Our Trace Pty Ltd (ACN 639 998 799) of Level 8, 11 York Street, Sydney NSW 2000 (we, us and our) understand that your privacy is paramount, and are committed to protecting your privacy. This policy sets out how we handle information about you.
- Collection of personal information
Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.
We may collect personal information from you when you:
- buy any goods or services from us, we will collect the personal information you provide to us during the ordering process or in the course of the purchase
- visit our website;
- complete our carbon footprint calculator quiz;
- participate in any event, activity or competition organised or run by us;
- contact us by any method, such as telephone, email, post, facsimile or in person,
or otherwise as notified to you from time to time.
The personal information you provide to us may vary depending on the nature of your interaction with us, but may for example include your name, date of birth, address, contact details, behavioural data collected in our carbon footprint quiz and any communications you send to us.
There may be occasions when we collect information about you from a third party. In such instances, we will determine whether we would have been entitled to collect such information from you and to the extent we would not have been entitled to do so, we will destroy or de-identify such information as soon as reasonably practicable.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact us with a general enquiry, we will not ask for your name unless we need it to adequately handle your enquiry.
However, for most of our functions and activities we usually need your name and contact information.
- Our website
Our web servers may automatically collect information when you visit our websites, including:
- your IP address;
- the date and time of your visit;
- the parts of our website you access during your visit;
- your actions on our website; and
- the browser you are using.
We do not currently seek customer consent to capture cookies. This may be reviewed and amended as we expand our operations internationally.
Please note that rejecting cookies may mean that some or all of the functions on our website will not be available to you.
Sometimes our websites contain links to other websites. When you access a website other than our websites, we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each website you visit.
- Using your personal information
The personal information that we collect is generally used to provide products or services to you, and, if you use our website, to track your usage, to evaluate performance of our website, and to keep track of your account settings. Information collected by us may also be used for the following purposes:
- to provide you with information in relation to the products and services we provide;
- to send email notifications for special promotions or offers conducted by us;
- to conduct marketing activities and to conduct market research;
- to respond to your questions or suggestions;
- to improve the quality of our products or services; or
- to improve the quality of your visit to our Website.
You may opt out of receiving marketing information by notifying us accordingly, or by using any unsubscribe facility we provide for that purpose.
- Sharing your personal information
We may disclose your personal information to other related entities within our corporate group for our own business purposes, including third party contractors, who help us conduct our business. Where information is shared with these third parties, we will take all reasonable steps to ensure that third parties observe the confidential nature of such information and are prohibited from using any or all of this information beyond what is necessary to assist us.
All third party contractors are subject to Trace due diligence and will sign a Confidentiality Agreement as necessary.
While we may market the goods or services of third parties in limited circumstances as described above, we will always do so ourselves (or using our own third party contractors). In some circumstances we may agree to share your personal information with third parties in exchange for a promotional offer that benefits our customers (such as a free product). In these circumstances, you will be informed of the information exchange for marketing purposes and given the option to opt out.
- Accessing and correcting your personal information
We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under relevant privacy legislation. If you require access to your personal information, please contact our Trace as described in section 9 below. You may be required to put your request in writing for security reasons.
For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.
If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).
We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.
Under GDPR, you have the right to require trace to delete your data in certain circumstances, including, but not limited to where the information is no longer necessary for the purpose for which it was collected, or where the individual withdraws their consent and there is no other legal ground for processing their data (Article 17). To request that your personal information be erased, please contact firstname.lastname@example.org.
- Protecting your personal information
We are committed to protecting your personal information. We take appropriate security measures to protect your personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.
- Change of policy
- Contact information
If you have any queries or complaints with regards to our collection, use or management of your personal information, please contact Trace:
A: Privacy Officer, Trace, Level 7, 11 York Street, Sydney, 2000.
If you make a complaint, we will endeavour to respond to it as soon as possible. If you are dissatisfied with our response, you have the right to make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at email@example.com.
Updated: 16 March 2020