Definition of personal information
Problems, Complaints or Queries
For individuals in Australia:
Mail: Privacy Officer
Level 3 201 Miller Street NORTH SYDNEY NSW 2060
Please allow 30 days for this request to be processed. On receipt of your query, problem or complaint a review will be conducted and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page, or, for individuals in the EU, to the data protection supervisory authority in your country.
On what basis do we process your data?
Lawful basis of processing
For individuals in the European Union, Tedirex may also rely on the lawful bases of contract and legitimate interest. That is, where you enter into a contract with us, Tedirex will process your personal information because it is necessary for the performance of that contract with you. In some circumstances, such as fraud prevention, Tedirex may also have a legitimate commercial interest in processing your personal information that is not outweighed by your interests, rights and freedoms. Tedirex may also request your explicit consent to process your personal data from time to time for various purposes.
Tedirex reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Tedirex, any member of the Tedirex group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety
When and how do we collect personal information?
We (or our subcontractors) collect and combine personal information in a number of ways through the following channels (each, a Collection Channel):
- through legitimate third party sources including personal information data providers and other personal information data owners or organisations that share personal information data in circumstances where it is lawful and/or consent has been obtained for such organisations to do so;
- our online properties (here and after, each a “Website”), including:
- our websites, including but not limited to www.tedirex.com
- any related Tedirex website, social media page, internal website, intranet and any Tedirex mobile or tablet applications,
- from our customers and service providers as a result of the provision of professional services to our customers; and
- any other means through which an individual provides personal information to Tedirex, including either physically or electronically, directly or indirectly.
Active Information Collection
Personal information may be collected and combined via our Collection Channels if you:
- contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
- provide your personal information to a third party and consent to that third party sharing your personal information with personal information data brokers (which would include Tedirex), or if it was otherwise lawful for such third party to share your personal information with personal information data providers brokers (which would include Tedirex);
- conspicuously publish or provide on request your personal information to Tedirex; or
- interact with a Website for a specific purpose or interact with or browse a Website generally.
Where we collect your information through legitimate third party sources including personal information data providers, social media organisations, and other organisations that share personal information data, we do so in circumstances where it is lawful and/or you have given permission for them to do so.
What kinds of personal information does Tedirex collect?
We may collect personal information including:
- your full name, contact details (such as your email address, phone numbers, address, contact preferences), location, and profession;
- information about your preferences, interests, opinions, feedback and experiences with our products or services or the products and services of our customers;
- social media account usernames and information published on your social media accounts;
- information regarding your personal and professional interests and your networks;
- information about your education and qualification, skills and experience;
- enquiry and complaint details;
- information about your experience with Tedirex’s products or services or third party products or services. This information is requested including in order to tailor our subsequent communications to you and continuously improve our products and services;
- the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Tedirex and used for the purposes set out in this policy (which may include using their details for marketing purposes);
- financial details, if you have provided them to us, such as your bank account, credit card, Paypal or other online payment system details (where you purchase any products or services from us);
- When you visit a Website, we may also collect personal information about you in the following general categories:
- device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
- other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a website.
- if you are an employee or prospective employee, information about your employment history and future plans, and documents relating to your employment;
- any other personal information requested or required by a Collection Channel.
Consequences of not providing personal information
No-one is obliged to provide personal information. However, failure to do so may result in Tedirex’s customers being unable to provide goods, services, information, upcoming opportunity, promotion, event or product information or other content, including where requested by you.
For what purposes does Tedirex collect, hold, use and disclose your personal information?
Personal information that Tedirex collects will be used for the following primary purposes:
- to provide services to personal information data providers with whom Tedirex has a contractual relationship, including providing Tedirex’s list brokerage services;
- to provide services to Tedirex’s customers, including providing Tedirex’s list brokerage services;
- to enable Tedirex’s customers to provide goods, services, information, upcoming opportunity, promotion, event, product information or other content to individuals whose personal information is collected.
- to maintain the functionality of a Website, including customising the Website based on your preferences; providing information to you relating to the content available on a Website; to improve the Website and system administration;
- where you are a customer of Tedirex, to carry out any purchases you make and otherwise manage our or our list providers’ commercial and trading relationship with you including identifying you in our system and contacting you, invoicing you correctly, sending you lists and to address your expectations of us in respect of how we conduct our business;
- where you are a customer of Tedirex, to ensure that your personal information remains up-to-date and complete;
- where you are a customer of Tedirex,to provide you with information about your accounts, transactions, content, services and products involving Tedirex or Tedirex’s personal information data providers;
- where you are a customer of Tedirex, to facilitate payments from you;
- where you are a customer of Tedirex, to contact you, including sending you any technical, administrative or legal notices relevant to Tedirex, our clients or a Website;
- where you are a customer of Tedirex, to otherwise maintain our relationship with you or the relationship between you and our customers, including providing after sales services and responding to enquiries;
Improving offerings to you and research
- to better understand and meet your needs and interests, to enable us to improve the nature of the goods and services we or our customers provide, to more accurately market our or our customers’ goods and services, and to research our or our customers clients;
- to obtain opinions or comments about products and/or services and to conduct other research and development;
- to record and analyse statistical and de-identified data for analysis including marketing analysis;
- to conduct market research including identifying likeminded individuals including through third party vendors such as Facebook or other social media websites;
- for any further purposes stated in a particular Collection Channel;
- to undertake recruitment for Tedirex (if applicable);
- any other purpose as may be deemed reasonably necessary by Tedirex in the circumstances;
- as needed to satisfy any law, regulation or legal request; to protect the rights or property of Tedirex, Tedirex’s customers, or any member of the public; to protect the integrity of Websites; to fulfill your requests; or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.
Contact by Tedirex
Tedirex group companies (and their directors, servants and agents), Tedirex’s promotional partners, Tedirex’s customers or trusted third parties (and other selected service providers and other non-Tedirex companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
Tedirex does not send advertising or marketing information without obtaining prior consent or in circumstances which are otherwise lawful. If you receive communications from Tedirex or its customers which you do not wish to receive, you may remove your name from the applicable database either by using the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting the relevant Privacy Officer. Please allow 30 days for this request to be processed.
Despite removing your name from the Tedirex database from receiving future advertising and marketing information, Tedirex may send you non-commercial “Administrative Emails”. Administrative Emails relate to your account with Tedirex or Tedirex’s customers or personal information data providers (if applicable) and may include administrative and transaction confirmations, requests and inquiries or information about a particular account. If you do not wish to receive such communications from Tedirex, you may remove your name from the database by contacting Tedirex’s Privacy Officer or as otherwise directed. Please allow 30 days for this request to be processed.
Tedirex does not make decisions that produce significant effects on you which are solely based on automated decision making.
How do we share your personal information?
Solely for the purposes described above, personal information may be shared with the entities below including their directors, servants and agents and related bodies corporate:
- our customers;
- our or our customers’ marketing and email sending partners;
- technical service providers, such as mail carriers, personal information data providers, hosting providers, IT companies and communications agencies; and
- other trusted service providers, promotional partners and third parties.
Technical service providers may be engaged by Tedirex to perform a variety of functions, such as legal and accounting services, data storage, support services, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our websites. These companies may have access to personal information if needed to perform such functions. Where you are a customer of Tedirex, your credit card details are only used to facilitate your purchases. They are not used for any other purpose and will never be supplied to a third party other than Tedirex or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary.
Some of the recipients of your personal information may be located overseas. Tedirex employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by Tedirex. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Tedirex will not be held responsible for events arising from unauthorised access to personal information except to the extent required by the relevant privacy laws.
The recipients of your personal information may be located in Australia or overseas, including but not limited to United States, United Kingdom, New Zealand, Europe, Hong Kong and China.
For individuals in the EU, please note that the recipients of your personal information may be located in countries in which the privacy or data protection laws differ from those of the European Union, and which are not the subject of an adequacy decision by the European Commission. For recipients of your personal information in Australia, appropriate or suitable safeguards over your personal data will be put in place, including through the standard data protection contract clauses approved by the European Commission. Please contact our Privacy Officer for more information.
How do we hold, and how long do we hold your personal information?
Tedirex takes appropriate security measures to keep personal information secure and to prevent unauthorised access, disclosure, modification, misuse, interference or loss of personal information. Tedirex, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by Tedirex.
Your privacy rights
You have a number of rights under the Australian Privacy Law and the GDPR. These include:
- (access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, Tedirex may determine that it is not legally required to give an individual access to personal information, in which case Tedirex will provide you with a written notice of its refusal to provide access;
- (correction) to request that we correct your personal information;
- (withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message; and
- (complaint) to complain about a breach of the Australian Privacy Principles.
If you are an individual in the EU, you have additional rights under the GDPR that you can exercise against the “controller” of your data. Where we are the controller of your data, your rights include:
- (access) to request that we transfer your personal information to another service provider of your choosing;
- (erasure) to request that we erase your personal data. All reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain services (including the uploading, access to, and receipt of content on a website or the Tedirex Application, and purchase transactions undertaken on a website);
- (objection and restriction) in some circumstances, to object to the use of your personal data by us and request that we restrict our use of your personal information; and
- (complaint) to lodge a complaint in relation to our processing of your personal data with a data protection supervisory authority under the GDPR.
Anonymity and Pseudonymity
Where practicable, Tedirex will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our collection channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the personal information identified above. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.
Sale of the company
Personal information will not be collected from any person who is known by Tedirex to be under the age of sixteen (16) without the consent of a parent or legal guardian or as has been provided to us lawfully by third parties, including our customers. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian.
Passive Information Collection
As with many commercial websites (and mobile and tablet applications), Tedirex and Tedirex’s customers may also collect information which tells us about visitors to our websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.
Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to website visitors and users, customise a website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party Website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.
Tedirex and other websites
Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Tedirex is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Tedirex or any of its affiliates. Tedirex is not responsible for the content (including representations) of any third party advertisement on a website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.
21 May 2019