1. Your rights in relation to privacy
Thinxtra Ltd (Thinxtra) recognizes and respects the importance of protecting the privacy of an individual’s personal information. This statement sets out how Thinxtra aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Thinxtra and the way Thinxtra collects, holds, uses and discloses your personal information.
In handling your personal information, Thinxtra will comply with the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and where relevant, the Credit Reporting Code. This policy statement may be updated from time to time.
2. What kinds of personal information does Thinxtra collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of Thinxtra’s products and services, Thinxtra may collect your personal information.
Generally, the kinds of personal information Thinxtra collects are:
· contact and identification information such as your name, company name, business street and postal address, business telephone and facsimile number, business email address or other personal contact details;
· professional information including your job responsibilities;
· consumer credit information (provided the collection is expressly consented to and for a purpose related to an application for commercial credit), being credit-related personal information lawfully created and accessible within the Australian credit reporting system including:
· identification information;
· consumer credit liability information including information about credit accounts and credit limits;
· repayment history information;
· information about credit defaults;
· credit eligibility information, which is information about you that Thinxtra obtains from a credit reporting body such as VEDA Advantage or Dunn & Bradstreet together with information Thinxtra derives from such information based on its own analysis; and
· any other information lawfully obtainable within the Australian credit reporting system.
If your personal information is collected using a collection notice that references this Privacy Statement, you are taken to consent to the disclosure of your personal information to overseas recipients as detailed above. You also acknowledge and understand that by providing such consent that Thinxtra will not be required to take such steps as are reasonable in the circumstances to ensure such overseas recipients comply with the Australian Privacy Principles.
In connection with your personal information, Thinxtra may also collect information about your payment and shipping preferences for purchases and any special interests in products or industries.
In some circumstances Thinxtra may also hold other personal information provided by you.
3. How does Thinxtra collect personal information?
Generally, Thinxtra collects your personal information directly from you, through:
· registering with Thinxtra on its website;
· completing order entry purchases;
· completion of online or hard-copy application forms including but not limited to
o credit and insurance application forms with Thinxtra;
o job application forms;
o accessing the Sigfox business support systems
· other exchanges with Thinxtra, including any of Thinxtra’s affiliates, including Sigfox, through face-to-face meetings or via email, telephone or facsimile.
There may be occasions when Thinxtra collects your personal information from other sources such as from an information services provider, credit reporting agency or a publicly maintained record. Generally, Thinxtra will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4. Why does Thinxtra need your personal information?
Thinxtra collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
· telecommunications network operation
· telecommunications products services
· providing services in relation to the financing and resale connectivity;
· evaluating applications for, and providing, commercial credit in relation to Thinxtra’s business;
· internal research on Thinxtra’s website users’ demographics, interests and behaviours to better understand and serve Thinxtra’s customers;
· accounting, billing and other internal administrative purposes;
· identifying and informing you of products and services that may be of interest to you from Thinxtra or selected third parties; and
· any other legal requirements.
Where personal information is used or disclosed, Thinxtra takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Thinxtra. However, without certain information from you, Thinxtra may not be able to provide its products and/or services to you.
5. To whom does Thinxtra disclose your personal information?
Thinxtra discloses your personal information for the purpose for which Thinxtra collects it. That is, generally, Thinxtra will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to SIGFOX and its subsidiaries, affiliates and related parties, Thinxtra’s subcontractors and third parties engaged to perform administrative or other services for the purposes of:
· processing customer orders and delivering and supplying products and services;
· data processing and market research services;
· marketing Thinxtra’s products and services;
· regulatory and compliance purposes;
· updating of credit information to credit reporting agencies;
· resale and valuation services; or
· underwriting, assessing and administering insurance risk and claims.
This disclosure is always on a confidential basis. Thinxtra may also disclose your personal information with your consent or if disclosure is required or authorized by law.
6. Overseas disclosures
Thinxtra may disclose personal information to overseas recipients in order to provide its services and products and for administrative or other business management purposes. Recipients of such disclosures are located in e.g. Singapore and France.
Before disclosing any personal information to an overseas recipient, Thinxtra takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles, or the overseas recipient is bound by a substantially similar privacy scheme and there are mechanisms that you can access to take action to enforce that scheme, unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
7. Direct marketing
Thinxtra may use and disclose your personal information in order to inform you of products and services of Thinxtra that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting Thinxtra via the contact details set out in paragraph 12 or through any opt-out mechanism contained in a marketing communication to you.
8. Security of your personal information
Thinxtra takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorized access, modification or disclosure. Thinxtra holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorized staff.
Thinxtra uses Secure Sockets Layer (SSL) encryption, when collecting or transferring certain personal information such as financial information, which is designed to make the information unreadable by anyone other than Thinxtra. SSL encryption functionality is evidenced by either the symbol of an unbroken key or closed lock (depending on your browser) being visible at the bottom of your browser window.
Thinxtra will destroy or de-identify personal information in circumstances where it is no longer required, unless Thinxtra is otherwise required or authorized by law to retain the information.
9. Can you access and correct the personal information that Thinxtra holds about you?
Thinxtra takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by Thinxtra. If at any time you would like to access or correct the personal information that Thinxtra holds about you, or you would like more information on Thinxtra’s approach to privacy, please contact Thinxtra via the contact details set out in paragraph 12 below. Thinxtra will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
· you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individual and that the privacy of others is protected;
· Thinxtra requests that you be reasonably specific about the information you require; and
· Thinxtra may charge you a reasonable administration fee, which reflects the cost to Thinxtra, for providing access in accordance with your request.
If Thinxtra refuses your request to access or correct your personal information, Thinxtra will provide you with written reasons for the refusal and details of complaint mechanisms available to you. Thinxtra will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of Thinxtra.
Thinxtra will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
10. Online information – what kinds of non-personal information does Thinxtra collect and why?
How does Thinxtra collect information?
Thinxtra automatically receives some non-personal information when you visit Thinxtra’s website including:
· the name of the domain from which you access the Internet;
· the Internet protocol (IP) address of the computer you are using;
· the browser software you use and your operating system;
· the date and time you access Thinxtra’s website;
· the geographic location from which you access Thinxtra’s website; and
· the Internet address of the website from which you linked directly to Thinxtra’s website.
Thinxtra uses this information to monitor the usage of its website. All of the information Thinxtra automatically captures provides Thinxtra with the ability to enhance its customers’ search and shopping experiences and to determine aggregate information about its user base and usage patterns.
11. Does Thinxtra use electronic mechanisms such as “cookies”?
Thinxtra also capture metrics on the number of visitors to its sites for use in server capacity needs.
12. How to contact Thinxtra
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional communications, please contact Thinxtra’s Privacy Compliance Officer at:
Privacy Compliance Officer
13. Privacy complaints
Please direct all privacy complaints to Thinxtra’s Privacy Compliance Officer. At all times, privacy complaints:
· will be treated seriously;
· will be dealt with promptly;
· will be dealt with in a confidential manner; and
· will not affect your existing obligations to Thinxtra or affect the commercial arrangements between you and Thinxtra.
Thinxtra’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Federal Office of the Australian Information Commissioner.