Renewtrak is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
Renewtrak have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
In addition, where Renewtrak provide services globally, Renewtrak comply with the requirements of regional privacy legislation and guidelines, such as GDPR.
1. What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual.
Renewtrak collect your Personal Information for the primary purpose of providing our services to you, providing services to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
The personal information that we collect about you includes your name, postal and street address, email address, telephone number, profession/role, place of work, information relating to the complaints you have made to us and various personal preferences. We also collect your payment information, such as your credit card or direct debit information and ABN, when you purchase a product or service from us.
Personal Information processed by our Renewals platform is provided to Renewtrak by our clients under contract, and also collected directly when updated via our website and white label services. We don’t guarantee website links or policy of authorised third parties.
When we collect Personal Information directly we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
2How we collect Personal Information
a)Information you provide voluntarily
This is personal information that you choose to provide to us voluntarily, for example when interacting with our websites or using our products and Services. It includes details such as your name, email address, residential address, or other information permitting your identity to be directly or indirectly inferred. It will be apparent to you at the time you provide your information what information is requested, why, and whether the provision of the information is optional or mandatory.
Examples of when you provide information to us:
- Registering for newsletters, a product trial or placing an order
- Completing transactional services and/or payment services
- In discussion when contacted by a sales person
- Registering for products or services purchased
- Using the Renewtrak website
- Participating in customer surveys, advising us of your marketing and communication preferences
- Submitting a job application
- Registering a renewal opportunity
- Updating and/or altering the contact details in a renewal notification
- When requesting to opt-out of the service
b)Personal information we collect automatically
This is information that we collect automatically from the devices of visitors to our websites or users of our Services. This type of information is generally collected for analytics and reporting purposes, to improve advertising and marketing campaigns, and to maintain the security of our products, Services, and websites.
The following are examples of information we collect automatically:
- Log files generated by our websites which contain
- Your IP address
- Your browser version
- The operating system of your device
- Tracking of links through the application
- Diagnostic information
- Authentication credentials
- Most cookies do not collect personal information and only contain coded information that cannot be used by third parties to access your confidential information. Most web browsers allow you to adjust settings to erase cookies, disallow cookies, or receive a warning before a cookie is set.
Please note that some parts of Renewtrak websites may not function fully if you disallow cookies.
We and third parties may also transfer collected information to others if required by law, or where those other parties process the information on our behalf. The services we may use include Google Analytics, Google AdSense, DoubleClick, Yahoo, Adobe, Bing, Kenshoo and Microsoft.
c)Information we receive from third parties
- Sales leads from our joint initiative partners.
- Publicly available sources such as social media websites.
- Third parties that provide Renewtrak with marketing leads.
- Material including renewal data shared with Renewtrak to enable us to provide our services to you.
- Renewal information provided using manual or automated processing systems.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law.
4Information provided by Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Whereby Renewtrak provide a white-label renewals service in many instances we will be provided order and contact “renewal” information by third parties. In such a case our clients providing this information will take reasonable steps to ensure that you consent to being contacted by the renewals service, and Renewtrak will abide by the terms of the confidentiality clauses this renewal data is provided under.
5.Disclosure of Personal Information
Renewtrak may disclose your personal information to the following categories of recipients:
- Third party service providers and partners where the processing of your personal information is a function of providing the service
- To any other third parties where you consent to the use or disclosure
- In the event Renewtrak participate in the process of any third party acquisition or potential acquisition of an interest in us or our assets
- To process a job application including reference and background checks
- Where required or authorised by law.
6.European Union / European Economic Area data subjects and GDPR
EU/EEA data subjects may exercise the rights provided them under the provisions of the GDPR by requesting in writing to the address provided.
- Request erasure or suspension of processing by Renewtrak
- Request access to the personal information processed by Renewtrak
- Resolve inconsistencies in the personal information held by Renewtrak
- To opt out and/or withdraw consent relating to the processing of personal information
- Under certain circumstances, your personal information can be provided to you in machine readable formats for transfer to another controller
Renewtrak will review each request on a case by case basis and respond in accordance with the applicable data protection law.
7.Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.
Renewtrak have legitimate business needs to retain certain data.
This information is retained to comply with our legal obligations, resolve disputes, protect rights and enforce our agreements
Customer names, addresses and order history are maintained for 3 years from the last purchase or order activity unless required as part of accounting records.
Accounting records including invoices, purchase orders and other historical financial records are stored for 7 years for legislated accounting purposes.
Our backup media is protected using security measures including encryption and is disposed of securely when retired.
9.Collection and Use of Data relating to Minors
Renewtrak does not knowingly collect personal information relating to children under the statutory age of majority.
If you believe Renewtrak have recorded children’s personal information, please contact us and we will delete this information on request. We encourage you to talk with your children about communicating with strangers and disclosing personal information online.
10.Collection and Use of Data relating to Minors
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
Renewtrak will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information, we may require further identification from you before releasing the requested information.
If you do not want us to use your personal information for direct marketing, you can let us know at any time through the contact details provided below.
11. International Transfers
Renewtrak use facilities in locations globally including Australia, United Kingdom, USA and Singapore to process information in these regions.
If you are an individual from the European Union or European Economic Area (EEA), the information that we collect from you, including personal information relating to you or Customer Relationship Information that we process in providing a Service, may be transferred to, and processed by, Renewtrak service providers outside the EEA for the purposes described in this Policy.
These affiliates and service providers may be based in territories whose data protection laws are different from those of the country or region in which you are based, but we will always protect your personal information in accordance with this Policy. In addition, we will protect transfers to countries outside the EEA with appropriate safeguards, such as using standard contractual clauses adopted or approved by the European Commission.
Further details can be provided upon request to the address provided below.
12. International Transfers
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Renewtrak have a range of security measures in place to protect the personal information that we hold. For example, those of our web pages that request sensitive information employ encryption technologies such as Transport Layer Security (TLS 1.2+).
You can confirm that a data-entry page uses encryption by checking that:
The page address in the web browser’s tool bar or status bar begins with https://; and
The padlock icon in the web browser’s tool bar or status bar is locked.
If you are considering sending us any personal information by standard email, please be aware that the information may be less secure in transit. We are required by law to take steps to protect the security of personal information once it comes into our possession. Contact Renewtrak stating the nature of the communication and we will provide a secure upload facility to use.
13. Policy Updates
This Policy may change from time to time and is available on our website:
This policy was revised on the 15th May 2019
14. Enquiries, concerns and complaints
If you want to make a complaint about a breach of your privacy by Renewtrak, you can contact us using the contact details at the bottom of this web page. All complaints will be investigated by an appropriately qualified representative. We will endeavour to resolve your complaint as quickly as possible, and in any event within 30 days. If your complaint takes longer to resolve, we will keep you informed of our progress with the investigation. We will let you know the outcome of the investigation, including how we propose to resolve your complaint and what, if any, corrective measures will be put in place.
If you are not satisfied with our handling or resolution of your complaint, you can lodge a complaint with the Office of the Australian Information Commissioner. For more information about making a complaint to the OAIC, visit http://www.oaic.gov.au/privacy/making-a-privacy-complaint.
If you would like to report to us please contact us at:
RENEWTRAK GLOBAL SERVICES PTY LTD
Level 2, 822 George Street,
NSW 2008, Australia