Togram Group Pty Ltd ABN 54633126626 trading as talentinsight Australia, (‘Us’, ‘We’, ‘Our’) place great importance on protecting the privacy of individuals and We take all reasonable steps to ensure personal information is protected from misuse and unauthorised disclosure.
It is Our intention to always comply with the Privacy Act 1988 (Cth)(‘Act’) including the Australian Privacy Principles (‘APPs’).
1. Collection of Information
- Personal Information is information We hold which is identifiable as being about You. This information includes information such as Your name, address, email address or any other type of information that can reasonably identify an individual, either directly or indirectly.
- We collect and store the Personal Information that You provide to Us directly or give to Us in other forms.
2. How We collect Your Personal Information
- Generally, We will collect Personal Information:
- From You directly when You provide Your details to Us; and
- from You indirectly through emails, forms, face-to-face consultations, mailing list subscriptions, registration and attendance at seminars, business cards and telephone conversations and through use of the services and facilities available through Our website and social media channels.
- Additionally, We may also collect any other information You provide while interacting with Us, either electronically or in person.
- We will collect and use Personal Information with Your consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will also process Personal Information if it is necessary for Our legitimate interests or to fulfil a contractual or legal obligation.
- We do not collect or process any Personal Information from You that is considered “Sensitive Information” under the Act or the European Union General Data Protection Regulation (‘GDPR’) (if applicable).
- You must not provide Us with Your Personal information if You are under the age of 18 without the consent of Your parent or guardian. We do not knowingly collect or process the Personal Information of persons under the age of 18.
3. How we Use Your Personal Information
- conduct Our business and provide You with Our products and services;
- provide, market, develop and research Our products and services;
- communicate with You to provide or promote Our products and services;
- purchase goods or services;
- carry out identity verification;
- help Us manage and enhance Our business, products and services;
- protect Our rights, privacy, safety, or property, and/or that of Our affiliates, You, or others;
- comply with Our legal obligations;
- for a related purpose, where the individual concerned would reasonably expect Us to use it for that related purpose;
- communicate with You by a variety of measures including, but not limited to, telephone, email, sms or mail;
- investigate complaints;
- present You with personalised offers;
- provide You with the opportunity to review Our products and services;
- provide You with information, updates, offers or advertising relating to Our products or services; or
- screen for potential risk or fraud (and to assist regulators, trade bodies and law enforcement agencies in relation to the same).
If You withhold Your Personal Information, it may not be possible for Us to provide You with Our products and services or for You to become or remain a Member.
4. Sharing Your Personal Information
So that We can provide You with Our products and services, We have to share some Personal Information with trusted third parties. We do not sell Your Personal Information but We may share Your Personal Information as follows:
- With core service providers to enable Our business to function
We rely on a few external companies to provide Us with services to conduct Our business. Our core service providers include payment gateway providers and technological service providers. It also includes companies to help Us with Our marketing and data analytics.
- With regulators and law enforcement agencies when required to do so by law
We may from time to time need to disclose Your Personal Information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
- When We think it is reasonably necessary to protect You or Our business
In the unlikely event that We are the subject of attempted criminal activities, We will take all reasonable steps to protect You and Our business but sometimes We may need to share Your Personal Information where We think it is reasonably necessary to:
- detect, monitor, investigate or prevent any suspected illegal activities, fraud or security issue;
- enforce Our terms and conditions and to protect Your and Our rights and property; and/or
- Investigate and defend any third party claims or allegations.
- As part of a business sale or purchase, merger or reorganisation
Although We have no current plans to do so, if there is a change of control in Our business or a sale or transfer of business assets, We reserve the right to transfer to the extent permissible at law Our user databases, together with any personal information and non-personal information contained in those databases.
When We share Your Personal Information We take all steps required by law to ensure that it remains secure.
5. Security of Your Personal Information
- We are committed to ensuring that the Personal Information You provide to Us is secure.
- In order to prevent unauthorised access or disclosure, We have put in place reasonable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
- The transmission and exchange of information is carried out at Your own risk.
- We cannot guarantee the security of any information that You transmit to Us or receive from Us.
6. Personal Information retention
- At the end of the retention period, Your Personal Information will either be completely deleted or anonymised so that it can be used in a non-identifiable way for statistical analysis and business planning.
7. Access to Your Personal Information
- You may request details of Your Personal Information that We hold in accordance with the provisions of the Act and to the extent applicable, the GDPR.
- We reserve the right to refuse to provide You with information that We hold about You in certain circumstances set out in the Act or any other applicable law.
8. Your rights under GDPR
- We comply with Your rights under the GDPR as to how Your Personal Information is used and controlled if You are an individual residing in the European Union.
- Additionally, if You are a European resident We note that We are processing Your information in order to fulfil agreements We might have with You, or otherwise to pursue Our legitimate business interests listed above. Additionally, please note that Your information will be transferred outside of Europe, including Australia.
11. The Website
Generally when You visit the Website, We may automatically collect certain information about Your device, including information about Your web browser and some of the cookies that are installed on Your device. We may also collect information about the individual web pages or products that You view and information about how You interact with the Website.
- Web Browser
When You visit the Website, We may collect certain information such as Your web browser, IP address, time zone, the date and time of Your visit, the pages viewed and information downloaded etc. This information is used in an aggregated manner to analyse how people use the Website such that We can improve Our service and to assess the success of Our marketing and advertising campaigns.
- Using pixel tags, web beacons, clear GIFs or other similar technologies
We may from time to time use pixel tags, web beacons, clear GIFs or other similar technologies in connection with some website pages and HTML formatted e-mail messages to, among other things, measure the success of Our marketing campaigns, and compile statistics about website usage and response rates.
12. Third party sites
The Website may, from time to time, have links to other websites not owned or controlled by Us. These links are meant for Your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that We are not responsible for the privacy practices of other such websites. We encourage Our users and Members to be aware, when they leave the Website, to read the privacy statements of each and every website that collects Personal Information.
13. Contact Us