SIRVA Pty Ltd ABN 53 115 936 993 and SIRVA Relocation Pty Ltd ABN 95 098 843 326
SIRVA Pty Ltd, SIRVA Relocation Pty Ltd and their related entities (referred to as SIRVA, we or our) are committed to the protection of your Personal Information and Sensitive Information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) as amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (Privacy Act).
|1||What is the difference between "Personal Information" and "Sensitive Information"?|
"Personal Information" is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
"Sensitive Information" includes an individual's health information, genetic information, biometric information or templates, or personal information that is also information or an opinion about an individual's race or ethnicity, their religious, political or philosophical beliefs, opinions or affiliations, their sexual orientation or criminal record.
|2.||What information do we collect and hold?|
SIRVA may collect and hold Personal Information such as your name, gender, date of birth, contact details (including your address, phone numbers and emails, whether personal or for work, current or historical), family details (including Personal Information of family members), citizenship details, employment details (whether current or historical), education details, passport, travel or visa details (whether current or historical), financial information, payment details, bank account details, tax file number and/or services information and preferences.
|2.2||Sensitive Information. |
SIRVA may collect and hold Sensitive Information such as your health information (including mental health information and medical history, whether current or historical, general or in relation to specific conditions), your criminal record (including any probation or parole orders, imprisonment or involvement in the commission of any criminal offences), character information (including outstanding debts, national security information, deportation or detention information) or your ethnic origin.
|3||Why do we collect Protected Information?|
|3.1||SIRVA collects Protected Information from clients (whether individuals or employer entities), employees, contractors, agents, and other individuals that is reasonably necessary for one of more of our functions or activities, including: in order to allow us to conduct our business functions, to meet any regulatory requirements which apply to our business, to market and sell our services and to conduct employee related activities.|
|3.2||You have the option to deal with us anonymously or by using a pseudonym. However you acknowledge that where this is impractical (for example when you contract with us) or where the law or a court order provides otherwise we are not required to provide these options to you.|
|3.3||If you choose not to provide your Personal Information to SIRVA, we may not be able to undertake certain activities for you such as providing you with requested information or services.|
|4||When and how do we collect Protected Information?|
|4.1||SIRVA collects Protected Information when you: visit our Website, supply or buy services, request information about us or our services, provide feedback, respond to a survey, change your content or email preferences, contract with us, fill in a form on our Website, or contact us by telephone, facsimile, email, post or in person.|
|4.2||SIRVA may also collect Protected Information about you via third parties including from our suppliers, agents and government agencies.|
|4.3||In some circumstances we may receive Protected Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.|
|5||Information collected via our Website|
|5.1||SIRVA will not collect any Protected Information about users of our Website except when they knowingly provide it or as otherwise described below. For example, SIRVA may collect Protected Information from users of the Website when they:|
|5.2||Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns.|
|5.4||Web beacons are images that originate from a third party site to track visitor activities. SIRVA may use web beacons to collect aggregate data and provides this information to our Website host to administer and improve the performance of our Website. |
|5.5||We use Google and/or other third-party service providers to serve ads on our behalf across the Internet and sometimes on our Website. They may collect anonymous information about your visits to our Website (not including your name, address, email address or telephone number), and your interaction with our services. They may also use information about your visits to the Website and other websites to target advertisements for goods and services in order to provide more relevant advertisements about goods and services of interest to you.|
|6||How SIRVA uses the Protected Information it collects about you|
|6.1||SIRVA uses the Protected Information it collects about you for our business functions and activities, which may include the following purposes:|
|6.2||SIRVA may use your Protected Information for a secondary purpose if that secondary purpose is related to those purposes in clause 6.1, if we have your consent or if otherwise provided for under the Privacy Act.|
|6.3||SIRVA may use your Protected Information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Protected Information from a third party. Direct marketing material may include promotional material about SIRVA or the services offered by SIRVA.|
|6.4||You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 13.|
|7||Who do we disclose your Protected Information to?|
|7.1||Depending on the nature of your relationship with SIRVA, we may disclose your Protected Information to shareholders, officers and employees of SIRVA, other businesses within our group of companies, service providers who assist us in our business operations (including third party service providers based overseas), government agencies, parties involved in the purchase or sale of any of our businesses, other third parties (including parties that are connected with or involved in our relationship with you), or otherwise as required by law.|
|7.3||We may also share non-personal, de-identified and aggregated information for research or promotional purposes, in connection with providing requested information or services to you, or for the purpose of improving our services. We will not sell your Protected Information to third parties for marketing purposes.|
|8||Disclosure of your Protected Information overseas|
|8.1||Your Protected Information may be disclosed outside of Australia to an entity in a foreign country, including entities in which SIRVA has an ownership interest or third party service providers (Overseas Entities). The countries where your Protected Information may be disclosed will depend on the nature of our relationship with you, including whether we are responding to your enquiries, information requests or application for our services and the countries that these relate to. You can request a list of countries where your Protected Information is likely to be disclosed by contacting SIRVA in any of the ways set out in clause 13.|
|8.2||It is possible that Overseas Entities to which we disclose your Protected Information may be subject to foreign laws that do not provide the same level of protection of information as in Australia. Overseas Entities may not be subject to any privacy obligations in some countries and they may be required or compelled to disclose your Protected Information to a third party such as overseas authority. You may not be able to seek redress in the overseas jurisdiction against the Overseas Entity.|
|8.3||By providing us with your protected information, you acknowledge and consent to us sharing your protected information to overseas entities for the purposes set out above, and you consent to us making multiple disclosures to an overseas entity for the same purpose as that initial disclosure. If you do not consent to us disclosing your protected information to Overseas Entities we may not be able to provide you with the requested services.|
|8.4||If you consent to us disclosing your Protected Information to an Overseas Entity and that Overseas Entity breaches the APPs, we will not be accountable for that breach under the Privacy Act and you will not be able to seek redress in respect of that breach under the Privacy Act.|
|9||Storage and security of Protected Information held by SIRVA|
|9.1||SIRVA will take reasonable steps to protect your Protected Information from misuse, interference and loss and from unauthorised access, modification or disclosure.|
|9.2||SIRVA aims to keep your Protected Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Protected Information that we handle, including information which is held on SIRVA's computer systems.|
|10||Updating and correcting your Protected Information|
|We will take reasonable steps to ensure that the Protected Information that we hold is accurate, up-to-date and complete. You can update your Protected Information at any time by contacting SIRVA in any of the ways specified in clause 13. SIRVA welcomes any changes to your Protected Information so as to keep our records up to date.|
|11||How long will SIRVA keep your Protected Information?|
|11.1||We will keep your Protected Information only for as long as required for our business purposes and otherwise as required by Australian law.|
|11.2||Where we no longer need to keep your Protected Information in accordance with clause 11.1, we will take reasonable steps to destroy or de-identify your Protected Information.|
|11.3||If you wish to have your Protected Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).|
|12||Finding out what Protected Information SIRVA holds about you|
|12.1||You are entitled to access Protected Information that SIRVA holds about you. If you request access to your Protected Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Australian Privacy Principles or at law. If we refuse your request to access your Protected Information, we will provide you with written reasons for the refusal.|
|12.2||A request for access can be made by contacting SIRVA in any of the ways specified in clause 13.|
|13||How to contact us and more information|
Att: Privacy Officer
202-228 Greens Road, Dandenong South, Victoria 3175 Australia
|13.2||You can find out more information about the Privacy Act and the Australian Privacy Principles from the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au(email - email@example.com).|
SIRVA is committed to the protection of privacy. The aim of SIRVA is to provide an environment which will ensure the information provided to us will be handled in as secure, efficient and confidential a manner as possible, and in accordance with legislation.
Persons providing information to SIRVA will be subject to this policy, including consent to the collection and use of personal information and a right to make amendments to this statement from time to time. We encourage all interested parties to regularly review the statement on this site to be informed of any amendments.
What Information do we collect and store?
Customers of SIRVA may be asked to submit personal details about themselves verbally, by email, in online form or in hard copy form. The information submitted or sent electronically is received by our network and stored in our database. The information provided verbally is also stored in our database. Hard copy information is held within secure files on our business premises.
In providing SIRVA with information, sending SIRVA an email, completing an online form or providing hard copy information, providers of information accept that SIRVA is granted consent to use any personal information within our organisation for the purposes prescribed including responding to queries, republishing information on our site, and compilation of databases and research for marketing purposes.
How do we use the information we collect?
The information we collect is used to provide SIRVA’s services. We pass on depersonalised information in statistical or demographic form to third parties and government departments. We do not intend to submit personal information to third parties. However, if we do we will seek consent prior to submitting personal information where practicable.
The SIRVA website does not have information-recording software such as ‘cookies’. SIRVA does monitor activity on the SIRVA website.
We may use the information provided to send newsletters outlining news, services or events. In newsletters we have instructions as to how receivers unsubscribe from the mailing list. If marketing material is not required or if inclusion in the mailing list is not necessary, please contact our Privacy Officer on (03) 9797 1600, or write to the Privacy Officer, SIRVA, PO Box 123, Dandenong, Victoria, 3175.
We will not sell, trade or disclose any personal information to any third party without consent or unless we are required by law to do so.
We reserve the right to modify the information, collate, edit or track personal information in order to improve our services or if required by law.
Security, Quality and Accuracy of Information
We endeavour to keep personal information up to date and accurate. However, customers must let us know if there are any details accidentally recorded incorrectly in an email, in an online form, or in hard copy. We will endeavour to correct personal information within three business days of receiving a written request.
Whilst we will take all due care in protecting the security, confidentiality and privacy of the information submitted, we cannot guarantee that systems will be completely free from third-party interception or damage to information transmitted by email which is caused by viruses.
Use of Information Outside Australia
As part of a contract with SIRVA, we may need to transfer some personal information to an international affiliate or affiliates. All reasonable endeavours will be used to ensure that the recipient jurisdiction has in place a similar regime that recognises the rights to privacy.
Rights to Access and Amend Information
If details about other parties have been submitted to SIRVA, there is an entitlement to access the information that is subsequently handled within our organisation. There are exceptional circumstances where access to individual personal information may be refused by us, such as where access would be unlawful. We will advise of such circumstances if they arise.
If access to personal information is required, please submit a request to the Privacy Officer, SIRVA, PO Box 123, Dandenong, Victoria, 3175, outlining the documents or information required. We will endeavour to respond to any query within three business days of receiving a written request.
SIRVA encourages individuals to make contact to update any details or to correct any inaccuracies that may have inadvertently been recorded.
If any aspect of the way personal information has been collected or handled by SIRVA causes concern, please do not hesitate to contact SIRVA’s Privacy Officer. Please let SIRVA know if there are any queries in relation to any aspects of the above statement by contacting the Privacy Officer.