Standard Communications Pty Ltd ACN 000 346 814 (“Company”, “we”, “our” or “us”), operating under the brand names GME and Kingray, is committed to protecting your privacy.
The Company is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act) as well as other applicable laws protecting privacy.
What personal information do we collect?
The kinds of personal information that we may collect and hold includes, but is not limited to, your name , date of birth, telephone number, street address, postal address, email address, financial information, including your credit card information and website address.
How we collect personal information
We may collect your personal information from a variety of sources, including from you, advertisers, mailing lists, recruitment agencies, contractors and business partners
We may collect your personal information when you request or acquire a product or service from us, register with us, provide a service to us, complete a survey or questionnaire, make an application for employment, enter a competition or event, participate in our services (including any social media), or when you communicate with us via email, telephone or in writing, (e.g. if you contact customer service).
If at any time you provide personal or other information about someone other than yourself, you warrant that you have that persons consent to provide such information for the purpose identified.
Why we collect personal information
We collect personal information s o we can provide services and information to customers, improve our products and services, to assess employment and credit applications, for surveys, promotions and competitions, to assist with queries and for business operations.
We may state a more specific purpose at the point we collect your information
If you choose not to provide certain personal information to us, we may not be able to provide you with the products or services you require.
How we use personal information
We generally use your personal information for the purposes for which it was collected and for related purposes that would reasonably be expected by you, where you have otherwise consented, (or otherwise as required or authorised by law). For example, we may use your personal information to contact you when carrying out after sales service.
In order to provide you with products or services we may need to disclose your personal information to other companies within the group (which includes related companies and any other entity under the GME or Kingray brand name), to our suppliers, dealers, agents, insurers and business partners.
When we collect personal information, we may sometimes also use it for assessment and analysis of our market, customers, products and services, to enable us to monitor, review and improve products and services and for internal record keeping. As part of conducting our business, personal information may be used to maintain and develop business systems, including testing and upgrading them.
We will take all reasonable steps to ensure that persons or organisations to whom we disclose personal information are bound to protect the privacy of your personal information. You consent to the company using your personal information in this way.
You agree that the Company may use or disclose your personal information to provide you with information about products, promotions, special offers and other information which relates to our products or services or which we believe may be of interest to you. We may send you such information by email, telephone, SMS text message and/or any other form of electronic messages, post, fax or smartphone applications, social networking websites or any other method which becomes relevant from time to time.
If you receive direct marketing from us by email or by SMS message, you will be reminded in the email or SMS message that you are able to opt out. (See “Your Rights”, below)
How we hold personal information
We regard the security of your personal information as a priority and implement a number of physical and electronic measures to protect it. We remind you, however, that if you send information to our websites, the internet is not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.
You may request access to the personal information we hold about you, seek the correction of such information and/or complain about the way we have collected, used, held or disclosed your personal information. You can also tell us to delete your personal information or that you do not want us to use your personal information for specific purposes such as receiving direct marketing material. All such requests should be made in writing.
The company undertakes to respond promptly to all correspondence relating to your privacy, action all requests in a timely manner and thoroughly investigate any complaints and advise you of the outcome of any such investigation.
Please direct all correspondence related to your personal information to:
The Privacy Officer
Standard Communications Pty Ltd
PO Box 96
Or email: email@example.com
GME respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how GME collects and processes your personal data.
GME is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Standard Communications Pty Ltd, trading as GME
Name of data privacy manager: Patricia Richards
Email address: firstname.lastname@example.org
Postal address: 17 Gibbon Road, Winston Hills, New South Wales 2153, Australia.
Telephone number: +61288676000
We have appointed the following contact as our representatives in the EEA and they will be responsible for coordination and liaison with us and the data protection authorities (see details below).
Representative: Raworths LLP, 89 Station Parade, Harrogate, North Yorkshire HG1 1HF, England.
You have the right to make a complaint at any time to the relevant national authority responsible. The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a regulator so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in November 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
When you use our website, it may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status and title.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you, including invoicing;
- Technical Data includes internet protocol (IP) address, your login data, browser type and version and other technology on the devices you use to access our website.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you ask us to carry out our services for you.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (keeping a list of prospective customers)
To process and deliver our services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Other processing necessary to comply with our legal obligations
(d) ensuring business policies are adhered to, such as security policies and internet use
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts due to us or to be as efficient as we can so we can deliver the service to you.
To manage our relationship with you which will include:
(b) Updating client records
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We routinely share data with:
- Companies that provide services to help us to run our business more efficiently, such as CRM software, website hosting and IT support.
- Our banks and other professional advisors, such as accountants;
- Our insurers and brokers;
- The Australian Taxation Office (ATO) and other regulatory bodies where we conduct our business.
In addition we may share your data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
We transfer your personal data outside the European Economic Area (EEA) to our systems and servers in Australia. These transfers are subject to special rules under European and UK data protection law. We will, however, ensure the transfer complies with data protection law and personal information will be secure.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/ product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.