RTS PauaCo Pty Limited (ACN 617 558 219) trading as True South Seafood (we, our or us) is committed to complying with its obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).
We are committed to respecting your privacy and protecting your personal information. Our staff are trained to protect your personal information in accordance with our policies, procedures and systems.
This policy outlines how we manage and secure your personal information collected through our website. It also describes the kinds of personal information that we hold and for what purposes, and how that information is collected, held, used and disclosed.
This policy is easy to access and is available on our website at http://truesouthseafood.com. You may request a copy of the policy by contacting the Privacy Officer in accordance with paragraph 13.1 of this policy.
Please read this policy carefully before you provide us with any personal information.
We will review this policy from time to time. We encourage you to check our website regularly as any updated policy will be available on our website.
3. Types of information that we collect and hold
3.1. General information
We may collect and hold the following types of personal information about you:
(a) your name, contact details (such as address, email address or mobile phone number); and
(b) any other information that we consider to be reasonably necessary.
3.2. Sensitive information
We may need to collect sensitive information about you. Unless the collection of the sensitive information is permitted under the Privacy Act, we will only collect sensitive information with your consent where that information is reasonably necessary for our functions.
We may collect and hold sensitive information about you which is health information relating to food allergies and/or intolerances.
3.3. Information required by law
We may collect personal information about you because the collection of the information is required or authorised by law or a court/tribunal order.
3.4. Social media
We may collect information about you when you interact with us through social media channels. Please note that we will only interact with you on confidential matters via a secure forum.
4. Collecting your information
4.1. Collecting personal information
We collect your personal information so that we can perform our functions and activities.
We will, if it is reasonable and practical to do so, collect personal information directly from you.
We may collect your personal information when:
(a) you submit an online query through our website;
(b) you use our website to subscribe to any of our updates or marketing; and/or
(c) you send direct messages to us via our social media channels.
4.2. What happens if you do not provide us with your personal information?
If you do not provide us with your personal information, we may not be able to:
(a) verify your identity; and
(b) respond to your enquiry; and
(c) provide you with our subscription materials.
4.3. Unsolicited personal information
If we collect personal information about you that we did not ask for, we will check whether we could have collected that information ourselves. If we could have collected the information, we will handle it in the same way we handle other information we collect from you. If:
(a) we could not have collected the personal information; and
(b) the information is not contained in a Commonwealth record,
we will destroy the information or de-identify the information provided it is lawful and reasonable to do so.
4.4. Notification of collection of personal information
When we receive personal information directly from you, we will take reasonable steps to notify you of the collection and the circumstances that surround the collection.
(a) we collect your personal information from third parties; or
(b) you may not be aware that we have collected your personal information.
If we collect information that can be used to identify you, we will take reasonable steps to notify you of the collection and the circumstances that surround the collection.
5. Protecting personal information
5.1. Storing personal information
We are committed to keeping your personal information secure.
We store your personal information in different ways, including physical and electronic form.
We treat all personal information as confidential. We will take reasonable steps to ensure personal information is protected from:
(a) misuse, interference and loss; and
(b) unauthorised access, modification and disclosure.
5.2. How we store your information
Some of the ways we store your information are:
(a) computer systems;
(b) electronic databases (including cloud-based databases);
(c) digital records; and
(d) hard copy or paper files.
5.3. What happens if we no longer need your personal information?
If we no longer need your personal information for any purpose, we will take reasonable steps to destroy or permanently de-identify the information, unless:
(a) the information is contained in a Commonwealth record; or
(b) we are required by law, or a court/tribunal order, to retain the information.
6. Purposes for collecting, holding, using and disclosing information
We collect, hold, use and disclose your personal information for the purpose it was collected and related purposes, including:
(a) to respond to queries made through our website;
(b) to provide you with subscription services;
(c) subject to paragraph 8 of this policy, to issue direct marketing materials to you;
(d) to comply with any applicable laws, regulations or codes of practice; and
(e) for any other purpose for which you have given your consent.
7. Use and disclosure of information
7.1. Use and disclosure of personal information
We will not use or disclose personal information we hold about you that was collected for a particular purpose for another purpose, unless:
(a) you have consented to the use or disclosure of the information for another purpose; or
(b) the use or disclosure is otherwise permitted under the Privacy Act (e.g. you would reasonably expect us to use or disclose the information for another purpose or the use or disclosure of the information is required or authorised by law or a court/tribunal order).
7.2. Disclosure to third parties
Sometimes we may disclose personal information about you to third parties. Examples of third parties that we may disclose your personal information to include, but are not limited to:
(a) entities in our seafood export and distribution network; and
(b) any other person where you have given your consent.
7.3. Overseas recipients
In some circumstances we may need to disclose your personal information to overseas recipients (e.g. to our related entities overseas and to our cloud-based data storage provider). These recipients are likely to be located in:
(a) New Zealand;
(c) Hong Kong;
(d) Singapore; and
(e) the United States of America.
7.4. Third party data storage
We may store your personal information via third party data storage providers. Our current data storage provider is headquartered in the United States of America. However, as data storage can be accessed from various countries via an internet connection, it is not always practicable for us to know what country your personal information may be held in. As such, disclosures may sometimes occur in countries other than those listed in paragraph 7.3 (Overseas Recipients).
Where your personal information is disclosed, we will:
(a) take reasonable steps to ensure that the overseas recipient does not breach the APPs, unless an exception in the Privacy Act applies; and
(b) seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.
8. Direct marketing
8.1. Direct marketing
We may use or disclose your personal information (excluding sensitive information) for direct marking purposes.
8.2. Sensitive information
We will only use or disclose your sensitive information for the purposes of direct marketing if you have consented to the information being used or disclosed for the purposes of direct marketing.
8.3. Method of direct marketing
We may conduct direct marketing via email.
If at any time you decide you:
(a) do not want to receive any more direct marketing material from us;
(b) do not want us to use or disclose the information for direct marketing in the future; and/or
(c) want to know where we obtained the information,
(d) contact the Privacy Officer in accordance with paragraph 13.1 of this policy; or
(e) opt-out of receiving any more marketing material via any opt-out mechanism contained in our marketing correspondence.
All our marketing correspondence will display a clearly visible and user-friendly opt-out mechanism. We may imply consent to receive direct marketing material if you do not use the opt-out mechanism.
8.5. Processing requests
If you request to no longer receive direct marketing material we will process your request within a reasonable period after the request is made.
9. Quality of personal information
We will take reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and relevant to our functions or activities.
If you believe that your personal information is not accurate, complete or up to date, please contact the Privacy Officer in accordance with paragraph 13.1 of this policy.
10. Access to personal information
10.1. Requesting access
You may at any time request access to personal information we hold about you. We will give you access to that information, unless an exception in the Privacy Act applies.
You can request access to your personal information by contacting our Privacy Officer in accordance with paragraph 13.1 of this policy.
10.2. Dealing with access requests
We will respond to a request for access within a reasonable time (usually 30 days), and give you access in the manner you request, if it is reasonable and practicable to do so.
We may need to verify your identity before we give you access to your personal information.
10.3. Access fees
Depending on the nature of the request, we may charge you a small fee to access that information.
10.4. Refusal to give access
If we refuse to give you access, we will:
(a) take reasonable steps to give you access in a manner that meets our needs as well as yours; and
(b) provide you with the reasons for our decisions as required by the Privacy Act.
11. Correcting personal information
11.1. Requesting correction
If you think that any personal information we hold about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request us to correct the information by contacting the Privacy Officer in accordance with paragraph 13.1 of this policy.
11.2. Correcting information
We will take reasonable steps to correct that information.
11.3. Dealing with correction requests
We will respond to a correction request within a reasonable time (usually 30 days).
We may need to verify your identity before we correct your personal information.
11.4. Notification of correction to third parties
If we correct your personal information that we have previously disclosed to another entity, and you ask us to tell the other entity about the correction, we will take reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.
11.5. Refusal to correct information
If we refuse to correct the personal information, then we will provide you with the reasons for our decision as required by the Privacy Act.
You have the option to remain anonymous, or to use a pseudonym when dealing with us where it is lawful and practical to do so.
13. Complaints about personal information
(a) have any issues about the way we handle your personal information after reading this policy;
(b) become aware of a potential breach of privacy; or
(c) wish to make a complaint,
please contact our Privacy Officer.
Complaints can be made in writing or orally to:
True South Seafood
Telephone: +61 447 362 992
Mail: PO Box 64, Margate, TAS, 7054 Australia
13.2. External complaint mechanism
If you are not happy with the outcome of the Privacy Officer’s investigation or we have not replied to you within a reasonable time, then you can raise your concern with the Office of the Australian Information Commissioner (OAIC).
Complaints can be made to OAIC in the following ways:
Office of the Australian Information Commissioner
Telephone: 1300 363 992
Mail: Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001