2 COLLECTION OF PERSONAL INFORMATION
2.1 4Retirees may collect and use the following kinds of information:
(a) information about your use of the website or Services (including your IP address; browser type; version and language; operating system; pages viewed while browsing the website or Services; page access times; “cookies”; and referring website address); and
(b) information about your personal details (including name; phone contact details; address information; email; username; password; and payment information).
2.2 Information about your personal information may be collected from you in a variety of ways, including but not limited to:
(a) when you create an account;
(b) when you register for the Services;
(c) when you interact with 4Retirees electronically or in person;
(d) when you access 4Retirees’ website or Services; and
(e) when 4Retirees provides products and/or Services to you.
3 USE AND DISCLOSURE OF PERSONAL INFORMATION
3.1 4Retirees may use your personal information to:
(a) enable your access to the website;
(b) track usage and measure traffic statistics of the website;
(c) supply to you the products and/or Services that you purchase or request as a customer;
(d) receive and/or access information from third party providers for the provision of our products and/or Services to you;
(e) contact you regarding your use of the products and/or Services offered by 4Retirees;
(f) contact you in relation to comments, complaints, enquiries or dispute resolution;
(g) collect payments from you;
(h) communicate with third party providers or associate parties with respect to the provision of the Services; and
(i) send you marketing communications.
3.2 4Retirees will not disclose personal information about you, unless it is required, incidental or otherwise related to the primary purpose of providing Services to you or a third party for which you have consented to by engaging 4Retirees’ Services or by using 4Retirees’ Services. However, 4Retirees may disclose your personal information to its business partners who can assist them to provide Services to you as a customer.
3.3 4Retirees, in its sole discretion, may disclose your personal information if it is required to do so by law or legal process, including:
(a) in order to establish, exercise or defend its legal rights;
(b) as required or authorised by law; or
(c) to the extent required to permit 4Retirees to investigate suspected fraud, harassment or other violations of any law, rule or regulation, our policies, or the rights of third parties or any other suspected conduct 4Retirees deem improper.
4 SECURITY AND ACCURACY
4.1 It is important that you advise 4Retirees of changes to your personal information that you have provided to 4Retirees as it is essential that your personal information is accurate, complete, and up-to-date in order for 4Retirees to provide Services to you.
4.2 4Retirees will take commercially reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure. However, 4Retirees is not liable for any unauthorised access to this information.
4.3 4Retirees will take commercially reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes of providing our Services to you and where 4Retirees is not required to retain that information by law.
5 ACCESS AND CORRECTION
5.1 You are responsible to ensure that the information you provide to 4Retirees is accurate, complete and up-to-date.
5.2 By request, you may contact 4Retirees and ask to know what sort of personal information is held about you, for what purposes, and how it is collected, held, used and disclosed.
5.3 By request, you may access your personal information by contacting 4Retirees at email@example.com 4Retirees reserves the right to charge a reasonable administration fee for this access.
5.4 4Retirees in its sole discretion, may consider that there is a sound reason under the Privacy Act, Freedom of Information Act or other relevant law to withhold personal information, or not make the requested changes.
6 IDENTIFIERS AND ANONYMITY
6.1 You acknowledge that 4Retirees retains, collects and maintains your personal information for statistical analysis purposes (whether for commercial or non-commercial purposes). You agree that 4Retirees may share, distribute and/or transfer information which you have provided to 4Retirees to third parties, after that information has been de-identified.
7 TRANS-BORDER DATA FLOWS
7.1 4Retirees uses Amazon Web Services (AWS), and as such, its server is located in Australia and you acknowledge, agree and understand that your personal information will be transferred and stored in Australia and other foreign jurisdictions which AWS services may direct the data to be stored. You agree for us to transfer your information into foreign jurisdictions for the purposes of providing you with the Services.
7.2 In addition to the above, 4Retirees will transfer personal information to someone who is in a foreign country where:
(a) 4Retirees reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles;
(b) the individual consents to the transfer;
(c) the transfer is necessary for the performance of a contract between you and 4Retirees, or for the implementation of pre-contractual measures taken in response to your request;
(d) the transfer is necessary for the conclusion or performance of a contract concluded in your interest between 4Retirees and a third party;
(e) all of the following apply:
(i) the transfer is for your benefit;
(ii) it is impracticable to obtain your consent to that transfer; and
(iii) if it were practicable to obtain such consent, you would be likely to give it; or
(f) 4Retirees has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the National Privacy Principles.
8 SENSITIVE INFORMATION
8.1 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.
8.2 Sensitive information will be used by 4Retirees only:
(a) for the primary purpose for which it was obtained;
(b) for a secondary purpose that is directly related to the primary purpose;
(c) with your consent; or
(d) where required or authorised by law.
9.2 A complaint should identify whether it is about:
(a) the collection of personal information;
(b) the use of personal information;
(c) the disclosure of personal information;
(d) the security or storage of personal information;
(e) the accuracy of personal information;
(f) a refusal to give access to or provide about their personal information; or
(g) a refusal to change or delete personal information.
9.3 4Retirees values your opinions and takes complaints very seriously. Upon receiving written notice of your complaint about privacy, 4Retirees will respond in a timely manner to advise you of the outcome following its enquiring into the same. You will also be invited to respond to its outcome. If a response is received, 4Retirees will assess your response and advise if it has changed its view. If you are unsatisfied with the final outcome, 4Retirees will advise further options including, if appropriate, making a complaint with the Office of the Australian Information Commissioner.
10.2 Governing Law & Jurisdiction
11.3 This policy was last modified on 06 September 2018.