PRIVACY POLICY
Emilio Frank Design (ABN 55 104 811 118)
Effective 15 June 2017.
General Policy Statement
At Emilio Frank Design, we take your privacy very seriously and understand the importance of protecting your personal information.
It is our intention to always comply with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (“APPs”). This policy applies to information collected by Emilio Frank Design. It outlines how we collect and use personal information that we hold about you in accordance with the APPs.
What Personal Information do We Collect?
Personal Information is information which can reasonably identify you. We only collect personal information that is reasonably necessary for us to provide you with our services and products. If you do not provide us with the information we request, we may not be able to provide you with the services that you want. We may collect information such as your name, address, phone number, email address and such other information as we may require to confirm your identity and other information related to the specific services and products we provide our clients.
How personal information is collected
By using Emilio Frank Design’s services you are consenting to us collecting your personal information.
We usually collect personal information directly from an individual when an individual communicates with us, such as when he or she:
Provides us with personal information in connection with the provision or potential provision of consulting services by us.
Makes inquiries about our services or contacts us for any other reason so that we can process, deal with and respond to such queries or any other issues, including complaints.
Provides us with business cards or other contact information.
Uses our website.
Contacts, registers with, posts to, likes or follows any of our social media websites, pages, forums or blogs.
We may also collect personal information about an individual when a client (for example, an employer, colleague or associate of the individual) uses our services. We may also collect personal information about individuals from third parties, such as:
From agents or advisors on behalf of an individual.
From third party referrals.
Through reports from professionals, or otherwise in connection with the provision of our services.
From publicly available sources.
Sensitive information
We may collect sensitive information about individuals, but only where:
The individual has provided consent to such collection and the information is reasonably necessary for our functions or activities; or
As otherwise permitted by the APPs.
Use of Personal information
Emilio Frank Design may use your personal information for the primary purpose of providing you with compliance services and products, as well as for related purposes, such as:
To verify your identity or transactions that you may enter into with us.
To administer and manage the provision of our products and services to you.
To comply with any applicable Australian laws and regulatory requirements, including complying with any lawful request made by a governmental authority, regulator or enforcement agency, including in connection with legal proceedings or the prevention or detection of crime, fraud or other misconduct.
To comply with Emilio Frank Design’s risk management policies and procedures.
To conduct due diligence prior to providing you with your requested products and services.
To provide you with regular updates on our service and product offerings by way of direct marketing.
For research and development purposes related to business development, product planning and product delivery.
Any other purpose related to the primary purpose.
Use and disclosure of information
We collect and use personal information for our business purposes. The main purposes for which we collect and use information are:
To provide our clients with consulting services.
Where the information was given to us for another specific purpose (such as a job application), for that purpose.
In respect of our website, to respond to any requests made and for statistical, web development and internal purposes.
For our own internal, relationship and marketing purposes (however, we always provide a choice to “opt out” of receiving direct marketing or related communications from us).
For a related purpose, where the individual concerned would reasonably expect us to use it for that related purpose.
We only disclose personal information:
With the consent of the individual concerned.
As otherwise permitted by the APPs.
As required or permitted by law or court or tribunal order.
Cookies and other web tracking systems
We track traffic patterns throughout our website.
We use “cookies” on our website. A “cookie” is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser but not you. A cookie can collect and store information, but cannot interfere with your computer.
Our internet service provider will record and advise us of your service address, domain name, the date and time of your visit to our site, the pages viewed and the information downloaded.
If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our website, but not all services may be available.
Disclosure of Information
Emilio Frank Design will generally not provide any of your personal information to third-parties unless expressly consented to by you when you apply for our products and services. However, in the course of providing our products and services to you we may also disclose your personal information:
To a relevant Credit Reporting Body (in certain circumstances).
To government regulatory authorities and enforcement agencies.
Related bodies corporate.
Where we are otherwise required or authorised to do so by law.
Access to, Correction of, or Updating of Your Personal Information
Generally, we will provide you with access to your personal information that we hold within a reasonable time-frame upon receipt of a written request. We may not grant access to you, if a relevant exception under the Privacy Act applies. If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, please contact us about your concerns. If we determine your concerns to be valid, we will update the personal information we hold within a reasonable timeframe, and provide you with written notice of the correction. Alternatively, if we disagree with your concerns, we will note the issues on your records that we hold, provide you with written notice of our reasons, and outline any additional avenues of redress open to you. You should keep us informed of any changes to your personal information, by notifying us in writing. From time-to-time we may request that you review, confirm and advise us of changes to your personal information.
Security of Information
Emilio Frank Design is committed to protecting your personal information from misuse and we take all reasonable steps to ensure your personal information is not misused, lost, or accessed or disclosed by unauthorised persons.
Cross-border Disclosure of Personal Information.
Emilio Frank Design may transfer personal information to related bodies corporate and unaffiliated service providers in locations outside Australia’s territorial jurisdiction in the course of storing, using or disclosing that information. When transferring your personal information to foreign jurisdictions, Emilio Frank Design will take all reasonable steps to ensure the overseas recipient deals with that information in ways consistent with the APPs. That being said, the overseas recipient may not have privacy protections exactly equivalent to those in Australia under the APPs. By using Emilio Frank Design services and products, you consent to Emilio Frank Design making overseas disclosures of your personal information necessarily related to the primary purpose for which it was collected.
Disposal of Personal Information
If we no longer need to hold your personal information for the primary purpose, we will take reasonable steps to de-identify and then destroy that information. We may retain your personal information when required to do so under a relevant Australian law.
Complaints
If you have a complaint about a breach of the APPs by Emilio Frank Design in relation to your personal information, please contact us in writing, either by email or mail – see the relevant details in the Contact Us section below.
Complaints will be reviewed by our Privacy Officer and a response will usually be provided within thirty (30) days of receipt of the complaint by us.
If you believe that your complaint has not been satisfactorily addressed by us, after following the procedure set out above, you can make a complaint to the Office of the Information Commissioner.
For more information about making a complaint, contact our Privacy Officer.
Changes to this Privacy Policy
We may make changes to this privacy policy from time to time for any reason. Any changes will be effective from the date of publication on our website. Please check this privacy policy from time to time for updates.
Contact Details
If you have any questions about our privacy policy or need to contact our Privacy Officer for any other reason, please contact our Privacy Officer using the contact details below.
Shana Danon
Emilio Frank Design
PO Box 2449
Bondi Junction NSW 1355
Phone: 0414 868 091
Email: shana@emiliofrankdesign.com