Privacy Policy

Untangled ICT Pty Ltd – Privacy Policy

This is the Privacy Policy of Untangled ICT Pty Ltd (“Untangled”). In this Privacy Policy, “Untangled”, “we”, “us” and “our” have the same meaning. At Untangled we respect the privacy of the people we deal with and we uphold high standards of privacy practice and information/data security. This Privacy Policy is designed to explain how we handle personal information and how we interact with you online.

Whenever we handle personal information, we take steps to ensure that appropriate standards of privacy practice and data security are applied.

This Privacy Policy sets out why we need to collect personal information, how we collect it, what we do with it, how it is stored and with whom we might share it. The Privacy Policy also describes how you can access and correct information that we hold about you, how you can ask further questions or make a complaint, as well as useful information about our website and online activities.

The information we collect

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. We require you to provide us with certain personal information so that we can provide you with the most appropriate products and service, information and marketing material and to satisfy certain legislative and regulatory requirements.

If you give us personal information about another person, you represent that you are authorised to do so and you agree to inform that person who we are, that we will use and disclose that information for the relevant purposes set out below, and that they can access the information we hold about them.

We do not generally collect or disclose sensitive personal information, such as information about a person’s race, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions or biometric and health information.

If you choose to not provide us with your personal information we may not be able to provide you with all of our products and services.

Information we ask you to provide us

• When you use our products and services, we may collect the following types of personal information:
• name;
• email address, mailing or street address and other contact details;
• date of birth;
• information to verify your identity, such as your driver’s licence number;
• tax file number; and
• bank account details.

Information we automatically collect using cookies

For all visitors to our web site, we use cookies to collect anonymous information such as the server your computer is logged on to, your operating system, your browser type (for example, Internet Explorer, Chrome or Firefox), and your IP address. (An IP address is a number that is assigned to your computer automatically and is required for using the Internet). We may also derive the location associated with an IP address. Once you have logged into our client portal, have accessed our website from an e-mail or other personalised communication sent to you, or provided us with personal information by completing a form online, we may be able to identify you and we may combine that with other information in order to provide you with a better online experience.

You can configure your browser to notify you when you receive a cookie and this will allow you to either accept or reject a cookie each time. If you disable the use of cookies on your web browser or remove or reject specific cookies from our website or linked sites, then you may not be able to gain access to all of the content and facilities within our website.

Our website also uses Google Analytics to collect data about site traffic via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. This informs the use of:

• Google Analytics Demographics and Interest Reporting, which allows us to better understand who our users are, and how they are using our site. No personally identifying information is collected or included. From time to time, we may use these insights to refine ad campaign strategies through the Google Display Network.
• Remarketing with Google Analytics – from time to time, we may use remarketing through third parties such as Google to re-target users who have visited the site.
• Google Display Network Impression Reporting, which gives us insight into who has viewed our paid advertising on other sites, such as remarketing with Google. No personally identifying information is collected or included.
• Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers – the integration between Google Analytics and third party paid advertising platforms that allows us to tailor the advertising for a better user experience.

If you would like to change preferences or opt-out of these Google Analytics features, you can do so via the Google Ad Settings Manager or the Google Analytics Opt-Out Tool.

Why we collect personal information

Sometimes we are required by law to collect information to identify and verify your identity. We therefore may make enquiries as to your identify and other personal details as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

Other than as required by law, we will only use your personal information for the purpose of providing you with our products and services. We collect your personal information to:

• assess your online application and prepare the documents needed to set up your Untangled account;
• communicate with you in relation to your business ITC services and your use of our products and services;
• monitor, audit, evaluate and otherwise administer our products and services;
• customise our products and services to you;
• perform data analytics to help us improve our products and services, including by generating analytics about how our customers browse and interact with our website and to assess the success of our marketing and advertising campaigns;
• assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or the research purposes of us and our contractors and service providers; and
• do any other thing as expressly authorised by you.

We will only use or disclose personal information we collect about you for the purpose for which it was disclosed to us, or related purposes which would reasonably be expected, without your permission, or as permitted by the Australian Privacy Principles.

How we collect and store your information

The main ways we collect personal information about our customers are:

• if you register to receive information about our products and services;
• if you submit an online application for any of our products;
• if you give information or other material to us;
• if the information is provided to us by a third party (including public sources, your adviser(s), employer (or its affiliates), agents, referrers, brokers, our related companies and service providers); and
• if you interact with us (including online, by telephone or email) by making an enquiry or complaint.

We keep personal information in electronic records, at our premises and the premises of our service providers, which may include storage on the cloud.

Keeping information secure

We use security procedures and technology to protect the information we hold. Access to and use of personal information by Untangled is controlled in a manner that seeks to prevent misuse or unlawful disclosure of the information – this includes internal policies, auditing, training and monitoring of staff.

However, no method of transmission over the internet using industry standard technology is 100% secure. Therefore, we cannot guarantee the absolute security of your information.

If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
Where the personal information we collect is no longer required, we generally delete the information or permanently de-identify it in accordance with relevant laws and our records management policy.

When your information is disclosed

We take reasonable steps to ensure that third party organisations meet the data privacy conditions described in this Privacy Policy. Outside of authorised personnel employed by us, we may share personal information with the following third parties:

• agents, contractors and external service providers appointed by us, who provide services in connection with our products and services;
• your personal representative, attorney, agent or financial adviser (but only with your written consent);
• a government or regulatory body, where required or authorised by law;
• financial institutions and other similar organisations that we deal with in the course of providing our services to you; credit reporting agencies;
• a third party that acquires, or intends to acquire, Untangled or its material assets;
• companies that we work with for the purposes of product development, joint venture arrangements and distribution arrangements; and organisations that provide direct marketing services.

We may also disclose your personal information to entities located overseas for one or more of the purposes set out above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the Australian Privacy Principles relating to your personal information.

Keeping information accurate and up to date

We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

How you can access or correct your information

You can request access to, or correction of, your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

Changes to our Privacy Policy

We reserve the right to modify this Privacy Policy at any time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we make material changes to this Privacy Policy you will be notified via email (if we have your contact information) or otherwise in some manner through our services that we deem reasonably likely to reach you.

Any modifications to this Privacy Policy will be effective upon our publication of the new terms and/or upon implementation of the new changes to our services (or as otherwise indicated at the time of publication). In all cases, your continued use of our services or website after the publication of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact us

If you have any questions or complaints regarding privacy or information handling, please contact us at accounts@untangledict.com.au. We will respond to let you know who will be handling your matter and when you can expect a further response.

If your concerns are not resolved to your satisfaction, you may be able to escalate your complaint to an external dispute resolution scheme or to a regulatory authority such as the Office of the Australian Information Commissioner.