PTN Global Privacy Policy

Updated: 15 October 2020
  1. About this Privacy Policy

    1. This Privacy Policy describes how PTN Global Pty Ltd ABN 22 631 660 118 (we, us and our) manages personal information about our customers, visitors of our website and individuals whose data is processed by the PTN Global website at www.ptnglobalcorp.com  All such individuals are referred to in this Privacy Policy as "data subjects". 

    2. This Privacy Policy describes:​​

      • ​The period for which we store personal information;

      • A data subject’s right to access, rectify or to request erasure of personal information;

      • A data subject’s right to withdraw consent to our collection and use of your personal information;

      • A data subject’s right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC);

      • Why we collect and process personal information, the types of personal information that we collect and process and who we disclose it to;

      • Details of the security measures that we take to help protect personal information; and

      • Other information about how we collect, use and disclose personal information.

    3. ​We are committed to complying with our privacy obligations in accordance with the Australian Privacy Principles contained in Schedule 1 to the Privacy Act 1988 (Cth).​​​​

    4. If we decide to change this Privacy Policy, we will post the updated version at PTN Global Website www.ptnglobalcorp.com/privacy and notify you of such updates to the email account notified by our data subjects to us. Our policy is to be completely transparent about our privacy practices.
       

  2. Personal Information we may collect and process:

    1.  We may collect information at our websites such as: (a) Directly (e.g when you provide information such as your name, email address, designation, company, country and telephone number, to request for a quotation or register to feedback on a forum website); and (b) indirectly (e.g, through our website’s technology, we would collect certain information such as your IP address, demographics, your computers’ operating system, and browser type).
       

  3. Customer responsibility for data subject privacy

    1. Our customers, visitors and partners are required to comply with all applicable privacy laws.

    2. We rely on our customers to obtain all relevant privacy consents and authorisations from data subjects required by law, in order for the personal information that is entered into the PTN Global website to be collected, disclosed and otherwise processed by us.

    3. We also rely on our customers to ensure that all personal information of their data subjects held by us is accurate, up to date, complete, relevant and not misleading.
       

  4. How we collect personal information

    1. Our policy is to not collect personal information by means that are unfair or unreasonably intrusive in the circumstances.

    2. We collect personal information about data subjects in one or more of the following ways:

      • when a visitor enters personal information in to PTN Global Website.

      • when a customer provides personal information to us.

      • publicly available records and registries, online searches and any other third-parties data sources that voluntarily disclose it to us.

      • when it is voluntarily disclosed to us (such as via telephone, surveys, e-mail and online forms).
         

  5. How we use customer and data subject personal information

    1. We use customer and data subject personal information for the following purposes:

      • to deliver software services for the purposes of fulfilling our obligations under our customer contracts;

      • by hosting personal information on our servers that may incorporate personal information;

      • in the course of providing support services (when receiving technical support calls or when accepting enquiries, requests or orders for new services);

      • when employing staff and engaging contractors and when interviewing staff and contractors;

      • through the use of cookies on the PTN Global website;

      • when processing orders for our products and services; and

      • in order to identify members when contacted with questions or concerns regarding our products and services;
         

  6. How we hold and secure personal information

    1. We hold and store personal information that we collect in our offices, computer systems and third party owned and operated hosting facilities for a period of 7 years following the termination of any contract with a customer for information collected using the PTN Global website. For personal information not collected using the PTN Global website, we will hold and store such personal information for a period of 7 years following the date that we first collected the information. In particular:

      • We hold data collected via the PTN Global website in hosting facilities operated by reputable hosting providers;

      • personal information that is provided to us via email is held on our servers or those of our cloud-based email providers;

      • we use third party owned cloud-based marketing platform providers to hold personal information about current and prospective customers;

      • personal information is held on computers and other electronic devices in our offices and at the premises of our personnel;

      • we hold personal information that is provided to us in hard copy in files on our business premises.

    2. We take reasonable steps to protect personal information that we hold using such security safeguards as are reasonable in the circumstances to take against loss, unauthorised access, modification and disclosure and other misuse and to implement technical and organisational measures to ensure a level of protection appropriate to the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.

    3. We:

      1. ensure all staff and contractors are aware of their information security responsibilities and that they are appropriately trained to meet those responsibilities;

      2. use SSL encryption on our systems;

      3. implement anti-virus and security controls for email and other applicable computer software and systems;

      4. have data backup archiving, data breach response plans and disaster recovery processes in place;

      5. implement passwords and access control procedures into our computer systems;

      6. perform audit tracking of personal detail read/updates;

      7. maintain other electronic (e-security) measures for the purposes of securing personal information, such as passwords, anti-virus management and firewalls

      8. maintain physical security measures in our buildings and offices

      9. ensure that data centres that we engage:

        1. undertake server security hardening services;

        2. employ strict security policies and visitor access management;

        3. keep entry points to a minimum to ensure full visibility of those entering the facility;

        4. use surveillance cameras and security barriers to keep unwanted intruders out;

        5. operate a strict access policy for all those on-site;

        6. implements DDoS prevention systems and 24/7 network monitoring;

        7. have extensive data backup and restoration facilities;

        8. implement two-factor authentication Access Control Systems in place to protect data from employee negligence or malicious activities; and

        9. incorporate a digital Visitor Management Solution to provide full visibility and accountability for any third party contractors or visitors who may require ad hoc access.

      10. with respect to personal information that we no longer require or where we are otherwise required to destroy it under applicable law, we ensure that such personal information is securely destroyed.
         

  7. Disclosure of personal information

    1. We only disclose customer and data subject personal information that we collect to third parties as follows:

      1. where required under a contract with a customer, we will transmit data subject personal information to third parties on behalf of the customer;

      2. when performing contracts we may outsource certain obligations to third party contractors such as professional service providers in accordance with our contractual rights. Professional services carried out by them may require access to customer and data subject personal information;

      3. when providing information to our legal, accounting or financial advisors/representatives or insurers, or to our debt collectors for debt collection purposes or when we need to obtain their advice, or where we require their representation in relation to a legal dispute;

      4. where a person provides written consent to the disclosure of their personal information;

      5. where it is brought to our attention that specific personal information needs to be disclosed to protect the safety or vital interests of any person;

      6. to avoid prejudice to the maintenance of the law by any public sector agency, including the prevention, detection, investigation, prosecution, and punishment of offences;

      7. for the enforcement of a law imposing a pecuniary penalty;

      8. for the conduct of proceedings before any court or tribunal (being proceedings that have been commenced or are reasonably in contemplation); or

      9. where required by law.

    2. Customers who use the PTN Global website to disclose personal information about data subjects to third parties are expected to only do so where permissible under applicable law.
       

  8. Third party websites

    1. The PTN Global website may include links to third party websites. Our linking to those websites does not mean that we endorse or recommend them. We do not warrant or represent that any third-party website operator complies with applicable data protection laws. Customers and data subjects should consider the privacy policies of any relevant third-party website prior to sending personal information to them.
       

  9. Interacting with us without disclosing personal information

    1. If a person does not provide us with their personal information, they can only have limited interaction with us. For example, a person can browse our public facing website without providing us with personal information such as the pages that generally describe the services that we make available. However, when an organisation enters into a contract with us, or a person submits an enquiry to us, we need to collect personal information for identification purposes, so that we can provide our services, and for the other purposes described in this Privacy Policy.

    2. Any person has the option of not identifying themselves when contacting us to enquire about our services.
       

  10. Offshore disclosure

    1. We may disclose personal information to our offshore service providers and personnel who assist us with providing our services and to assist us with the operation of our businesses generally. We will take reasonable steps to ensure that such overseas recipients do not breach the Australian Privacy Principles in relation to personal information.
       

  11. Our contact details

    1. Any person who wishes to contact us for any reason regarding our privacy practices or the personal information that we hold about them, or make a privacy complaint, may contact us using the following details: PTN Global Pty Ltd contact@ptnglobalcorp.com 

    2. We will use our best endeavors to resolve any privacy complaint with the complainant within a reasonable time frame given the circumstances. This may include working with the complainant on a collaborative basis or otherwise resolving the complaint.

    3. If the complainant is not satisfied with the outcome of a complaint or they wish to make a complaint about a breach of the Australian Privacy Principles, they may refer the complaint to the Office of the Australian Information Commissioner who can be contacted using the following details:
      Telephone: 1300 363 992
      Email: enquiries@oaic.gov.au
      Address: GPO Box 5218, Sydney NSW 2001