“We”, “Us” and “Our” refer collectively to “Lorgan Pty Ltd.,”
We are committed to protecting your privacy in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”).
Our Privacy Policy provides you with information about how “personal information” may be collected, accessed, used, stored, disclosed or otherwise handled by Lorgan.
- What is “personal information”?
“Personal information” is defined in the Privacy Act to mean any “information or an opinion about an identified individual, or an individual who is reasonably identifiable”:
– whether the information is true or not, and
– whether the information or opinion is recorded in a material form or not.
What constitutes personal information will vary, depending on whether an individual can be identified or is reasonably identifiable in the particular circumstances.
Information that includes a person’s first name, mailing address, telephone number, title or e-mail address may be personal information, for example.
In this Privacy Policy, we also use the term “sensitive information”. Sensitive information includes personal information relating to health, as well other kinds of personal information to which higher standards apply under the Privacy Act.
- Purposes for which we may collect and use personal information
We collect personal information when reasonably necessary for one or more of our functions or activities. Purposes for which we collect, hold, disclose and otherwise use personal information include, but are not limited to, the following:
– to promote and market Lorgan, including their people and activities, to you,
– to assess, receive, manage or terminate the receipt of goods or services from you or the organisation which employs you,
– to provide services to clients that engage us, as required by law.
In all cases where personal information is used, we will ensure we have consent from you to do so.
Our practices in relation to electronic mailing lists
We do not send “commercial electronic messages” by email, SMS or other means unless the relevant electronic account holder consents or we are otherwise permitted to send them under the Spam Act 2003 (Cth). We include certain information about ourselves and an unsubscribe facility in any commercial electronic messages that we send.
If you provide your email address to us via one of our websites (for instance, by sending an electronic message or by completing a web form), we will only use your email address for the purposes for which you provided it or agreed it may be used. Your email address will not be subscribed to a mailing list without your consent. If you subscribe to one of our mailing lists, you will be sent a confirmation message before your email address is added to that mailing list. We will never provide your email address to a third party without your consent.
- How we collect personal information
If we collect personal information about you we will take reasonable steps to notify you or to ensure your awareness of at least the following:
– our identity and contact details,
– the facts and circumstances of collection,
– whether collection is required or authorised by law,
– the purposes of collection,
– the consequences if personal information is not collected,
– our usual disclosures of personal information of the kind collected,
– information about this Privacy Policy, and
– whether we are likely to disclose personal information about you to overseas recipients, and if practicable, the countries where they are located.
We may collect personal information about you in a number of ways, including:
– directly from you, such as when you provide information by phone or in a form, or when you submit your personal details through our websites;
– from third parties, such as our clients, or your representatives; or
– from publicly available sources of information.
Sensitive information
We will collect sensitive information only with the consent of the individuals concerned, subject to limited exceptions permitted by the Privacy Act.
You can interact with us anonymously or by using a pseudonym when it is lawful and practicable to do so.
For example, you may be able to provide comments or make certain inquiries anonymously or by using a pseudonym. However, if you choose to remain anonymous or use a pseudonym, it may be impracticable for us to respond to some inquiries (e.g. investigate a complaint) without knowing your identity.
Where you interact with us via one of our websites, we may automatically collect various connection parameters, such as your IP address and details about your internet service provider, in order to administer and improve the performance of the website. If the website uses “cookies” you may choose to configure your web browser to access our websites without accepting the cookies, but it may reduce your user experience and require you re-enter certain information from time to time.
- How we hold personal information
We will take reasonable steps to protect any personal information that we hold from misuse, loss, unauthorised access, modification or disclosure. We will also take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for the purpose for which the information was collected.
Your personal information may be stored in hardcopy documents, as electronic data, in our internal software or systems, or using a third party under an outsourced arrangement for data storage or backup.
Our practices in relation to emails
Lorgan logs and stores email messages by capturing each email log file on a mail server. If an investigation is necessary, Lorgan, a law enforcement agency or other government agency may inspect the above information for the purposes of the investigation. We do not otherwise use or disclose the above information except in accordance with applicable laws, including the Privacy Act.
- Disclosure of personal information
Lorgan may disclose your personal information (including to each other) for the primary purpose for which it was collected, for a related purpose as you would reasonably expect, with your consent, or otherwise as required or authorised by law.
For example, we may disclose your personal information to:
– our professional advisors including our accountants, auditors and lawyers,
– your authorised representatives or legal advisors (e.g. when requested by you to do so),
– credit-reporting and fraud-checking agencies,
– third parties to whom we have outsourced various business functions,
– Government and regulatory authorities and other organisations, as required or authorised by law,
– Lorgan members,
our partners or other third parties who assist us in achieving the purpose for which the information was collected.
- How to access and correct your personal information
You have a right under the Privacy Act to request access to your personal information, and to request its correction.
We will provide you with access to personal information that we hold about you, subject to any exceptions allowed by law. We may charge you for providing access, but the charge (if any) will not be excessive and we will never charge you for making a request for access.
If you are aware that personal information which we hold about you is inaccurate, incomplete or out-of-date, please contact us and we will take reasonable steps to correct the information or, if necessary, to associate a statement that the personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, in such a way that will make the statement apparent to users of the personal information.
We will also respond to each request within a reasonable period after it is made. If we do not provide access or make corrections as requested, then we will notify you of our reasons except to the extent that it would be unreasonable to do so.
- Updates to this Privacy Policy
We may change or modify this Privacy Policy from time to time. We encourage you to check our websites regularly for updates.
- Website analytics
To improve your experience on our site, we may use ‘cookies’. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
Our website uses Google Analytics, a service which transmits website traffic data to Google servers outside of Australia. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
By using this website, you consent to:
– The processing of data about you by Google in the manner described in Google’s Privacy Policy;
– The use of data corresponding to your interactions with our websites to tailor marketing messages to you that may be displayed on this or other web sites or, through third parties, across the Internet.
– Information about how your visitors can opt out of Google’s use of cookies by visiting Google’s http://www.google.com/settings/ads
-You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.
- How to contact us
For any matter relating to this Privacy Policy or your personal information, including if you wish to complain about a breach of the Australian Privacy Principles, please
contact:
Privacy Officer
Lorgan Pty Ltd.,
Email: ask@lorganglobal.com
We will respond to you, and we will try to resolve any complaints, as soon as possible.
