QuintessenceLabs has obligations concerning the collection, use, disclosure, and storage of personal information. These obligations are set out in the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act), and other applicable State and Territory privacy laws.
What is personal information?
"Personal information" is information or an opinion about an identified individual or reasonably identifiable individual, whether true or not and whether recorded in material form or not.
What personal information do we collect and hold?
We collect information about you and your interactions with us. The types of personal information we may collect about you will depend upon the nature of our interaction with you. Specifically, the personal information we collect and hold may include:
- email address;
- telephone number or mobile number;
- information provided to us via customer surveys;
- the location from which you have come to our website and the pages you have visited; and
- technical data, which may include IP address, the types of devices you are using to access the Websites, device attributes, browser type, language and operating system.
How do we collect personal information?
We may collect personal information directly from you or from a third party. We will only collect your personal information from a third party if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
We will collect information from third parties such as:
- your nominated representative;
- publicly available sources of information or registers;
- our related entities, companies or businesses; or
We may collect this information when you communicate with us through the Websites, by telephone, by e-mail or through a written application. In some circumstances the collection of personal information may be required by law.
Specifically, we may collect your personal information:
- when you use our services;
- when you request information about us our services;
- when you provide feedback to us;
- when you visit or fill in a form on the Websites;
- when you visit premises from which we operate;
- when you contact us by telephone, email, social media, post or in person;
- when you visit us at conferences and trade shows; and
- when we are otherwise required or authorised by law.
Why do we collect, hold, use and disclose personal information?
We collect, hold, use and disclose your personal information for the following purposes:
- to perform our organisational functions and activities in order to operate our business efficiently;
- to identify and communicate with you;
- to enable us to provide you with requested information, products or services;
- to help us to manage and enhance the services we provide to you;
- to help us to manage and enhance services we procure from our suppliers and subcontractors;
- to manage and administer any account you hold with us;
- to enable you to access and use our Websites and online services;
- to operate, improve and optimise our Websites and online services and yours and other users' experience;
- to send support and administrative messages, reminders, technical notices, updates, security alerts, and information to you;
- to send marketing and promotional messages to you and other information that has been requested or which may be of interest;
- to process any application submitted by you;
- to respond to any queries or complaints you have made;
- to comply with our legal obligations; and
- to assist government and law enforcement agencies or regulators.
We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.
When you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
To whom do we disclose personal information?
We may disclose your personal information to the following third parties for the purposes listed above:
- QuintessenceLabs related companies (Group Entities)
- trading partners and service providers (of QuintessenceLabs and Group Entities);
- to your nominated representatives;
- other organisations or individuals who assist us in providing services to you or to administer our business (for production and integrated logistics management purposes); and
- Government, regulatory authorities or other organisations as required or authorised by law.
We may disclose your personal information to external service providers so that they may perform services for us or on our behalf or to assist us in providing our services or to administer our business.
When we disclose personal information to third parties, we make all reasonable efforts to ensure that we disclose only relevant information and that it is accurate, complete and up to date and that the third party will comply with the Privacy Act in relation to the use, disclosure and storage of your information.
Other permitted disclosures
We may disclose personal information in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by the Privacy Act or another law. These other disclosures may include where:
- you would reasonably expect the disclosure to occur (for example, quality assurance purposes or training);
- we are authorised or compelled by law to disclose;
- it will prevent or lessen a serious threat to someone's life, health or safety or a threat to public health or safety;
- it is necessary as part of the establishment or defence of a legal claim;
- it is requested by an enforcement agency such as the police; or
- it is a necessary part of an investigation following a complaint or incident.
Other uses and disclosures
Disclosure of personal information outside Australia
We may disclose your personal information to recipients located outside Australia, including to our Group Entities who may store or process your information on our behalf. The country in which those third party recipients may be located are in the United States of America.
Where we disclose information outside of Australia, we will take reasonable steps to ensure that any such person to whom personal information is disclosed will deal with that information in a way that is consistent with the APPs.
Information collected via our websites
- https://www.quintessencelabs.com; and
- any other websites owned or operated by QuintessenceLabs from time to time
(together, the Websites).
A "cookie" is a small file stored by the web browser software on your computer when you access our Websites. An explanation of cookies can be found on the Office of the Australian Information Commissioner's (OAIC) website.
We use session cookies for maintaining contact with a user throughout a web browsing session. Session cookies expire when the browsing session comes to an end or a user shuts down their computer.
We use persistent cookies for statistical purposes and to improve our Websites.
The website communications generated from using and/or registering on this Website, such as promotional emails, may contain electronic images known as "web beacons". Web beacons generally work in conjunction with cookies, and we may use them with cookies to, for example, count the number of visitors to the Websites or see whether you have acted on an email or clicked on a link, for example where this is a condition of entering a competition.
The information generated by the cookie about your use of the Websites (including their IP address) will be transmitted to and stored by HubSpot on servers in the United States. HubSpot will use this information for the purpose of compiling reports on the Websites' activity and providing other services relating to the Websites and internet usage. HubSpot may also transfer this information to third parties where required to do so by law, or where such third parties process the information on HubSpot’s behalf. HubSpot will not associate a person's IP address with any other data held by HubSpot.
When you visit our Websites, a record is made of your visit, including the following information:
- your server address;
- your top level domain name;
- the date and time of access to the site;
- pages accessed and documents downloaded;
- the previous site visited; and
- the type of browser software in use.
We analyse this non-identifiable Website traffic data (including through the use of third party service providers) on an aggregated basis to improve our services and for statistical purposes.
No attempt will be made to identify users or their browsing activities except in the unlikely event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet Service Provider's log files.
Third party websites
The Websites may link to other websites which are outside our control, and other websites outside our control may link to the Websites. Whilst we try to ensure that we link only to websites which share our privacy and security standards, once you have left a Website we cannot be responsible for the protection and privacy of any information which you provide on other websites. You should exercise caution and review the privacy statement applicable to the website in question.
Security of your personal information
We store most information about you in access controlled financial and customer relationship management systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.
We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes:
- limited access and distribution by only key authorised personal;
- training our staff in how to keep your information safe and secure;
- storing your hard copy and electronic records in secure systems; and
- using trusted contracted service providers (including cloud storage providers).
If the information we store is no longer required by us for any purpose for which it was collected and is no longer required by law to be retained by us, we will destroy or de-identify the information.
How can I access or correct my personal information?
We have measures in place to ensure the information we hold about you is accurate, complete and up to date.
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.
If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons.
If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.
How can I make a complaint?
If you have a complaint or concern regarding our handling of your personal information or think that your privacy has been affected, you should contact us using our contact details set out below to raise your complaint or concern.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled your privacy complaint or concern, you may approach an independent advisor or contact the OAIC. See the OAIC website for more information about how to make a complaint.
- wish to make a complaint about the way we have collected, used, held or disclosed your personal information;
- would like to opt out of receiving our newsletter or information about QuintessenceLabs products or services,
please contact our Privacy Officer in any of the following ways:
- Email: firstname.lastname@example.org
- Phone: +61 2 6260 4922
- Mailing address: Unit 11, Brindabella Circuit, Brindabella Business Park, Canberra Airport, ACT 2609
This policy was last updated: 6th April 2023