Privacy Policy

RedBay Consulting Pty Ltd ACN 134 369 949 (referred to in this document as “RedBay” or “we” or “us” or “our”) is committed to protecting the privacy of your personal information. This privacy policy explains how RedBay manages the personal information that we collect, use and disclose and how to contact us if you have any further queries about our management of your personal information.

RedBay is required by the Privacy Act 1988 (Cth) (Privacy Act) to comply with the National Privacy Principles (NPP) (contained in and subject to the other provisions of the Privacy Act 1988) and the Information Privacy Principles, and after the 12th March 2014 with the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Australian Privacy Principles (APP) which replaces the NPP & Information Privacy Principles and amends the Privacy Act 1988.

The NPPs and APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal. RedBay is also required to comply with the Spam Act 2003 (Cth)

At RedBay we know that when you give us your personal information, it imposes a serious responsibility upon us. We are committed to protecting your personal information and maintaining your trust.

Your acknowledgement of our Privacy Policy

This privacy policy is published on our website and available from our office, as required, in order to meet our obligation under National Privacy Principle 5.1 and under the APP which requires us to set out our policies on the management of personal information in a clearly expressed document which is available to anyone who asks for it.

Without limiting the generality of the above statement, your use of our website constitutes an acknowledgement that you have been made aware of our privacy policies.

This policy does not create or confer upon any individual any rights, or impose upon RedBay any rights or obligations outside of, or in addition to, those rights or obligations imposed by the Privacy Act 1988 (Cth) or related legislation.

Should there be, in a specific case, any inconsistency between this statement and the Act, this statement shall be interpreted, in respect of that case, to give effect to, and comply with the legislation.

This policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation'.

What is personal information?

Personal information is information or an opinion, in any form and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. Examples include an individual's name, address, contact number and email address.

Special provisions apply to the collection of personal information which is sensitive information. Sensitive information includes (for example) information about a person's membership of a professional or trade association.

Collection of personal information by RedBay Consulting

RedBay may collect personal information in a range of ways, including:

• when you provide it directly to us, for example, by submitting it to us via our website, via any electronic or paper forms you submit to us, or by you providing information to our representatives by telephone, email, or any social media networks through which you liaise with us;
• in the course of providing you with a requested product, service or benefit;
• from third party service providers, business partners, including, without limitation, commercial associates or credit reporting agencies;
• from publicly available sources;
• from our records of your use of our services; and
• when we are required to do so by law, for example, when we are required to verify your identity from certain documents before supplying a product, service or benefit to you.

Protection of your privacy and personal information

RedBay takes the protection of your privacy very seriously. This Privacy Policy sets out how we deal with your personal information.

RedBay is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth). As a supplier of telecommunications services, RedBay also has obligations under other laws, regulations and industry codes, including the Telecommunications Act 1997 (Cth).

By using the RedBay website, or by providing any personal information to RedBay, you consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy.

Use and disclosure of personal information by RedBay

If RedBay uses or discloses your personal information for a purpose (secondary purpose) other than the main reason for which it was originally collected (primary purpose), to the extent required by the Privacy Act, we will ensure that:

• the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that RedBay would use or disclose your information in that way;
• you have consented to the use or disclosure of your personal information for the secondary purpose;
• the use or disclosure is required or authorised by or under law; or
• the use or disclosure is otherwise permitted by the Privacy Act (for example, as a necessary part of an investigation of suspected unlawful activity)

We do not share your personal information with other organisations unless you give us your express consent, or where sharing is otherwise required or permitted by law, or where this is necessary on a temporary basis to enable our contractors to perform specific functions.

When we temporarily provide personal information to companies who perform services for us, such as specialist information technology companies or other contractors to RedBay we require those companies to protect your personal information as diligently as we do.

Why does RedBay collect personal information?

RedBay will use the personal information it collects for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy. RedBay will not use your personal information for any other purpose without first seeking your consent, or where authorised or required by law.

RedBay collects uses and discloses personal information about you in order to supply our product or services to you, or for related purposes, for example:

• business planning and product development;
• informing you about ways our product or services, or your use of our product or services, can be improved;
• providing you with marketing and promotional material, including by direct marketing, information about other products and services, including products and services provided by our commercial associates (unless you tell us that you opt-out of the use of your personal information for these purposes, as detailed below);
• billing for your use of our services; administering your use of our product or services;
• reviewing and improving our product or services;
• informing you about problems with our product or services;
• performing credit checks;
• doing anything we are required to do by law or on the direction of a relevant authority, including to assist in connection with legal proceedings, crime or fraud protection, detection and prosecution;
• receiving professional advice, such as legal or financial advice; and
• protecting the safety of you or any member of the public, for example, to avoid an imminent threat to a person’s life.

We may also disclose your personal information to third parties who work with us in our business (located in Australia or overseas) including, without limitation, any of our commercial associates, suppliers and business partners, agents, consultants, professional advisers to help provide, promote or improve the product or services we provide, or where authorised or required to do so by law.

For example, we may disclose your personal information to:

• billing and debt-recovery service providers.

RedBay may also disclose personal information in circumstances where it is authorised or required to do so by law, and in circumstances where we consider it is appropriate to do so in order to ensure laws are complied with, for example, to reduce the occurrence of fraud.

How might we contact you?

We may contact you in a variety of ways, including by post, email, SMS, telephone call or facsimile.

Direct Marketing

We may also use and disclose your personal information to send direct marketing to you from us and/or from third parties including, without limitation, social networking sites, commercial associates, suppliers and business partners, agents, consultants, professional advisers, who work with us to help provide, promote or improve the products or we provide.

The direct marketing may relate to the products and services we provide or the products, and services of other parties or to keep you informed of new developments we believe may be of interest to you.

You may opt-out of receiving this direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication, by going to the RedBay website at http://www.redbay.com.au/subscribe or e-mail to admin@redbay.com.au or calling +617 3206 7774.

Data quality and security

To the extent required by the Privacy Act, RedBay will take reasonable steps to:

• make sure that the personal information that we collect, use and disclose is accurate, complete and up to date
• protect the personal information that we hold from misuse and loss and from unauthorised access, modification or disclosure
• destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act

Transfer of personal information overseas

If RedBay transfers your personal information outside Australia, RedBay will comply with requirements of the Privacy Act that relate to trans-border data flows.

Links to other sites

The RedBay website contains links to other sites. We are ultimately not responsible for the privacy practices or the content of such websites, we encourage you to read and understand the privacy policies on those websites prior to providing any information to them.

Access and correction of your personal information

If there are any errors in the personal information we hold about you, or if you tell us that any of your personal information has changed (for example, your address), we will correct and update the information we hold about you.

At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception to the Privacy Act 1998 (Cth) applies.

We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.

Please contact RedBay if you would like to obtain a record of your personal information that we hold.

Further information

Please contact RedBay if you have any queries about the personal information that RedBay holds about you or the way we handle that personal information.

RedBay details for privacy queries are set out below.