Background and scope

This privacy policy applies to the collection, storage, use and disclosure of personal information by or on behalf of DPM Conferencing Pty Ltd trading as Communication Link (ABN 49 081 231 629) (referred to in this policy as “Communication Link”, “our”, “we” or “us”). Please read it carefully.

We are committed to protecting your personal information, and ensuring its privacy, accuracy and security. We handle your personal information in a responsible manner in accordance with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles (APPs).

By using any of our products or services, visiting our website (communicationlink.com.au) or giving us your personal information, you agree to your information being collected, stored, used and disclosed as set out in this Privacy Policy.

What is ‘personal information’?

This policy applies to all personal information we collect. References in this policy to ‘personal information’ or ‘sensitive information’ have the same meaning as in the Privacy Act:

  • ‘personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form. This may include (without limitation) an individual’s name, postal or email address, telephone number, driver’s license, date of birth, image and financial details;
  • ‘Sensitive information’ is a subset of personal information and includes information or an opinion about an individual’s: racial or ethnic origin, political opinions and associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a union, sexual preferences or practices, criminal record, biometric, genetic information or health related information.

 

Collection of personal information

We only collect personal information by lawful and fair means. We may collect your personal information from a range of sources, including from you, recruitment agencies, contractors, business partners and government agencies. For example, we may collect your personal information when you:

  • engage with us to request, use or acquire a product or service from us;
  • provide a service or product to us;
  • apply for employment or work experience with us;
  • communicate or request information from us via our website, apps, online forms, by e-mail and/or attachments, surveys, telephone, in person, in writing or via other electronic means;
  • when you visit the Communication Link website, or use our other online resources, we may collect information from your electronic devices by use of cookies, single pixels tags and similar tracking technologies, including a range of tools provided by third parties such as Facebook and Google, to collect or receive information.

Wherever reasonable and practicable, we collect personal information directly from the individual to whom the information relates. However, we may also collect personal information from third parties including:
our service providers;

  • third party companies, related entities or agencies, such as referral partners (such as those who refer your business to us), credit reporting bodies, law enforcement agencies and other government entities;
  • employees, related companies or your representatives;
  • from publicly available sources of information;
  • advertisers;
  • recruitment agencies;
  • contractors and business partners;
  • through someone else who has provided us with your information; and/or
  • when legally required to do so.

If you provide personal information about someone other than yourself, you agree that you have that person’s consent to provide the information for the purpose for which you provide it to us. You also agree that you have told the person about this Privacy Policy and where to find it.

 

Do you have to disclose your identity when dealing with us?

Where lawful and practicable, we will give you the option of interacting with us anonymously or using a pseudonym. However, in some cases this may not be possible.

 

What types of information do we collect?

The personal information we collect includes:

  • names, addresses, e-mail addresses, phone numbers, other contact details, payment details, resume and occupation, photographs, and other information to assist us in conducting our business, and providing and marketing our products and services;
  • information about staff and directors, as required in the normal course of human resource management and the operation of a business;
  • and information about current and previous suppliers and clients with whom Communication Link has dealings.

We will only collect your sensitive information:

  • if you have consented to us doing so;
  • or where required or permitted by law.

The information collected and used may include your Internet Protocol (IP) address; domain name; browser type; date and time of your request; your internet service provider, mobile carrier, or data services provider; and your online behaviour, such as information on the pages you visit, links you click, features you use, how and when you interact with the services, the content, images and advertisements you select. If you use a mobile device to access our websites or online resources, we may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile websites and other mobile resources. Most internet browsers and mobile devices can be set to inform you when tracking technologies are being used or sent to your device. They also provide you with the option of refusing the use of tracking technologies, however, this may negatively impact the display or function of certain areas or features of our services.

How and why do we use personal information?

We use your personal information for the purpose for which it was provided to us, for related purposes or as required or permitted by law. Such purposes include:

  • in the ordinary course of conducting our business. For example, supplying or acquiring products and services, responding to your enquiries and feedback, and providing information or communicating with you about our events, news, publications, products and services that may be of interest to you, including but not limited to, by email, mail, SMS or phone;
  • to manage and enhance our services (such as for market research, product and service development);
  • to conduct surveys, promotions or competitions, including for or on behalf of selected third parties;
  • to provide as part of statistics, insights or business data to third parties or to use internally in our business;
  • performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
  • employment-related purposes, such as recruiting and providing services to staff;
  • other purposes related to or in connection with our business, including meeting our legal and contractual obligations to third parties and for internal corporate governance purposes;
  • as part of a sale (or proposed sale) of all or part of our business;
  • to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
  • as otherwise required or permitted by any law (including the Privacy Act).

If you do not provide your personal information, we may not be able to supply the requested product or service, employ you or otherwise deal with you.

 

Use of personal information for marketing purposes

Communication Link may collect and use personal information (other than sensitive information) to promote and market third parties’ or our own products and services, promotions and upcoming events. This may occur for example, by way of direct mail, telemarketing, targeted digital advertising, SMS, MMS messages and notifications and alerts to your mobile device. Communication Link will only send you such marketing information if:

  • you have indicated your consent to receiving such information;
  • such information is related to the purpose for which Communication Link originally collected the personal information; or
  • when otherwise permitted to do so under relevant laws. Communication Link may send marketing information to keep you informed of our products and services, promotions, special offers, recruitment opportunities and the like which we consider may be of interest to you.

Communication Link may use external service providers to assist us in these marketing activities.

Opting Out

You may, at any time, opt out of receiving direct marketing communication by following the directions in our direct marketing material. For example, by using the unsubscribe facility in our email correspondence, the opt-out facility for SMS messages, or at any time by contacting us and requesting that we no longer send you marketing or promotional material, (see contact information below).

 

Disclosure of personal information

General disclosures

We may disclose, and you consent to us disclosing, your personal information to third parties:

  • that are authorised by you to receive information we hold;
  • engaged by us to provide products or services, or who undertake functions or activities which help us to operate our business or to provide a product or service to you. For example, processing payment information;
  • that are our business partners, joint venturers, partners or agents;
  • information technology service providers, our legal, accounting, financial or other professional advisors;
  • as part of a sale (or proposed sale) of all or part of our business. For example, we may disclose information to our external advisers, to potential and actual bidders and to their external advisors; or
  • as required or permitted by law or as is reasonably required to enforce the law, or for enforcement related activities conducted by or on behalf of an enforcement body

If we disclose your personal information to a related corporate body, your information will be collected, stored, used and disclosed in accordance with this Privacy Policy and the APPs.

 

Use or disclosure of sensitive information

We will only use or disclose your sensitive information for the purpose for which it was initially collected or for a directly related purpose, as required or permitted by law, or where you consent to the use or disclosure.

 

Security

Communication Link will take reasonable steps to protect your personal information from misuse, interference, loss and from unauthorised access, modification or disclosure and monitor that it is accurate, up-to-date and, when used or disclosed, that personal information is relevant to the purpose for which the information is being used or disclosed. Such reasonable steps include:

  • physical security over paper-based and electronic data storage and premises;
  • computer and network security measures, including use of password access and secure servers;
  • restricting access to your personal information to employees and those acting on our behalf who are authorised and on a ‘need to know’ basis;
  • retaining your personal information for no longer than it is reasonably required, unless we are required by law to retain it for longer; and
  • entering into confidentiality agreements with staff and third parties as appropriate.

Your personal information is held on secure servers or in storage located in controlled environments. Communication Link employees and service providers are required to maintain the confidentiality of any personal information held by us. Communication Link is not responsible for the privacy or security of third party websites that you access via links on the Communication Website.

Destruction and de-identification of personal information

Where we no longer require your personal information, including where we are no longer required by law to keep records relating to you, we will take reasonable steps to ensure that it is de-identified or destroyed. We securely dispose of hard copy information using a paper shredder and we permanently delete electronic information which we no longer require.

 

Access and correction of your personal information

You are able to access your personal information that we hold, with some exceptions as allowed by law. You may request details of the personal information that Communication Link holds about you by contacting our Privacy Officer (see details below) and we will assess your request and provide you with a response, usually within 10 working days. A copy of your personal information will generally be made available to you within 30 days unless there is an exception which applies under the Privacy Act. We may also require personal identification from you before providing you with any requested details. We reserve the right to charge a reasonable fee for the provision of this information.

If we refuse your request, or if we refuse to give you access in the manner you requested, Communication Link’s policy is to provide you with written confirmation of the reasons for our refusal and the available complaint process.

We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. However, we rely on you to advise us of any changes or corrections to the information we hold about you.

If you consider that any personal information we hold about you is inaccurate, incomplete or out of-date, please contact our Privacy Officer. It may take up to 30 days to update our records.

If we do not agree with the corrections you have requested (for example, because we consider that the information is already accurate, up-to-date, complete, relevant and not misleading), we are not required to make the corrections. However, where we refuse to do so, we will give you a written notice setting out the reasons.

 

Complaints

If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact our Privacy Officer using the details below. You will need to provide us with details of your complaint, as well as any supporting evidence and information.

We will endeavour to deal with your complaint and take any steps necessary to resolve the matter promptly, but usually within 10 business days.

If you are not satisfied with our response or the outcome of your complaint, you may discuss your concerns with or complain to the Office of the Australian Information Commissioner via www.oaic.gov.au.

Variations to this Privacy Policy

We reserve the right to review and update this Privacy Policy or any part of it from time to time, including taking account of new or amended laws, new technology and/or changes to our practices or operations. All personal information held by us will be governed by the most recent updated Privacy Policy.

Please review this Policy periodically for changes. Your continued use of our website, products or services, requesting our assistance, or the provision of further personal information to us after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy. Any updated versions of this policy will be placed on our website at communicationlink.com.au This Privacy Policy was last updated December 2020.

How to contact us

If you have any questions about this Privacy Policy, please contact The Privacy Officer via info@communicationlink.com.au or (02) 6185 3301.