Last modified: 19 October 2021
Online Specialists Pty Ltd (ACN 138 718 528) trading as Affordable Staff (Australian Entity) and Pathcutters Phils. Inc. (Philippines Entity) (together, we, us or our) are committed to protecting your privacy whether you are:
- a user of our services (or representative of a user of our services) (Our Client);
- a client of any of Our Clients (End Client); and/or
- a visitor (Visitor) to our websites on the domains affordablestaff.com.au and pathcutters.ph (Websites).
If you do not provide us with or obtain from Our Clients your personal information (including sensitive information) or you decide to withdraw your consent to our Processing of your sensitive information) we may not be able to provide Our Client with and you may not be able to benefit from our services. As an End Client, if you wish to withdraw your consent, please contact the relevant entity of Our Client at first instance.
1.2 Tax file number information
Our contact details are:
Online support form: Click here (use this option for fastest service)
Telephone: 1300 139 482
Post: Level 1, Suite 391 241 Adelaide Street, Brisbane, QLD, 4000.
Privacy Issues Email: firstname.lastname@example.org
2. What personal information we collect and how
2.1 Personal information we collect from Our Clients
When engaging with you as Our Client to deliver our services we will ask you to provide certain personal information to enable or facilitate our provision of services. We may also collect personal information when you make an enquiry or a request to us or when you otherwise interact with us generally (such as by telephone or videoconference, in person, in interviews or by email).
As one of Our Clients the types of the personal information (including sensitive information) that we may collect about you includes:
(a) your name and role/responsibilities in the business;
(b) your (and/or individual employee) contact details (full name, email address, telephone number, billing address);
(c) your business’ Australian business number (ABN);
(d) login and account information (for our online portal); and
(e) banking information.
2.2 Personal information we collect from Visitors
If you contact us through a Website we will collect your name, email address, phone number and any further personal information you choose to provide to us via the contact form on the Website.
2.3 We may collect personal information indirectly (for example for End Clients)
Where it is reasonable or practical to do so we will only collect personal information about you from you directly.
However, as an End Client we will collect your personal information from Our Clients (i.e. other than from you) in order for us to undertake the Processing and provide our services to them so that they can provide their services to you.
For example, as an End Client, Our Client may collect identification information about you and/or information about your personal and financial circumstances in order to provide you with a service (e.g. mortgage broking, real estate or property management) and Our Client is likely to provide some of this personal information about you to us to perform our services for them.
3. How we use and disclose your personal information
3.1 Why we use your personal information
As Our Client we will only use and disclose your personal information:
(a) to provide you with our services;
(b) to provide you access to our online portal available through our Website;
(c) to create user accounts to access our online portal and services;
(d) to provide technical support or responding to your general queries and enquires;
(e) for our internal research and statistical purposes;
(f) to market our services to you as described in Section 3.3;
(g) and verify and authenticate payments to us; and
(h) for other purposes are required or authorised by law.
As an End Client we will only use your personal information as provided to us by Our Client to provide our services to Our Client.
3.2 Disclosure of your personal information
We maintain a strict personal information ‘barrier’ between the Australian Entity and the Philippines Entity such that:
(a) the personal information of Our Clients is accessible to Australian Entity and Philippines Entity staff; and
(b) the personal information of End Clients is accessible only to Philippines Entity staff, other than in the most exceptional of circumstances.
We also disclose Our Clients’ personal information (including sensitive information):
(a) to Ezidebit Pty Ltd (ABN: 67 096 902 813) and its related bodies corporate to enable the processing payments that you make to us; and
(b) for other purposes are required or authorised by law.
In providing our services we use a number of third party tools including:
(b) Microsoft OneDrive and SharePoint;
(g) Trello; and
3.3 Direct marketing
From time to time we may use Our Clients’ personal information to provide Our Clients with current information about special offers you may find of interest, changes to our organisation, or new and existing products or services being offered by us or any company we are associated with. We will never use End Client personal information for marketing or any purpose other than to provide services to Our Client.
As our Client, if you do not wish to receive marketing information you may at any time decline to receive such information. We will take all reasonable steps to meet your request at the earliest possible opportunity.
4. Security of your personal information
Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. We will use industry best practice processes and take all reasonable steps to protect personal information that we hold from:
(a) misuse, interference and loss; and
(b) unauthorised access, modification or disclosure.
The reasonable measures we take to secure your personal information include:
(a) the use of encryption of in-transit data;
(b) encryption of data at rest;
(c) regular software patching and logging of system access;
(d) strict password management practices;
(e) robust physical security at the premises of the Philippines Entity;
(f) custom security configuration of workstations used by Philippines Entity staff;
(g) periodic deletion of data no longer needed from data storage media; and
(h) proactive network security to detect suspicious activity.
5. Accessing and/or updating your personal information
5.1 How to request access to your personal information that we hold
Subject to certain exemptions and evidence of your identity you have the right to request access to your personal information that we hold at any time by contacting us using the contact details in Section 1.3 above.
Following your request we will contact you within one month from the date of receipt of your request and provide you with the personal information requested, unless we decide to withhold access to the personal information (in which case we will notify you of the reasons for such withholding).
While the above is applicable to End Clients, it will most likely be more straightforward to obtain access to your personal information from Our Client (i.e. the entity to which you originally provided your personal information).
5.2 How to request correction of your personal information that we hold
We request that you ensure that the information you provide to us is accurate and to update your personal information as necessary.
If after receiving your request we choose not to correct your information, we will notify you within one month of the reason of our refusal and the mechanisms available to you to object to our refusal.
If we correct personal information about you that we previously disclosed to a third party, we will take reasonable steps to notify the third party of the correction and to request that they do the same.
Again, while the above applies to End Clients, in practice it will be easier for End Clients to correct your personal information by making the request to Our Client (i.e. the entity to which you originally provided your personal information).
6. Information for Visitors
6.1 Website analytics
As a Visitor, whenever you visit one of our Websites our servers automatically record information for statistical purposes about the usage of the Website such as:
(a) the type of browser you use;
(b) the URL that linked you to our Website;
(c) which pages on the Website you viewed;
(d) the date and time of your visit to the Website; and
(e) the URL you leave our Website to visit.
Our Websites use ‘Google Analytics’, a service which transmits website traffic data to Google servers in the United States. 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 web page usage.
You can customise or opt out of Google Analytics for display advertising using the ads settings for your Google account.
However, this information we collect about you is not personal information. We do not link the anonymous information to any personal information and we will not link a record of your usage of our Website to you.
6.2 Cookies and other tracking technologies
(a) Google marketing platform integrations;
(b) demographic and interest reporting;
(c) display advertising including remarketing and Google display network impression reporting to advertise our services online;
(d) optimising and personalising ad services based on your past visits to our Websites; and
(e) reporting the use of ad services and interactions with ad impressions and how they are related to visits to our Website.
Cookies and other tracking technologies may also be used to support analytics by other third parties.
7.1 Making a complaint
If you make a compliant you need to provide us details:
- explaining what happened, when and how it came to your attention;
- referring to specific breaches of one or more of the Australian Privacy Principles; and
- outlining the outcome you seek.
7.2 Our response
Within 30 days of receipt of your complaint we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.
7.3 What to do if you are not happy with the outcome of our investigation
If you are not happy with the outcome of our investigation of your complaint, you may complain to the Office of the Australian Information Commissioner (OAIC) whose contact details (and further information) can be found at oaic.gov.au.
9. Further information