General
Informed Sources is committed to protecting the privacy of
personal information and manages personal information in an open
and transparent way.
Informed Sources recognises that your privacy is very important
to you and that you have a right to control your personal
information. We know that providing personal information is an act
of trust and we take that seriously. At Informed Sources, our
policy is to respect and protect the privacy of our users, clients
and employees.
You can be assured that Informed Sources will never disclose
individually identifiable information to any third-party for any
purposes. This means that your email address, your name and other
personal details that you provide will not be given or sold to any
other company for any reason.
The only exceptions to this will be:
(a) if we are required by law to make the
disclosure
(b) we believe it is necessary to provide you
with a service that you may have requested
(c) to protect our rights or the rights of
another Informed Sources user; or
(d) to lessen a serious threat to a person's
health and safety.
This Privacy Policy is effective from 25 May 2018. From time to
time, our policies and procedures will be reviewed and, if
appropriate, updated. If any changes are made to this policy these
will be posted on our websites. In some cases, we will also
email users notifying them of the changes in our privacy
practices.
Purpose of Policy
The purpose of this policy is to set out clearly the practices,
procedures and systems relating to Informed Sources' functions and
activities that:
(a) will ensure that Informed Sources
complies with the various Privacy Laws that apply in the Countries
where Informed Sources carries on
business including:
(i) Australian
Privacy Principles (APP) as set out in thePrivacy Act 1988
(Cth);
(ii) General Data Protection
Regulation (GDPR) (European Union) Effective 25 May
2018;
(iii) Personal Data Protection Act 2010
(Malaysia);
(iv) The Privacy
Act 1993 (New Zealand); and
(b) will enable Informed Sources to deal
with inquiries or complaints from individuals about Informed
Sources compliance with the Privacy Laws.
Informed Sources is bound by the requirements of the Privacy
Laws, which regulates how Informed Sources may collect, use,
disclose and store personal information. These laws also specify
how individuals may access and correct personal information held
about them.
Contents of Privacy Policy
This Privacy Policy will set out the policies for the management
of personal information within Informed Sources including:
(a) the kinds of personal information that
will be collected and held;
(b) how Informed Sources collects and holds
the personal information;
(c) the purposes for which Informed Sources
collects, holds and uses and discloses personal information;
(d) how an individual may access personal
information about the individual that is held by Informed Sources
and seek the correction of such
information;
(e) how an individual may complain about a
breach of the Privacy Laws that binds Informed Sources, and how
that complaint will be dealt with;
(f) whether Informed Sources is likely
to disclose personal information to overseas recipients;
(g) if Informed Sources is likely to disclose
personal information to overseas recipients - the countries in
which such recipients are likely to be
located if it is practicable to specify
those countries in this policy.
Availability of Privacy Policy
Informed Sources will take all reasonable steps to ensure that
this Privacy Policy is available free of charge electronically to
such persons who may be entitled to a copy of this Privacy
Policy.
If a person requests a copy of the Privacy Policy in any other
particular form, Informed Sources will take such steps as are
reasonable in the circumstances to give the person or body a copy
in that form.
Definitions
Set out below are some of the definitions contained in the
Australian Privacy Act 1988. For further information please
refer to the Australian Privacy Act 1988. The terms below are
defined differently in the various Privacy Laws set out
above. For further information or clarification, you should
refer to the specific Privacy Law.
Individual means a natural person.
Personal Information means
information or an opinion about an individual, or an individual who
is reasonably identifiable:
(a) Whether the information or opinion is
true or not; and
(b) Whether the information or opinion is
recorded in a material form or not.
For
example: the types of information that would be personal
information includes your name, contact details including your
address, age and health information.
Record for the purposes of
this Privacy Policy includes:
(a) A document; or
(b) An electronic or other device:
But does not include:
(a) a generally available publication;
or
(b) letters of other articles in the course of
transmission by post.
Informed Sources means:
Informed Sources
(International) Pty Ltd
ACN 010 828 967 |
Informed Sources
(New Zealand) Ltd
586550 |
Informed Sources
(Deutschland) GmbH
HRB 53436 |
Informed Sources
(Suomi) Oy
2457698-7 |
Informed Sources
(Australia) Pty Ltd
ACN 003 714 332 |
Informed Sources
(Malaysia) Sdn Bhd
600397 D |
Informed Sources
(Norway) AS
989 523 597 |
Informed Sources
(Sverige) AB
556837-8813 |
Informed Sources
(Consulting) Pty Ltd
ACN 006 840 151 |
Informed Sources
(Europe) Ltd
SC384641 |
Informed Sources
(Polska) Sp. z o.o.
KRS 0000 413 044 |
1nf0rmed Sources
(UK) Ltd
SC574266 |
MotorMouth Pty Ltd
ACN 095 755 052 |
and any other company that is a subsidiary of Informed Sources
(International) Pty Ltd or Informed Sources (Europe) Ltd from time
to time.
Sensitive Information includes:
(a) information or an opinion about an
individual's:
(i) racial or ethnic origin;
or
(ii)
political opinions; or
(iii)
membership of a political association; or
(iv) religious
beliefs or affiliations; or
(v)
philosophical beliefs; or
(vi)
membership of a professional or trade association; or
(vii) membership of
a trade union; or
(viii) sexual orientation
or practices; or
(ix) criminal
record;
that is also personal
information; or
(b) health information
about an individual; or
(c) genetic information
about an individual that is not otherwise health information;
or
(d) biometric
information that is to be used for the purpose of automated
biometric verification or biometric identification; or
(e) biometric
templates.
What kind of personal information does Informed Sources collect
and hold?
Any personal information that you provide via our websites, the
MotorMouth App or directly is collected and managed by Informed
Sources.
If you provide your personal information to a third party via a
link from an Informed Sources website, that information is
collected and managed by those third parties. You should
familiarise yourself with their privacy policy prior to deciding
whether you wish to provide them with your information.
The types of personal information Informed Sources may collect
includes your:
- name;
- date of birth;
- gender;
- marital status and family details;
- residential, business and postal address;
- email address;
- contact telephone numbers;
- identification details;
- testimonials or opinions;
- photos of you, your vehicle including registration plates;
- financial information, such as bank account details;
- written or verbal contact with Informed Sources, including
voice recordings of telephone conversations you have had with our
employees; and
- activities, including but not limited to lifestyle and other
interests.
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.
Website users
When you visit an Informed Sources website, our servers
automatically record information about your visit. The information
that we collect is:
- your IP address;
- your cookie ID (if enabled)
- the date and time of your visit to our site;
- the date and time you left our site;
- the pages you accessed and documents downloaded.
- the type of browser you are using the type of operating system
you are using
This information is aggregated and is used in ascertaining usage
patterns on our site. We do this to help us better understand
what aspects of our services our users find the most useful and how
to develop services for you in the future. For sites that include
advertising, this information also helps to ensure any advertising
is more relevant to your interests.
For visitors that wish to make contact with us we also provide
the email facility to do so and request you enter your name,
company, email address and phone number. While these fields require
content you are able to remain anonymous or use a pseudonym,
however this may significantly impact our ability to respond to
your query.
By visiting our websites and/or providing your personal
information or data to us, you consent to the terms and conditions
in this Privacy Policy, unless you tell us to the contrary by
contacting us.
Software application users
For those who have access to our software applications and
business solutions, additional types of personal information we
collect include name, contact details such as email address, title,
company/employer, and details of your communications and
interactions with us.
This data is collected to verify your access and/or level of
access within our software applications and improve our service
offers. Once you have logged onto our server, we keep a record of
how you use our services. This helps us to build a profile of your
movements, allowing us to tailor our services to you.
MotorMouth App users: Registered (Motormouth
Members)
Once you have become a MotorMouth Member, we collect personal
information about you in order to provide you with the full
benefits of Membership. When you first register for
Membership, we collect information from you directly and also from
time to time thereafter if you provide us additional information.
The mandatory information we collect includes:
- Name (or pseudonym);
- Mobile Number;
- Email details are optional, but are required to subscribe to
periodic publications and enter some competitions.
When you register to become a MotorMouth Member or modify your
existing MotorMouth profile the pages are encrypted using a digital
certificate and a SSL (Secure Socket Layer) session.
MotorMouth App users: Unregistered (Non
Members)
If you are not a registered MotorMouth App user, the information
we collect about you remains anonymous, and we do not link it to
any other personal information.
Employment Applicants (via the website)
These applications are generated in the form of an email that is
dispatched to the most relevant contact/s within the Informed
Sources Group. All personal information contained within this
document will be used in the assessment and progression towards
employment within Informed Sources. All unsuccessful
applications will be kept on file (for future employment openings)
unless otherwise requested. Applicants should contact the
closest Informed Sources office for more information regarding the
privacy of their personal information.
Suppliers
We collect information from our suppliers to facilitate sourcing
and purchasing products and services. This information can be
collected directly from suppliers and related service
providers.
Registration for Surveys & Contests
From time-to-time we may request information from users via
surveys or contests. Participation in these surveys or
contests is completely voluntary and the user therefore has a
choice whether or not to disclose this information.
Information requested may include contact information (such
as name and shipping address), and demographic information (such as
postcode, date of birth). Contact information will be used
and shared with the contest sponsors to notify the winners and
award prizes. Survey information will be used for purposes of
monitoring or improving the use and satisfaction of our
services.
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.
What cookies/tracking technologies do we use?
Cookies and local storage
A cookie is a small text file that's stored on your hard drive
or mobile device when you visit one of our websites. We, and
our third-party service providers may use both persistent cookies
and session ID cookies.
We use persistent cookies for the following purposes:
- to enhance and personalise your experience across our websites
and applications
- provide us with aggregated information/analytics on how people
use our services, and
- help determine the effectiveness of advertisements and
campaigns.
Users can control the use of cookies at the individual browser
level.
Clear Gifs (Web Beacons)
We also employ a software technology called clear gifs (a.k.a.
Web Beacons/Web Bugs) in our HTML based emails. These are
tiny graphics files that contain a unique identifier that lets us
know which emails have been opened by recipients. This allows
us to understand how well customers accept certain communications
and the effectiveness of our marketing campaigns. We now also
use SendGrid to manage some marketing campaigns and service
notifications.
How does Informed Sources collect and hold your personal
information?
Informed Sources will only collect personal information about
you by lawful and fair means, and not in an unreasonably intrusive
manner.
It is Informed Sources' usual practice to collect personal
information directly from you when you:
- visit or use an Informed Sources website;
- complete an online form;
- complete a hard copy form;
- complete and return to us a hard copy form that is provided
with one of our services;
- speak with us, or one of our representatives directly; or
- contact us directly by telephone, via mail, e-mail or
online.
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 Informed Sources may need to collect
personal information from you to provide you with a service.
In some cases, if you do not provide the required personal
information we will not be able to provide you with a service.
As mentioned above your personal information may be collected
automatically by our software and server systems and/or directly
from your interactions/communications with us. It can
however, also be supplied to Informed Sources by your employer to
provide you with authorised access to our software applications in
order for you to perform your work.
In addition, we collect personal information from employees.
All of your personal information is kept in a secure environment
and will be kept by us for no longer than is necessary taking into
account the purpose for which the data was collected.
Informed Sources may store data for longer periods if the personal
data will be processed solely for research purposes.
The retention period for each category of personal data will be
set out in Informed Sources' Retention Schedule. Any personal
data will be disposed of securely when it is no longer required by
Informed Sources.
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).
Data quality 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.
In addition, our employees, contractors and third parties who
provide services related to our services are bound to respect the
privacy of any personal information held by Informed Sources.
Only employees who need the information to perform a specific
job are granted access to personally identifiable information.
Our employees must use passwords, access codes and security
cards to access your information. Furthermore, all employees
are kept up-to-date on our security and privacy practices through
emails, company newsletters and staff meetings. Any time new
policies are added our employees are notified and/or reminded about
the importance we place on privacy, and what they can do to ensure
our customers', suppliers', employees' and visitors' information is
protected.
You play an important role in keeping your personal information
secure, by maintaining the confidentiality of any password and
accounts used on an Informed Sources website. Please ensure
that your password is a strong password that is changed
regularly.
The purposes for which Informed Sources collects, holds, uses
and discloses personal information
We use your personal information for a variety of reasons
including to:
- provide services to you;
- answer your inquiries and deliver customer service to you;
- enable us to undertake a credit assessment;
- maintain and improve customer services;
- meet our legal obligations;
- consider making offers for employment purposes;
- manage and resolve any legal, consumer or commercial complaints
and issues;
- carry out internal functions including training; and
- conduct marketing research and analysis.
In the course of conducting our business and providing our
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 those purposes. 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, businesses 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 Informed Sources business or entity;
- professional advisers (such as lawyers or auditors);
- payment systems operators and financial institutions;
- 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. We will
only use or disclose your personal information for direct marketing
purposes if you have provided your information for that purpose
(and you would expect us to use the information for that purpose),
or if you have provided consent for your information to be used in
this way.
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,
SMS/text message or social media message.
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.
Informed Sources will only ever contact you if you have
consented to this, and you can ask to be removed from our marketing
lists at anytime by contacting us directly.
How to Opt-Out
If you no longer wish to receive our
email newsletters and special offers from our partners, you can
click on the 'unsubscribe' link at the bottom of the email to
opt-out of receiving future emails. We will process your request
within a reasonable time after receipt.
You will continue to receive
transaction-related emails regarding products or services you have
requested/access and administrative communications, such as updates
to Terms or this Privacy Policy.
- Mobile App Push Notifications and Location Data
Our MotorMouth App may occasionally
send you push notifications. You may, at any time opt-out
from receiving these types of messages by changing the settings on
your mobile device. Due to the nature of the application our
MotorMouth App requires location services to be 'on'.
Employees
Informed Sources collects personal information (which may
include sensitive information) from its employees (past, current
and future) in order to provide a range of employment related
services.
Informed Sources collects personal information directly from job
applicants (and their referees) or from recruitment agencies and
related service providers. The information we collect may
include your name, address contact details, employment and
education history, the names of your referees and other relevant
information.
This information we collect about you will be used for
recruitment purposes and may be disclosed to third party service
providers who provide recruitment related services to us.
How an individual may access personal information about the
individual that is held by Informed
Sources and seek the correction of such 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 via email to privacy@informedsources.com
or mail to The Privacy Officer, Informed Sources, 16 Benson Street,
Toowong, Qld 4066, and we will correct this information.
How an individual may complain about a breach of the Privacy
Laws that binds Informed Sources,
and how that complaint will be dealt with
If you:
(a) have queries, concerns or complaints
about the manner in which your personal information has been
collected or handled by Informed Sources; or
(b) would like to request access to or
correction of the personal information we hold about you;
please write to:
The Privacy Officer
Informed Sources
16 Benson Street
Toowong Qld 4066
Email: privacy@informedsources.com
For European Union data protection purposes, Informed Sources
(Europe) Ltd (company number SC384641) is our representative in the
European Union.
The Privacy Officer
Informed Sources (Europe) Ltd
Glen Orchy, 15 Glenorchy Road
North Berwick, EH39 49E Scotland
Email: privacy@informedsources.com
If you consider your privacy concerns have not been resolved
satisfactorily by us, or you wish to obtain more information on
privacy requirements in Australia, you can contact the Office of
the Australian Information Commissioner on 1300 363 992 or visit
their website at www.oaic.gov.au.
If your concerns are in regard to countries outside Australia
then:
Is Informed Sources likely to disclose your personal
information to overseas recipients?
Your personal information may be disclosed to other Informed
Sources entities, business partners and service providers in
Australia and overseas.
The countries this information may be disclosed to will vary
from time to time, but may include Australia, New Zealand,
Malaysia, Singapore, United Kingdom, countries in the European
Union and countries in the European Economic Area.
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 Informed Sources'
behalf).
If Informed Sources is likely to disclose personal information
to overseas recipients - the countries
in which such recipients are likely to be located if it is
practicable to specify those countries in this
policy.
As stated above, the countries this information may be disclosed
to will vary from time to time, but may include Australia, New
Zealand, Malaysia, Singapore, United Kingdom, and countries in the
European Union and countries in the European Economic Area.
Government related identifiers
Informed Sources will not adopt a government related identifier
(such as a driver's licence number) as its own identifier of an
individual.