Privacy Policy
Siltrax Privacy Policy
Dated: 14 August 2024
1 This Policy
This privacy policy applies to the handling of personal information by Siltrax Pty Limited ABN 97 668 567 824 (Siltrax, we, us, our).
We understand the importance of protecting the privacy of an individual’s personal information. This privacy policy sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by Siltrax, and how we collect, hold, use, disclose, and otherwise manage, your personal information.
In collecting, holding, using, disclosing and otherwise managing your personal information, we will comply with the Privacy Act 1988 [HW1] (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
We will regularly review our policies and procedures regarding personal information, and may update and amend this privacy policy from time to time. Any updated privacy policy will be made available on the Siltrax website at https://www.siltrax.net/privacy-policy/ or can otherwise be obtained by contacting us and requesting a copy.
2 Kinds of personal information collected [HW2]
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our services, or as a result of our other interactions or dealings with you including on our website or otherwise, we may collect your personal information.
The kinds of personal information that we collect will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Siltrax collects may include:
n if you or your company submit an enquiry with us, your contact information such as your name, employer, postal address, telephone number, contact email address and any information conveyed by you as part of your enquiry;
n marketing data, such as your preferences in receiving marketing from us, or information about the way you use our services or interact with our website; and
n any other information that you provide or otherwise make available to us in connection with our website or services.
We may also collect internet/technology related information from visitors to our website, including the referring URL, your IP address, which browser you used to come to the site, the country, state or province, the pages of our website that you viewed during your visit, any search terms entered on our website, the operating system used by accessing systems, the website from which an accessing system reaches our website (so-called referrers), the sub-websites, the internet service provider of the accessing system, and any other similar data and information that may be used in the event of attacks on our information technology systems.
We may also collect or hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information [HW3] about individuals, however if we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.
3 How we collect personal information[HW4]
Generally, we will only collect your personal information directly from you. For example, we may collect your personal information:
n when you request information or services or otherwise provide us with your details;
n where you use our website, web application or other services or otherwise interact with us; or
n if you post information to our social media or other online sites.
However, there may be occasions where we may collect your personal information from someone other than you, for example:
n from our other service providers that help us provide our services;
n from third parties you authorise to disclose your information to us;
n from cookies, log files and other similar technologies;
n from an organisation that you are an employee or other representative of; or
n from a publicly maintained record or other publicly available sources of information including social media and similar websites.
4 Purposes for which personal information is used[HW5]
We collect and use personal information so that we can offer you our services, and to generally develop, improve and promote our services.
Some examples of the purposes for which we may collect, hold, use or disclose your personal information include to:
n enable us to supply you with any information you request from us, or respond to any enquiry you submit to us;
n supply our services to you;
n notify you of new or changed services offered by Siltrax, or to notify you of related services;
n personalise your experience with our services and help us better respond to your needs;
n contact you to obtain your feedback regarding services or to conduct other market research;
n improve, modify or enhance our website, including the user experience;
n analyse information we collect so that we can administer, support, improve and develop our business and the services we offer;
n prevent misuse of our services, and if necessary, to make it possible to investigate any offences; and
n comply with the obligations of Siltrax under any applicable laws.
In addition to the purposes listed above, we may also use your personal information for other purposes (which we notify you of when we collect the information), or for purposes otherwise permitted or required by law.
Where personal information is used or disclosed, we will take steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.
You are under no obligation to provide your personal information to Siltrax, however without certain information from or about you, we may not be able to provide you with our services or information, or we may be limited in how we can interact with you.
5 Direct marketing [HW6] [MS7] [HW8]
In addition to the purposes outlined in above, we may use and disclose your personal information in order to inform you of events, products or services that may be of interest to you. This may include Siltrax disclosing your personal information to related companies of Siltrax or other entities with which Siltrax has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.
If you do not wish to receive such communications, you can opt-out at any time by contacting Siltrax, or through the opt-out mechanism contained in any marketing communications to you.
6 Anonymity and pseudonymity
You may request to engage with us using a pseudonym or whilst remaining completely anonymous. However, if you chose to remain anonymous or use a pseudonym, we may be limited in our ability to engage with you, and we may not be able to offer you the services or information you seek, or fully respond to your queries or requests.
7 Disclosure of personal information [HW9]
Generally, we only disclose your personal information consistent with the purposes for which that personal information was collected (such as set out above in this privacy policy). This may include disclosing your personal information to:
n related companies of Siltrax;
n our service providers and contractors and other third parties that provide products or services to us (including our technology service providers or other business or administration service providers);
n our professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers);
n Government or law enforcement authorities, where required by law; and
n people, entities, or other parties considering investing or acquiring an interest in Siltrax’s business or assets.
We may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, where we have otherwise received your consent to the disclosure, or where the disclosure is required or authorised by law.
If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
8 Overseas disclosures[HW10] [MS11] [HW12]
In providing our services or information to you, it is possible that we may occasionally need to disclose your personal information to locations outside of Australia, such as to our partners and related entities in China.
If these circumstances, we will (where possible) take reasonable steps to ensure that the overseas recipient of your personal information complies with this privacy policy and the Privacy Act (or a substantially similar privacy regime). Where this is not possible, we will seek your consent to the overseas disclosure.
9 Links to other websites
When you access our websites or other online services, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website has its own privacy practices, as described in that site’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot and are not responsible for any information that you may submit to that site.
10 Security of personal information
We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Your personal information held by us will be stored in a secure environment, and accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
We will destroy or de-identify personal information in circumstances where the persona information is no longer reasonably required, unless we are otherwise required or authorised by law to retain the information.
11 Access and correction
We take steps reasonable in the circumstances to ensure personal information we hold is accurate, up-to-date, complete, relevant and not misleading.
Under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Siltrax. If at any time you would like to access or correct the personal information we hold about you, or you would like more information on about our approach to privacy, please use the contact details set out in this policy below. We will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information, you may need to provide us with reasonable evidence or proof that you are entitled to access that personal information (such as verifying your identity, or authorisation). We also ask that you are reasonably specific about your information request.
We may also charge you a reasonable administration fee, which reflects and will not exceed the cost to Siltrax for providing access in accordance with your request.
12 Contacting Siltrax[HW13]
For further information, enquiries or complaints regarding your personal information or this privacy policy, or if you would like to opt-out of receiving any promotional or marketing communications, please contact us using our online submission form (available here: https://www.siltrax.net/contact/) or using any of the following contact details:
| Email: | [email protected] |
| Post: | PO Box Q285 QVB Post Office Sydney NSW 1230 |
13 Privacy complaints
Please direct all privacy complaints to Siltrax using the contact details set out above. At all times, your privacy complaints will be treated seriously and dealt with in a confidential manner (where possible).
We will acknowledge your complaint within 14 days of receipt and endeavour to resolve it within one month, unless we inform you otherwise and seeks your agreement in writing.
We will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which we will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.
[HW1]Note to Siltrax: We have assumed that Siltrax is either subject to the Privacy Act, or wishes to comply with the Privacy Act.
We note there are limited exceptions from requirements to comply with the Privacy Act, including for organisations with an annual turnover of less than $3 million.
[HW2]Note to Siltrax: Please consider this section carefully and advise if there are any other kinds of personal information which Siltrax may collect.
[HW3]Note to Siltrax: We have assumed that Siltrax will not collect ‘sensitive information’ for the purposes of the Privacy Act.
Sensitive Information is defined at section 6 of the Privacy Act 1988 (Cth), and includes medical or health information, religious or cultural information, criminal records, political opinions or associations, etc.
Please confirm whether Siltrax is likely to collect sensitive information.
[HW4]Note to Siltrax: Please consider this section and let us know if there are any other methods that Siltrax may use to collect personal information.
[HW5]Note to Siltrax: Please consider this section and let us know if there are any other purposes / uses which Siltrax may have for personal information.
[HW6]Note to Siltrax: Marketing activities are specifically regulated under the Privacy Act (see APP 7) – we have inserted a general marketing activities section here, however please advise if Siltrax is likely to engage more directly in marketing activities using personal information (such as marketing communications).
The spam Act 2003 (Cth) may also be relevant to any marketing communications of Siltrax.
[MS7]This is fine but we are unlikely to do any of this at the present moment.
[HW8]Noted, thank you for confirming. Even though Siltrax does not engage in this activity, section 5 can remain in case Siltrax ever does.
[HW9]Note to Siltrax: Please consider this section and let us know if there are any other persons / entities to whom Siltrax may disclose personal information.
[HW10]Note to Siltrax: Disclosure of personal information to locations outside of Australia are specifically regulated under the Privacy Act (see APP 8).
In this section, we have assumed that Siltrax will not send any personal information overseas. If Siltrax is likely to send personal information overseas, please advise (including the likely overseas locations and reason for the overseas disclosure) and we can adjust this section.
[MS11]It is possible that customer information and needs will be communicated between Siltrax Pty Ltd and its Chinese OEM (under same parent group) in order to fully cater to the customers needs.
[HW12]Noted, thank you for confirming. We have amended this clause to reflect your instructions.
[HW13]Note to Siltrax: Please insert reasonable contact details (we generally recommend at least a postal and email address which is monitored)