Table of contents
> Our privacy commitment
> Our privacy obligations
> How and why does CommTrade International collect and hold your personal information?
> What kind of personal information does CommTrade International collect and hold?
> How does CommTrade International use your personal information?
> In what circumstances will CommTrade International disclose your personal information?
> Who do we disclose your personal information to?
> Direct marketing
> Does CommTrade International disclose your personal information to overseas recipients?
> Use of Government Identifiers
> Data quality and Security
> Website usage
Links to third party sites
> How you can access or correct your personal information
> How you can notify us of a privacy concern or contact our Privacy Contact Officer

Our Privacy Commitment

CommTrade International is committed to protecting the privacy of your personal information. We manage your personal information in an open and transparent way.

CommTrade International will only use your personal information when it is necessary for us to deliver you a service or perform other necessary business functions and activities.

CommTrade International will not use or disclose your personal information for purposes unrelated to the services we provide, unless we first obtain your consent.

Where we can, we will allow you to deal with us anonymously or by using a pseudonym. However, in some circumstances, this may not be possible, and CommTrade International may need to collect personal information from you to provide you with a delivery or other service. In some cases, if you do not provide the required personal information we will not be able to provide you with a service.

Our privacy obligations

This privacy policy sets out how we comply with our obligations under the Privacy Act 1988 (Cth). CommTrade International is bound by the requirements of these privacy laws, which regulate how we may collect, use, disclose and store personal information. These laws also specify how individuals may access and correct personal information held about them.

“Personal Information” means information or an opinion about an identified individual (or an individual who is reasonably identifiable), whether true or not, or recorded in a material form or not.

For example, this types of information could include your name, contact details, age and health information.

In this policy ‘we’, ‘us’, ‘our’ and ‘CommTrade International’ refers to CommTrade International Pty Ltd, ABN 56 112 403 620.

If you have any questions regarding CommTrade International’s Privacy Policy, please email us at [email protected]. If you would like CommTrade International to send you a copy of this policy, please contact us and we will do so.

By visiting our website and/or providing your personal information to us, you consent to the terms and conditions in this Privacy Policy, unless you tell us to the contrary by contacting our Privacy Contact Officer. This privacy policy is effective from March 2016. From time to time, our privacy policies and procedures will be reviewed and, if appropriate, updated. If any changes are made to this policy these will be posted on our website.

How and why CommTrade International collect and hold your personal information?

CommTrade International will only collect personal information about you by lawful and fair means, and not in an unreasonably intrusive manner.

It is CommTrade International’s usual practice to collect personal information (about you (and possibly about your family) directly from you when you:

We may collect personal information about you from a third party or a publicly available source, but only if you have consented to such collection, or would reasonably expect us to collect your personal information in this way.

CommTrade International only collects personal information for purposes that are directly related to our business activities, and only when it is necessary for or directly related to such purposes. We also collect personal information related to employment services, human resource management, and other corporate service functions.

If we receive information about you from a third party and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so).

What kind of personal information does CommTrade International collect and hold?

Any personal information that you provide via our websites or directly (for example, when you sign up to receive marketing information or apply for a credit account) is collected and managed by CommTrade International.

If you provide your personal information to a third party via a link from the CommTrade International website, that information is collected and managed by those third parties. You should familiarise yourself with their privacy policies prior to deciding whether you wish to provide them with your information.

The types of personal information CommTrade International may collect includes (but is not limited to) your:

> name;
> date of birth;
> gender;
> marital status and family details;
> residential address;
> email address;
> contact telephone numbers;
> place of work;
> identification details;
> testimonials, comments or opinions;
> photos of you;
> recipes;
> financial information, such as credit card details;
> written or verbal contact with CommTrade International, including voice recordings of telephone conversations you have had with our employees; and
> activities, including but not limited to dining and other lifestyle interests.
If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.

How does CommTrade International use your personal information?

We use your personal information for a variety of reasons including to:
provide services and products to you;
answer your inquiries and deliver customer service to you;
facilitate your credit account;
to tell you about other products that we think may be of interest to you;
maintain and improve customer services;
meet our legal obligations;
manage and resolve any legal or commercial complaints and issues;
carry out internal functions including training; and
conduct marketing research and analysis.
Whilst you may opt not to provide us with your personal information, you should be aware that without this personal information, we may not be able to provide you with some of the services and/or products you are seeking.

In what circumstances will CommTrade International disclose your personal information?

In the course of conducting our business and providing our products and services to you, we may disclose your personal information.

We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities. We do not give it to anyone else unless one of the following applies:

you have consented to the disclosure;
you would reasonably expect, or have been told, that your information is passed to those individuals, bodies or agencies; or
it is otherwise required or authorised by law.
If we engage third party agents or contractors, we will take all reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.

Who do we disclose your personal information to?

We may disclose your personal information to:
another CommTrade International business;
professional advisers (such as lawyers or auditors);
payment systems operators and financial institutions;
organisations authorised by CommTrade International to conduct promotional, research or marketing activities;
upon lawful request from law enforcement agencies or government authorities; and
any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.
In all circumstances where your personal information is disclosed, we will take all steps reasonable to ensure that these third parties undertake to protect your privacy.

Direct Marketing

We are committed to compliance with all laws and requirements relating to the use of your personal information for direct marketing.

When you provide your personal details, you may consent to us using your personal information for direct marketing purposes (for an indefinite period).

From time to time, we may contact you with information about products and services offered by us and our related entities and our business partners, which we think may be of interest to you. When we contact you it may be by mail, telephone, email or SMS.

Where we use or disclose your personal information for the purpose of direct marketing, we will:
allow you to request not to receive direct marketing communications (also known as ‘opting-out’); and
comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

In some circumstances, CommTrade International may disclose your personal information to overseas recipients. If this occurs, we take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the relevant privacy laws in relation to that information.

Sometimes we use third party platforms and services to process sales, provide web support, send marketing messages, deliver products or otherwise deliver information.

These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas. We use products and services maintained in Australia and Chicago, Illinois (United States of America).

Your personal information may be stored in a secure and encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us (or by third parties on CommTrade International’s behalf).

Use of Government identifiers

CommTrade International will not use Government Identifiers, such as Medicare numbers, or a driver’s licence number as its own identifier of individuals.

Data and Security?

We will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure.

The personal information that we collect about you is stored on our database server managed by Campaign Monitor. They use a state-of-the-art redundant server cluster in fully managed data centers across multiple geographic locations. All sensitive data is stored on servers behind a constantly maintained firewall using the same level of encryption as many banks.

Campaign Monitor are an Australian company but their servers are based in the United States. They use Rackspace (http://www.rackspace.com/about/datacenters/) for their primary data center, and they are based in Chicago, Illinois. They also have a backup data center at Orcsweb (http://www.orcsweb.com/hosting/our-data-center/), who are based in Charlotte, North Carolina.

The CommTrade International website is on a datacenter located in Chicago, which is equipped with raised floors, climate control, 24/7 security, fire suppression systems, water detection systems, UPS & generators to ensure that our customers data is safe and secure. Databases saved in MySQL on the server. The Network is routed by the top of the line Juniper edge routers and aggregated through Cisco and Juniper switches.

We have a range of systems and communication security measures, as well as the secure storage of any hard copy documents. Access to your personal information is restricted to those properly authorised to have access. Hard copy documents are stored in the Finance department in filing cabinets, access by key account staff.

CommTrade International also has policies in place for data retention across all key areas. We keep your personal information for as long as it is required to provide you with the products you requested from us and to comply with legal requirements. If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information. Any inactive accounts (for 12 months plus) are destroyed.

Website usage?

Our websites are professionally hosted and operate in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet.

Ensure you logout when you have finished visiting our website, especially if you accessed it from a shared computer.

Cookies are pieces of information that a website transfers to your computer for record-keeping purposes. The information collected may be used by CommTrade International to improve your experience on our website. If you visit an area of the website where you are not required to log on, to read, browse or download information, our system will record the date and time of your visit to our site, the pages viewed and any information downloaded.

Any personal information that you submit to us using our website or in an e-mail will only be used in accordance with this privacy policy.

Links to third party sites

Whilst links to third party websites are provided on our website, we are not responsible for the content or practices of these third party websites.

These links are provided for your convenience and do not represent CommTrade International’s endorsement of any linked third party website.

We recommend that you check the privacy policies of these third parties prior to providing them with your personal information.

No links may be made to this website without our prior written consent. Applications for consent must be made to The Marketing Manager, email [email protected]

How can you access or correct your personal information?

You can request access to the personal information we hold about you at any time, and we will

provide you with that information unless we are prevented by law from giving it to you.

If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.

If you believe that your personal information is not accurate, complete or up to date, please contact us by telephone on (61) 414 631 327, via email to [email protected] or address your request to the CommTrade International Pty Ltd, 19 Hickson Road, Walsh Bay NSW 2000.

How you can notify us of a privacy concern or contact our privacy contact officer

If you:
> have queries, concerns or complaints about the manner in which your personal information has been collected or handled by CommTrade International; or
> would like to request access to or correction of the personal information we hold about you;
please write to: The Marketing Manager Commtrade International Pty Ltd 19 Hickson Road, Walsh Bay NSW 2000 Email: [email protected]

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.