regulations.

Otherwise, we will only disclose your personal information to third parties without your consent if the disclosure is:

  • necessary to protect or enforce our legal rights or interests or to defend any claims;
  • necessary to prevent or lessen a serious threat to a person’s health or safety;
  • required or authorised by law; or
  • permitted by another exception in the Regulations.

If you are based in the EU, please note that it may be necessary for us to transfer your personal information to recipients in countries which are outside of the European Economic Area (e.g. Australia). Where any such transfer is necessary, we shall put in place appropriate safeguards to ensure that your personal information is held securely and in accordance with the GDPR. If you require further information about the safeguards put in place you can request it from us by contacting us by email at the email address set out below, under the Contact heading.

Where we wish to use or disclose your personal information for other purposes, we will obtain your consent.

How we secure and protect your personal information

We will take reasonable steps to keep secure any personal information which we hold and to keep this information accurate and up to date.

Your personal information is held and stored on paper, by electronic means or both.  We have physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorized access, modification and disclosure. We use industry accepted and compliant technology and security so that we are satisfied that your information is transmitted safely to us through the internet or other electronic means.

We further confirm that:

  • data held and stored on paper is stored in lockable offices and in secure premises;
  • data held and stored electronically is protected by internal and external firewalls, limited access via file passwords, and files designated read-only or no access;
  • data held and stored “in the cloud” is protected by internal and external firewalls, limited access via file passwords and files designated read-only or no access.;
  • we require our IT contractors and other third parties to implement privacy safeguards; and
  • where we disclose personal information to third parties (including contractors and affiliated businesses located locally and overseas), our contractual arrangements with them include specific privacy requirements.

Your personal information may be stored and processed outside of Australia.  When transferring information to others, we ensure that appropriate and suitable safeguards and data protection measures are in place to protect your personal data and which comply with the Regulations

We will only retain your personal information for as long as is reasonably necessary in relation to the purposes for which it was collected. We will also retain personal information to ensure compliance with any applicable statutory or regulatory obligations imposed on us in relation to the retention of records.

Where you have requested we stop processing your personal data for marketing purposes, we may retain a record of your request to ensure we abide by your request in the future.

Destruction and De-identification

We will retain your personal information whilst it is required for the purpose for which it was collected, for our business functions, or for any other lawful purpose. 

We use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed.  For example, paper records are shredded or destroyed securely and electronic records are deleted from all locations, to the best of our ability, or encrypted and/or placed beyond use.

Software

When you install our software, we collect certain information about your device, such as:

  • the device or machine name; and
  • the licence key you have entered and information about our licenced software to which you have access.

Logs about whether or not an installation or activation by you is successful are also kept for auditing purposes.

Some of our software gives you the ability to voluntarily submit software usage information. This data is sent anonymously and can include the windows you access or the controls you use. This allows us to internally analyse the areas of the software regularly used and how they can be improved.  Other than in respect of user name, device/machine name and session usage times (the “Licensee Requested Usage Data”), sending usage information is not enabled by default and must be agreed to by each user.

When you use our software, the Licencee Requested Usage Data may, from time to time, be shared with the licensee of the software (noting that a licensee and the user of the software may be different parties).  The Licencee Requested Usage Data may be used by the licensee of the software to assist with future software purchases.

If an error is displayed while using our software, you may voluntarily send the log files to us to report the error. Device information such as system specifications as well as our licence information and product version information are collected by us in order to identify the cause and best method of rectifying the error. We will use this information for the sole purpose of identifying the individual user with the error, corresponding with them, identifying the cause of the error, and for the provision of information regarding resolutions. Error information is not sent automatically by the application. No internal project data is transferred with the error log information.

While our software may contain links to other websites to assist you to access further useful information, those websites are not subject to our privacy standards, policies and procedures (with the exception of our related entities’ websites). We recommend that you make your own enquires as to the privacy policies of these third parties and we are in no way responsible for the privacy practices of these third parties.

Website

When you browse our website or contact us electronically, we may record geographical tagging, cookies and statistical data. This may include your IP address, date and time of your visit, operating system, language preferences, device characteristics, pages visited, information downloaded and type of browser used to access the Site. 

We use this information to help us to make decisions about maintaining and improving our website and any online services.

A “cookie” is a small text file which is placed on your computer by our webpage servers when you access our Site. The purpose of a cookie is to help analyse web traffic and to allow our Site to respond to you when you return to our site. Cookies are also used to enhance the secure use of our Site.

Cookies are frequently used and in themselves do not identify the user, just the computer used.  You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser.  If you decide not to display cookies you may not experience optimum performance of our Site.

While our website may contain links to other websites to assist you to access further useful information, those websites are not subject to our privacy standards, policies and procedures (with the exception of our related entities websites). We recommend that you make your own enquires as to the privacy policies of these third parties and we are in no way responsible for the privacy practices of these third parties.

Online Tracking

We may use third-party web analytics services on our website, such as Google Analytics. These service providers help us analyse how users use our website. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use anonymised, aggregated data collected from users of our website in connection with their own businesses, including in order to improve their products and services.  To learn more about opting out of data collection through Google Analytics, click the following link: Google Analytics opt-out

You may see certain ads on other websites based on your visits to our website because we may participate in advertising networks administered by third-party vendors, such as Google Adwords.  Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context.

These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons.  The networks use this information to show you advertisements that are tailored to your individual interests, to track your browser across multiple websites, and to build a profile of your web browsing.  The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you view and the actions you take on the websites.  This data collection takes place both on our website and on third-party websites that participate in the ad networks.  This process also helps us track the effectiveness of our marketing efforts. 

We may use features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keywords used to visit our website.

Requests for access and correction

You have a right to request access to, and correction of, personal information held about you.  We have procedures in place for dealing with and responding to requests for access to, and correction of, the personal information held about you.

To request access to or correction of personal information held about you, please send a written request to us. Our contact details can be found below. Your written request should include:

  • if it is a request for access to personal information, details regarding which information is requested to be produced; or
  • if it is a request to correct personal information, details of the misrepresented information and the corrections to be made.

In most cases, we expect that we will be able to comply with your request.  However, if we do not agree to provide you access or to correct the information as requested, we will give you written reasons why.  For example, a request to access personal information may be rejected if:

  • the request is frivolous or vexatious;
  • providing access would have an unreasonable impact on the privacy of another person;
  • providing access would pose a serious and imminent threat to the life or health of any person;
  • providing access would prejudice our legal rights; or
  • there are other legal grounds to deny the request.

To assist us to keep our records up-to-date, please notify us of any changes to your personal information.

Complaints and concerns

We have procedures in place for dealing with complaints and concerns about our practices in relation to the Regulations.  We will respond to your complaint in accordance with the relevant provisions of the Regulations.  Any complaints should be directed to us at our contact details below.

Nothing in this policy prevents you from making a complaint to the relevant privacy regulatory authority in Australia (namely the Office of the Australian Information Commissioner). If you are based in the EU, please note that you have the right to lodge a complaint with a relevant supervisory authority for data protection issues. For more information about privacy issues in Australia and protecting your privacy, visit the Australian Federal Privacy Commissioner’s website at www.privacy.gov.au.

Changes to this Privacy Policy

It may be necessary for us to review and revise our Privacy Policy from time to time. An amended version will be posted on our website at www.pronamics.com.au/privacy-policy/. We suggest that you visit our website regularly to keep up to date with any changes. The continued use of our website by you indicates that you acknowledge and agree to any future changes of our Privacy Policy.

Contact

If you would like any further information, or have any queries, problems or complaints in relation to this Privacy Policy or our information handling practices in general, please email us at info@pronamics.com.au, telephone us on +61 7 3481 9666 or complete a feedback form and ask for our Privacy Officer appointed to look after these concerns.

Version 4.1 – updated 6/3/2024