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1. Your rights in relation to privacy
Thinxtra Ltd (ABN 79 606 156 325) and its related companies:
- Thinxtra Network Pty Ltd, ACN 612 807 057
- Thinxtra Solutions Pty Ltd, ACN 612 804 547
- Thinxtra Network Limited, NZBN 942 904 232 6311
- Thinxtra Solutions Limited, NZBN 942 904 240 0356
- Thinxtra Network Limited, Business Registration 66731998-000
- Thinxtra Solutions Limited, Business Registration 66731883-000
- Thinxtra Holdings Ltd, Business Registration 66731613-000
of Suite 6.01, Level 6, 53 Berry St. North Sydney, NSW, 2060 Australia (“Thinxtra”, “we” or “us”) 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) (including , the 13 Australian Privacy Principles) and where relevant, the Credit Reporting Code (Privacy Laws). This Privacy Statement may be updated from time to time.
By using this website or our products and services, you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Policy.
2. What kinds of Personal Information does Thinxtra collect?
Personal Information is information or an opinion about an identified, or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be Personal Information regardless of whether it is true or not.
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:
- 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.
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
- credit and insurance application forms with Thinxtra;
- job application forms;
- accessing the Sigfox business support systems
- other exchanges with Thinxtra, including any of Thinxtra’s affiliates, through face-to-face meetings or via email, telephone or facsimile.
Personal Information or other data Thinxtra collects online may also be combined with information you provide to us through other channels such as product registration, or in conjunction with events such as training seminars, promotions, and conferences. Where permitted by applicable law, other information gathered from social media platforms and other published sources may be added to the Personal Information you provide to us.
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. This may include disclosing your Personal Information to:
- Thinxtra’s related companies; and
- law enforcement or other governmental agencies; and,
- 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. Those recipients are likely to be in France, Hong Kong, New Zealand and Singapore.
Before disclosing any Personal Information to an overseas recipient, Thinxtra takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Privacy Laws.
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’s Privacy Compliance Officer via the contact details set out in Section 13 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. How to 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; and
- Thinxtra requests that you be reasonably specific about the information you require.
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?
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. External Links
12. Does Thinxtra use electronic mechanisms such as “cookies”?
Thinxtra also captures metrics on the number of visitors to its sites for use in server capacity needs.
13. 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
14. 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.