Collection of information
3. Some information provided to us by clients, customers and other parties might be considered private or personal. However, without such information we would not be able to carry on our business and provide our services. We will only collect such personal information if it is necessary for one of our functions or activities. The kinds of personal information that Luxul may collect and hold in respect of individuals includes:
4. In particular, personal information is collected in the following situations by Luxul:
5. At or before the time the personal information about an individual is collected by us, we will take reasonable steps to ensure that the individual is made aware of who we are, the fact that the individual is able to gain access to the information held about the individual, the purpose of the collection, the type(s) of organisations to which we may usually disclose the information collected about the individual, any laws requiring the collection of the information and the main consequences if all or part of the information is not collected.
6. We usually collect your personal information about individuals directly from the individual. However, sometimes we may need to collect personal information about individuals from third parties for the purposes described below in this policy. The circumstances in which we may need to do this include, for example, where we need information from a third party to assist us to process an application (such as to verify information an individual has provided or to assess the individual’s circumstances) or to assist us to locate or communicate with the individual.
Use of information collected and disclosure of personal information to others
7. We may use or disclose personal information held about an individual as permitted by law and for the business purposes for which it is collected (e.g. provision of our services, including administration of our services, notifications about changes to our services, record-keeping following termination of our services and technical maintenance) - that is, to carry on our business and provide services to our customers. We may also use such information about individuals for a purpose related to the primary purpose of collection and where the individual would reasonably expect that we would use the information in such a way. This information is only disclosed to persons outside our business in the circumstances set out in this policy or as otherwise notified at the time of collection of the information.
8. Luxul’s business purposes for which personal information is collected, used and disclosed may include:
9. In addition we are permitted to use or disclose personal information held about individuals:
10. Third parties to whom we may disclose personal information about individuals in accordance with Luxcul’s business purposes set out above may include:
Anonymity and Pseudonymity
11. Individuals have the option of dealing with Luxul anonymously. However, this only applies where it is not impracticable for Luxul to deal with individuals acting anonymously or under a pseudonym. For example, individuals making general enquiries of Luxul may do so anonymously or under a pseudonym. However, if the dealing with Luxul is for Luxul to supply goods and services and/or to enter into contractual relations then it is impractical for individuals to deal with Luxul on an anonymous basis or under a pseudonym.
12. As part of Luxul’s functions and business activities and to promote the services we can provide to our customers, Luxul may use personal information that individuals have provided to Luxul for the purposes of direct marketing. Direct marketing includes, but is not limited to, sending to our customers and other parties (including individuals) and/or contacting our customers (including individuals) in relation to promotions and information about Luxul. Recipients of direct marketing are always able to opt out of receiving direct marketing communications by sending an email to Luxul’s Privacy Officer at firstname.lastname@example.org. In any direct marketing communication we remind recipients of their right to opt out of receiving direct marketing communications.
13. Our web site may contain links to other web sites and those third party web sites may collect personal information about individuals. We are not responsible for the privacy practices of other businesses or the content of web sites that are linked to our web site. Luxul encourages users to be aware when they leave the site and to read the privacy statements of each and every web site that collects personally identifiable information.
Security and storage
14. Luxul places a great importance on the security of all information associated with our customers and clients and others who deal with us. We have security measures in place to protect against the loss, misuse and alteration of personal information under our control. Luxul takes all reasonable steps to protect personal information that is under Luxul’s control from misuse, interference, loss and/or unauthorised access, modification or disclosure. All personal information held is kept securely and that which is held electronically is held on secure servers in controlled facilities.
15. Personal information is de-identified or destroyed securely when no longer required by us.
16. Luxul retains information provided to us including individuals’ contact and financial and transactional information to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. Such information is held securely, including on secure servers in controlled facilities.
17. Information stored within our computer systems or by our agents who provide electronic storage facilities can only be accessed by those entrusted with authority and computer network password sanctions.
18. No data transmission over the Internet can be guaranteed to be 100 per cent secure. As a result, while we strive to protect users' personal information, Luxul cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once Luxul receives a transmission, we make every effort to ensure the security of such transmission on our systems.
Access to and correction of personal information
19. Luxul is committed to and takes all reasonable steps in respect of maintaining accurate, timely, relevant, complete and appropriate information about our customers, clients and web-site users.
20. Any individual may request access to personal information about them held by Luxul. Such a request for access to personal information is to be made to Luxul’s Privacy Officer:
Privacy Officer Telephone: 1300 669 277
PO Box 3687 Email: email@example.com
21. Please note Luxul does require that, as part of any request by an individual for access to personal information, the individual verify their identity so that Luxul may be satisfied that the request for access is being made by the individual concerned.
22. Please note that Luxul is not required to give an individual access to personal information in circumstances where:
(i) Luxul has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Luxul’s functions or activities has been, is being or may be engaged in;
(ii) giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
23. Inaccurate information will be corrected upon receiving advice to this effect. To ensure confidentiality, details of an individual’s personal information will only be passed on to the individual if we are satisfied that the information relates to the individual. From time to time, and having regard to the purpose of the collection and use of personal information about individuals, we may contact individuals to seek confirmation that the personal information provided to us by the individual is accurate, up-to-date and complete.
24. If we refuse to provide an individual with access to or correct the personal information held by us about the individual, then we will provide reasons for such refusal. Such reasons will set out the grounds for refusal, the mechanisms available to complain about the refusal and any other matters that are required by the Act.
25. Luxul will respond to any requests for access or correction within a reasonable time of receipt of the request, but by no later than 30 days of the request being received.
27. We will investigate any complaint within 30 calendar days and attempt to resolve any breach that might have occurred in relation to the collection, use or destruction of personal information held by us about the complainant in accordance with the Commonwealth Privacy legislation and the APPs. If a complainant is not satisfied with the outcome of this procedure then the complainant may contact the Office of the Australian Information Commissioner (“OAIC”). The web site of the OAIC is www.oaic.gov.au.
Credit Card Information
28. Luxul do not keep records of credit card details.
Transfer of information overseas
29. Luxul is unlikely to disclose personal information to overseas recipients. Personal information will only be disclosed by Luxul to overseas recipients in accordance with Australian Privacy Principle 8, such as if the disclosure is required by Australian law.
30. Luxul collects information from the site using "IP files".
31. When a user visits Luxul’s web site to read, browse or download information, our system will record/log the user’s IP address (the address which identifies the user’s computer on the internet and which is automatically recognised by our web server), date and time of the visit to our web 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 improved online service. We may automatically collect non-personal information about users such as the type of Internet browsers used or the site from which the user linked to our web sites. Individuals cannot be identified from this information and it is only used to assist us in providing an effective service on our web sites. You can adjust your Internet browser to disable cookies or to warn you when cookies are being used. However, if you disable cookies, you may not be able to access certain areas of our web site or take advantage of the improved web site experience that cookies offer.
34. For more information on privacy legislation or the APPs please visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.