Modifications last made: 21 August 2012
In this Policy:
- ‘Personal Information’ is information or opinion about an individual whose identity is apparent or can be reasonably ascertained from the information. ‘
- Related Bodies Corporate has the meaning given to that term under the Corporations Act 2001 (Cth).
- SingTel Group Member’ means an entity which is, having regard to the relevant laws of the jurisdiction in which the entity was created and/or operates, a ‘related body corporate’ or a ‘subsidiary’ or an ‘associated entity’ of Singapore Telecommunications Limited ARBN 096 701 567, or of substantially similar relationship to SingTel as the relationships that are described by each of those terms under the Corporations Act 2001 (Cth).
This Policy has been drafted having regard to Optus’ obligations under the Privacy Act 1988 (Cth) (including the National Privacy Principles) (‘Privacy Act’).
1.1 Optus will only collect Personal Information where the information is necessary for Optus to perform one or more of its functions or activities in relation to the Website or the Program..
1.2 Optus collects and uses Personal Information primarily to provide You with information about the Website and the Program, or to incorporate your information into the SeedBase section of the Website (‘SeedBase’), in circumstances where you have used the “Contact” function on the Website or supplied Personal Information for incorporation into the SeedBase.
1.3 Optus may also collect and use Personal Information for secondary purposes, including:
(i) to analyse and understand your experience on the Website;
(ii) to customise the Website to suit your preferences and behaviour;
(iii) to improve the quality of the Website;
(iv) for business planning and product development; and
(v) to provide You with information about promotions or events.
1.4 Optus will not collect Sensitive Information about You except with your consent and only where it is necessary for Optus to collect such information for an activity or function. In this Policy, ‘Sensitive Information‘ is Personal Information relating to racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health information about an individual or genetic information.
1.5 Optus will not collect Personal Information secretly or in an underhanded way.
1.6 The Website uses Google Analytics which collects information about Your activities on the Website via cookies and uses this information to anonymously track and report on how You use the Website. Our use of Google Analytics is governed by the Google Analytics Terms of Service at http://www.google.com/analytics/tos.html. You may use your browser to disable Cookies but this may impact your ability to use the Website.
2.1 Optus uses Personal Information primarily for the purpose described in 1.2 above.
2.2 Optus will obtain your consent for use of Personal Information that is not Sensitive Information for Secondary Purposes at the time of collection, unless the use is a related Secondary Purpose which would be within your reasonable expectations.
2.3 Optus may use your Personal Information to send You direct marketing materials. When sending You direct marketing materials, Optus will ensure that:
i) You are clearly notified of your right to opt out from receiving further direct marketing materials;
ii) You are given the choice to opt out of receiving any further direct marketing materials if You have not previously chosen to opt out; and
iii) if You opt out of all direct marketing the opt out will be respected by Optus and all its Related Bodies Corporate.
2.4 Optus will not use Sensitive Information for direct marketing.
2.5 Optus may use or disclose Personal Information in order to avoid an imminent threat to a person’s life or to public safety. Optus may also use or disclose Personal Information in order to assist law enforcement or conduct internal investigations into actual or suspected unlawful activities.
2.6 Optus will take reasonable steps to ensure that all Personal Information held is accurate, complete and up to date.
2.7 Optus will not attempt to match de-identified or anonymous data collected through surveys or cookies, with Personal Information, without Your consent. Cookies may reside on places that include Your computer, in the Website or in emails that Optus sends You.
3.1 Optus may disclose Personal Information between Related Bodies Corporate and to Singtel Group Members. Where information is disclosed according to this clause, the Related Body Corporate or Singtel Group Member is bound by the original purpose for which the information was collected.
3.2 If You have applied for and supplied Personal Information for incorporation into the SeedBase, Optus may disclose that Personal Information to an unrelated third party by displaying it in the SeedBase.
3.3 Optus may also disclose Personal Information to an unrelated third party if You consent to the disclosure.
3.4 Optus may disclose Personal Information to unrelated third parties to enable outsourcing of functions, where that disclosure or use is for a secondary purpose described about in clause 1.3 and has been notified to You or where such Disclosure can be regarded as likely to fall within your reasonable expectations.
3.5 Optus may disclose Personal Information to external advisers, partners, affiliates, or other contributors to the Program, subject to a confidentiality undertaking and where reasonably required for the conduct of the Website, the SeedBase or the Program.
3.5 Optus may disclose Personal Information to law enforcement agencies, government agencies and/or courts where required by law.
3.6 Optus may disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.7 If a disclosure is not for a primary purpose or secondary purpose described in clause 1.2 or 1.3, or your consent has not been obtained, Optus will not disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 Optus does not generally sell or share lists containing Personal Information on a commercial basis with third parties. However, we may do so with Your consent. If Your consent is conditional, Optus will take steps to ensure (by contract) that such use does not exceed the scope of the consent.
4. Information quality
4.1 Optus will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Optus will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise when that Personal Information is no longer required for the Primary or Related Secondary purpose.
5. Information security
5.1 Optus requires employees and contractors to perform their duties in a manner that is consistent with Optus legal responsibilities in relation to privacy.
5.2 Optus will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Optus who “need to know” or have a “right to know”.
5.3 Optus will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Your access and correction
6.1 Optus will allow its records containing Your Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Optus will correct its records containing Your Personal Information as soon as practically possible, at the request of the individual concerned, in accordance with the Privacy Act.
6.3 If You wish to lodge a request to access and/or correct your Personal Information, You should do so by contacting us using the details at the end of this policy.
6.4 Optus will not normally charge a fee for processing an access request unless the request is complex or is resource intensive. Optus does, however, reserve the right to charge a $25.00 administration fee if You request access to Your Personal Information more than once in a three month period.
7.1 The Program manager will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting us using the details at the end of this Policy.
8.1 Optus will not make it mandatory for visitors to the Website to provide Personal Information unless such Personal Information is required to answer an inquiry or communication from You or unless You elect to contribute Your Personal Information to SeedBase. Optus may however request visitors to provide Personal Information voluntarily to Optus (for example, as part of a competition or questionnaire).
9. Transferring personal information overseas
10. Contacting Optus
If You require further information regarding this Policy, You should contact us as follows:
Preferred point of contact:
Secondary points of contact:
The Program Manager, Optus-Innov8 Seed Program
Telephone: (02) 80825513
Address: PO Box 306, Salisbury South SA 5106
Optus Customer Service:
Telephone: 1800 780 219
TTY: 1800 500 002
TTY (mobile): 1800 123 124
Address: PO Box 306, Salisbury South SA 5106