POP is an organisation and an “APP Entity” for the purposes of the Privacy Act 1988 (Cth) (Privacy Act). POP may handle certain personal information of yours and is subject to the Australian Privacy Principles (APPs) contained in the Privacy Act in doing so. We are legally bound by the APP’s and are required to collect, protect, handle and disclose personal information in accordance with the standards set out in those APP’s.
What is your “Personal Information”?
Your Personal Information is information about you, or an opinion about you as an individual who is identified (or reasonably identifiable) from that information.
We handle Personal Information generally in accordance with this Policy. This Policy is not entirely exhaustive, so please feel free to contact us should you wish for more information.
What Personal Information do we collect?
The Personal Information we collect and hold about you includes, but is not limited to things like:
- your name;
- your date of birth;
- your address;
- your gender;
- your contact phone number and email; and
- your Tax File Number, bank account details and/or other financial or business information required for us to provide professional services to you.
We do not collect and store Personal Information that is not necessary for us to carry out our services.
We do not collect any sensitive information, such as your health data, political or religious views, sexual orientation or the like (Sensitive Information). If we do collect Sensitive Information, we obtain your clear and express permission to obtain it and tell you why we are asking for it, and then delete that Sensitive Information when we have finished using it for the specific purpose for which you provided it.
How do we collect your Personal Information?
- you volunteer it – you may provide us with your Personal Information voluntarily. For example, signing up for the POP App, or setting up an account with us as a user will require you to provide certain Personal Information. Some of our services will require you to do likewise, should you wish to use them.
If you use our enquiry forms, you will need to volunteer contact information so that we can get back to you. You voluntarily providing your information is the primary manner in which we collect Personal Information.
If you do not wish us to have your Personal Information, you are under no obligation to provide it in this manner;
- program integration – in using our services, you might authorise us to connect our services to those of a third-party (such as Xero, Facebook, etc.). If you authorise us to do this, you are authorising us to also access Personal Information that might have been collected by those third-party service providers and to use it in accordance with this Policy. You can always revoke those authorities.
Third-party services themselves are not covered by this Policy and you should make yourself aware of any terms that apply to those third-party services.
Please note that our website and App may have links to third-party websites and services. We are not responsible for the practices of those third parties and make no representations and warranties in relation to them – you should take time to familiarise yourself with the policies of any third parties when providing them with your Personal Information.
How do we use your Personal Information?
We use your Personal Information in order to run our business. Personal Information is required for us to do a number of things including:
- providing you with our professional services;
- responding to your inquiries and contacting you generally;
- allowing you to use our App and restricted areas of our website;
- to receive payment for our provision of services to you;
- to provide you with limited communications regarding products and services you might be interested in;
- to conduct business processing functions including providing Personal Information to our related bodies corporate, contractors, service providers or other third parties;
- conducting analytics, using de-identified information; and
- to meet our legal compliance requirements.
Should you not provide us with certain Personal Information, we may not be able to provide services to you or allow you to access our website and App.
We may also use your Personal Information to contact you for direct marketing and promotional services. You may request not to receive these communications by contacting us directly, or using the “opt-out” function which we provide. You are taken to have consented to receiving those communications if you do not opt-out or advise us otherwise. There are no consequences from withdrawing your consent to receiving these communications.
Third Party Collection
We may collect Personal Information from third parties including:
- services you authorise us to integrate with;
- commercial, consumer or other credit providers such as banks;
- financial authorities such as the Australian Taxation Office;
- law enforcement agencies and other government entities; and
- other third-party organisations that assist us in certain circumstances.
When do we disclose Personal Information, and who to?
We collect personal information so that we can provide you with services as agreed, and perform our business activities and functions to the highest standard.
Your personal information will not be shared, sold, rented or disclosed other than as described in this Policy. We will only disclose Personal Information to our employees, related bodies corporate, contractors, suppliers and advisers in relation to the provision of services to you or the operation of our business. Where we provide Personal Information to third parties, we will ensure that each of those third parties is aware of their obligations in handling your Personal Information.
We may also disclose Personal Information with your direct consent. We may also be required to disclose personal information for the purposes of law enforcement, other legal obligations or where there may be a legal or professional duty requiring the disclosure of personal information.
Some of the parties we disclose information to may be located outside of Australia. These may include our data hosting and other IT service providers.
How do we store and protect your Personal Information?
We take all reasonable steps to ensure your Personal Information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form.
We employ physical protection to the extent reasonably possible, as well as using technological safeguards, including industry-standard data encryption, passwords and anti-theft software.
Personal information is destroyed or de-identified when no longer needed. We ensure that our staff and relevant third parties are aware of their privacy and confidentiality obligations when they handle your Personal Information.
You should be aware that your Personal Information is transmitted through the internet. While we take all reasonable steps to safeguard your data, the internet is inherently insecure and we cannot provide any guarantee the security of any of your Personal Information communicated to us online and cannot guarantee that it will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information which you transmit to us online is transmitted at your own risk.
How can you access and correct your Personal Information?
You can always amend the Personal Information relating to your POP account through our website or the app.
You may contact us to request access to or correction of the Personal Information about you that we hold. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request and will not charge for making any corrections to your personal information. We may require you to take certain steps to verify your identity to our satisfaction in this case.
There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
We will take all reasonable steps to keep our records of your Personal Information up-to-date, complete and accurate.
Questions or complaints?
If you have any questions about this Policy or if you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below. Please provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint, to ensure we contact the right person and to resolve your complaint as quickly as possible. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint, what you can expect as an outcome and when. We will endeavour to respond within 48 hours of receiving any complaint. We aim to resolve all complaints within 10 Business Days, but this may take longer depending on the nature of the complaint.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
We take all complaints seriously. We will treat your requests or complaints confidentially.
If you are unsatisfied with our response to any complaint, you may refer your complaint to the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
Post: GPO Box 5218, Sydney NSW 2001
Tel: 1300 363 992
Changes to this Policy