Purpose

Executive Distributors Pty Ltd (ACN 669 084 824), trading as Whereabout Supply, will be referred to as Executive Distributors throughout this policy.

The purpose of this privacy policy is, firstly, to communicate the personal information handling practices of Executive Distributors. Secondly, the purpose of this privacy policy is to provide to all customers, suppliers and those who deal with us a better and more complete understanding of the type of personal information Executive Distributors hold and how that information is handled by our staff.

Privacy Act Obligations

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au

What is Personal Information?

In this policy “personal information” is used to mean information or an opinion that identifies an individual. Examples of Personal Information we collect include:

• names
• addresses
• email addresses
• phone numbers
• fax numbers
• business details, including Australian Business Number (ABN)
• credit references and other information relevant to credit worthiness, including information about a customer’s credit liabilities
• other transactional information.

We may also collect information from online users including your server address, your top-level domain name, the date and time of your visit to the site, the pages you accessed, the previous site you have visited, the type of browser you use and a record of your last login.

We also collect any other information necessary or reasonably required to provide the specific products and services our customers require.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

•            For the primary purpose for which it was obtained
•            For a secondary purpose that is directly related to the primary purpose
•            With your consent; or where required or authorised by law.

We do not collect any sensitive personal information such as sexual preferences or practices, criminal records, health status, race, culture, religion, philosophical beliefs, political opinions or any other information which is not relevant to the conduct of our business and our relation with our customers.

How do we collect personal information?

Personal Information is obtained in many ways including by email, phone, eCommerce account creation, form submissions and from third parties.

We collect personal information about our customers from external sources such as credit or trade references, credit reporting agencies, guarantors/ proposed guarantors, referees and our service providers involved in helping us to provide credit or to administer credit facilities, including our debt collectors, credit insurer, insurance broker and legal advisers.

Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimisation, fraud/security purposes, and advertising.

Executive Distributors also records user’s email addresses if a user sends us an email message. So, it or its hosting partners, can provide any support required.

Email messages may be monitored by technology services staff for system trouble-shooting and maintenance purposes. Executive Distributors may use a third-party providers for technology services staff. This information is used by those providers only on behalf of and under the instructions of Executive Distributors.

 

Links to other sites

Our website contain links to other sites. Executive Distributors is not responsible for the content and the privacy practices of other websites and encourages users to examine each site's privacy policy and make their own decisions regarding the accuracy, reliability, and correctness of material and information found.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. The types of people and entities we disclose personal information about you to include, but is not limited, to:

• Credit reporting agencies
• Our tax accountant, insurers, legal advisors and other professional advisors
• Debt collection agents
• Guarantors and proposed guarantors
• Courts, tribunals and regulators
• Anyone else whom the customer authorises us to disclose this information
• As otherwise authorised by legislation.

How do we use your personal information?

We collect, use, hold and disclose your Personal Information:  includes, but is not limited to:

• provide products and services to our customers
• communicate with our customers and contacts
• improve our products and services and your experience with us
• comply with our legal obligations
• inform you about products or services we think may be of interest to you
• manage our employees and contractors
• manage and deliver our loyalty program or schemes
• exercise our legal rights and to issue or defend legal proceedings
• assess our customers for creditworthiness or continuing creditworthiness as we reasonably see fit from time to time, for the purposes including but not limited to:
  • obtaining and exchanging information with a credit reporting agency, credit provider, credit insurer or insurance broker;
  • passing the information on to a debt collector or solicitor;
  • exchanging further personal information, including consumer and/or commercial credit information, with another body for any use reasonably connected with the provision of credit or the collection of debts.

You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

How we deal with personal information we didn't ask for?

Sometimes we receive information we didn't directly seek out. Where we receive this unsolicited personal information about individuals, we will consider whether the information is reasonably necessary for our functions and if we are permitted to hold the information in the same way as other information the individual has directly provided to us. If we can, we will handle the information in the same way we do with other information we seek from the individual. If not, the information will be destroyed or de-identified.

Sending information overseas

Depending on our commercial arrangements, we may disclose personal information about you to business partners with operations overseas or who store personal information overseas (e.g. providers of customer credit insurance).

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and
•          Where required or authorised by law.

We may disclose information regarding the provision of credit, the amount of credit provided, the terms and conditions of credit, when the credit account was opened and closed and information about repayments and defaults.

Anonymity and pseudonyms

Customers have the right to remain anonymous or to use a pseudonym when dealing with us in respect of a particular matter. However, this only applies where it is practicable for us to deal with customers anonymously or under a pseudonym, such as a general enquiry.

Non-disclosure of personal information

If we request personal information and it is not provided, we may not be able to:

• provide products or services or otherwise assist the relevant customer;
• manage or administer our customer's account;
• verify the customer's identity or protect against fraud;
• provide benefits to customers through our loyalty schemes or programs;
• inform about product or services that might better meet our customer's needs.

Integrity of personal information

We take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete and that the personal information we use or disclose is, having regard to the purpose of such use or disclosure, accurate, up to date, complete and relevant.

To that end, we encourage our customers to contact us to update or correct any personal information we hold about them as soon as practical.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Executive Distributors will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Denying access to personal information

We are not always required to provide our customers with access to their personal information upon request. We may refuse access to personal information where the information relates to existing or anticipated legal proceedings, where denying access is required or authorised by law, or where the request for access is regarded as frivolous or vexatious. If we deny a request for access to, or refuse a request to correct personal information we will provide the reasons for not doing so.

Data security

Executive Distributors takes all reasonable steps to protect the personal information it holds against loss, unauthorised access, modification or disclosure. These steps include the storage of personal information in secure facilities, taking regular backups of personal information, we hold, logging mechanisms and physical access restrictions to ensure only authorised personnel have access to personal information.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

Executive Distributors
14-16 Croft Crescent
Toowoomba QLD 4350
Australia

PH:  +61 (0)7 4613 4455  or +61 (0)7 3333 1617
FAX: +61 (0)7 4613 5577
E: [email protected]