THE-LOWDOWN GROUP PTY LTD (ABN 35 606 116 821) (TLD), aims to protect the privacy of the Personal Information that we collect and hold while carrying out our activities. This is an important policy goal for TLD.

TLD is bound by the Australian Privacy Principles (Principles) established under the Privacy Act 1988 (Cth) (Act). TLD is also bound by data protection, privacy or other data security laws, ordinances and/or regulations applicable and in force in the respective jurisdiction in which it may operate from time to time (Data Protection Laws). This Policy has been developed as part of TLD’s efforts to achieve its policy goal and to comply with its obligations under those Data Protection Laws.  

Personal Information is any information or opinion that is capable of identifying a person.

This Policy applies to Personal Information collected from and about staff, clients, potential clients, previous clients, suppliers, event and exhibition participants and any other person who’s Personal Information TLD may collect from time to time. 

This Policy explains:

• what types of Personal Information we might collect;
• how we aim to use Personal Information;
• when we will disclose Personal Information to others;
• how we manage, store, retain and secure Personal Information;
• how you can access and seek to correct Personal Information that we hold about you; and
• how you may make a complaint if you think that we have breached applicable Data Protection Laws.

This Policy does not form part of any contract (except to the extent that we expressly specify that it does).

From time to time, we may review and update this Policy – for example, to reflect changes to the law, technology or our companies. You should check the version of this Privacy Policy available on our websites periodically to read about any updates.

1. What types of Personal Information do we collect?

TLD aims only to collect ‘Personal Information‘ (or personal data‘ as defined under applicable Data Protection Laws) that is reasonably necessary for its activities.  The types of Personal Information that we collect will depend on the nature of the interaction between you and TLD, and where and how we collect the information. 

Personal Information collected by TLD includes but is not limited to:

• information about
  • clients and potential clients, including bank account details (to the extent they include Personal Information);
  • visitors which register in relation to events, promotions or other TLD activities  or on an TLD website or a website established or administered by TLD,(collectively called (Clients and Visitors), including names, addresses, email addresses, telephone and fax numbers and other contact details, details about their company or industry and also information about their use of TLD’s services;
• information about job applicants and staff members;
• details of other people who come into contact with TLD such as suppliers, subcontractors and other service providers (collectively called (Suppliers); and
• information about names, addresses, roles, and means of communication with and personal attributes of officers, employees and other representatives of corporations and individuals that TLD deals with (collectively called (Personal Representatives).

If some information that TLD requests is not provided, TLD may not be able to provide you with services or engage you to work for TLD.

Some of the information we collect is ‘sensitive information’ (as defined under applicable Data Protection Laws), including age, colour, marital status, membership of a professional or trade association, racial or ethnic origin, philosophical, political or religious beliefs (or others of a similar nature) or affiliation, physical or mental health, genetic or sexual life, or commission (whether alleged or not) of an offence of any other personal data as determined by the authorities. 

We will aim to only to collect sensitive information (as defined under applicable Data Protection Laws) from you where this is explicitly consented to by you and reasonably necessary for our activities, or if the collection is required by law or a court or tribunal order, or if the information has been deliberately made public by you, and only to share sensitive information if TLD believes that its use, processing or disclosure is necessary:

• to lessen or prevent threats to health, life or safety, or protect the vital interests, of any individual;
• for medical purposes, undertaken by (a) a healthcare professional or (b) a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if that person were a healthcare professional;
• to investigate unlawful activity or serious misconduct within or connected with its business;
• to assist enforcement bodies, such as the police, with their activities;
• to assist in locating a missing person;
• to establish, exercise or defend a legal or equitable claim or rights, or obtain legal advice;
• for the purpose of or in connection with legal proceedings
• for the administration of justice for the exercise of any functions conferred under any applicable law; or for any other purpose allowed under applicable Data Protection Laws;
• to exercise or perform any right or obligation which is conferred or imposed by law on us in connection with employment; and/or
• for the purpose of confidential alternative dispute resolution.
  
  2. How do we collect your Personal Information?

We usually collect Personal Information directly from you, for example when you send us correspondence by e-mail or in writing, deal with us over the telephone or in person, contact us, request a quote or information, provide online feedback, or register or provide contact details in relation to an event, promotion or other activity through one of our websites or mobile apps established or administered by TLD (Websites). 

We do not collect Personal Information from visitors on our Websites other than what is supplied to us on a voluntary basis or technical information as set out in this Privacy Statement.

Sometimes, someone else may provide us with Personal Information about you, with or without your direct involvement.  For example, we might collect your Personal Information from:

• your employer if it provides your contact details;
• another organisation of which you are a member;
• a contractor or supplier;
• your representative;
• publicly available sources of information (such as telephone directories or websites); or
• commercially available mailing and marketing lists.
  
  3. How do we use your Personal Information?

Information of Clients and Visitors, Suppliers and Personal Representatives

Personal Information is collected from Clients and Visitors, Suppliers and Personal Representatives, to enable TLD to conduct its business. The purposes for which TLD uses Personal Information of Clients and Visitors, Suppliers and Personal Representatives include (but are not limited to):

• to provide them with its services and/or products;
• to improve and develop its services and/or products;
• to provide ongoing support or help to manage its products, for example if they have a query;
• to communicate with them;
• to provide information about other products or services that TLD considers would interest them (which they can tell TLD not to do at any time);
• to help TLD run its business, for example to improve its products or services or its security, train staff or undertake marketing activities; and
• to comply with its legal obligations.

If we collect your Personal Information to be used for any other purpose, we will generally let you know that purpose at the time we collect the information.

Information of job applicants and staff members 

TLD collects Personal Information of job applicants and staff members for the primary purpose of assessing and (if successful) engaging the applicant or staff member as the case may be.

The purposes for which TLD uses Personal Information of job applicants and staff members include:

• comparing against job specification or criteria and assessing suitability for employment and generally for the processing of employment application;
• internal and external investigations including disciplinary, grievance, and regulatory issues, and carrying out checks such as medical and police record checks;
• managing individual’s employment or engagement and the provision of employee references;
• insurance purposes;
• ensuring that it holds relevant contact information;
• intra-group communications, and strategic, financial and business planning and operations within TLD and its parent companies;
• monitoring compliance with legal requirements, internal rules or contractual obligations of TLD;
• human resources management purposes, such as: on boarding, the planning and implementation of staffing and training, performance assessments, promotions, transfers, secondments and other career-related matters; the review, implementation and administration of our staff benefits, payroll administration and termination; and
• other purposes directly relating to any of the above.

Direct Marketing

TLD may also use Personal Information in order to provide certain individuals with information about other promotions, products or services that it believes would be of interest. If you change your mind about receiving such communications email us at any time at: info@the-lowdown.com. Your request may result in certain consequences which we will notify you of upon receipt of your request, for example, TLD may not be able to provide you with certain services that you have requested. After your request has been processed, we may still contact you for other purposes in relation to the goods or services provided by TLD to you or as set out in other sections of the Privacy Policy.

When and how will we disclose your Personal Information to others?

TLD aims to confine its disclosure of Personal Information to the primary purpose for which it has been collected, or for a related purpose.  This means TLD will usually only disclose Personal Information in connection with its business and administrative functions, including when disclosure is necessary to provide you with a product or service that you have requested, help us with the running of our organisation, or for security reasons.

Sometimes we may also disclose your Personal Information outside TLD for the purpose for which the information was collected or for a related purpose – for example when disclosure is necessary to provide you with a product, service or activity you have requested, help us with the running of our organisation, or for security reasons or comply with the law.

We may provide your Personal Information to:

• our clients in relation to their business;
• outsourced subcontractors, service providers and other suppliers and agents who perform functions on our behalf, such as organisations providing marketing related goods or services, banking or financial services, internet hosting services, cloud based applications or data networks, security services, audit services, legal services, insurance services, market research services and email or mail handling services, and representatives and agents who sell or promote goods and services on our behalf;
• anyone authorised by you to receive your Personal Information (your consent may be express or implied and can be withdrawn at any time);
• anyone to whom we are required by law to disclose Personal Information.

We aim to ensure that such third parties only use your Personal Information for the specific purpose for which it was given to us and to protect the privacy of your Personal Information.  Transfer of your Personal Information will be made for one or more of the purposes specified above, and in this regard to the extent that it is a requirement to do so in the relevant jurisdiction, we will obtain your consent to the transfer of your Personal Information for any of the purposes above outside of the jurisdiction that you are based in prior to collection or sharing of your information.

We do not sell Personal Information. We may share anonymous or aggregated information which does not identify individuals and cannot be recovered, with third parties.

Data Storage

The headquarters of TLD is located in Australia. TLD stores Personal Information on servers and a cloud based network with all servers currently located in Australia but which in the future may be located in an overseas country and as a result may comprise a transfer outside of your jurisdiction under the Data Protection Laws applicable to your Personal Information.

TLD websites

When you visit the public pages of our Websites, our Website servers make a record of your visit and log the following information;

• your  Internet Protocol address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);
• search terms used;
• the operating system and Internet browser software you are currently using; and
• the data that you download (such as web pages or other document files or software), and the time that you download it.

This information cannot be used to identify you and is only used for statistical purposes to help us identify what parts of our website our users visit the most, which in turn assists us to determine how to improve our services.

If you contact us, register through any of our Websites or email us, TLD aims to only use your Personal Information to respond to your request or answer your queries. We may also add your email address to our mailing list; however you can let us know if you change your mind about receiving information about TLD, our promotions, products and/or services.

TLD uses ‘cookies’ in the secure section of our Websites, which are a mechanism to keep track of certain information between visits to the site by the same user. Our websites use cookies to make the browsing experience more responsive when accessing some services on the websites. The information that we collect and analyse includes your computer and connection information such as browser type and version, browser plug-in type and version, operating system, language selection. This information is not linked to any Personal Information and cannot be used to identify the user. You can adjust your web browser’s settings to detect or disable cookies if preferred.

We use two types of cookies. A session cookie expires when you close your browser. A permanent cookie remains on your hard drive until it expires or until the computer user logs out from our Website. You can also remove permanent cookies by following directions provided in your Internet browser’s “help” file. The “help” feature in most browsers provides information on how to prevent your browser from accepting new cookies, how to turn on the notification for new cookies, and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or by visiting the Website of the add-on’s manufacturer. As cookies allow you to take advantage of some of the Website’s essential features, we recommend that you accept cookies.

We may also utilise cookies to track the effectiveness of online advertising where applicable. This information is aggregated and does not identify individuals. TLD may use this information to make informed decisions with regard to the purchase of any such online advertising.

It is important that you prevent unauthorised access to your password and your computer. You should always log out after using a shared computer to access our Websites.

Other websites

To the extent that our Websites contain links to sites operated by third parties, including other organisations, those linked websites are not controlled by us and we are not responsible for the data and privacy practices of the site operators. 

TLD may also administer or maintain websites or mobile applications for third parties. Those websites are owned by our clients or other third parties, and those mobile apps are specific to our clients’ or other parties’ and TLD is not responsible for the privacy practices of its clients and other parties.

Before you disclose your Personal Information on any linked websites or any website or mobile app administered or maintained by TLD for a third party, we recommend that you examine the privacy policy and terms and conditions of use of the website or app.

How we manage and secure Personal Information

A Privacy Officer has been appointed to be the Privacy Officer for TLD.

The Privacy Officer is responsible for managing any issues with Personal Information collected by TLD.

TLD staff are required to respect the confidentiality of all Personal Information and the privacy of individuals, and we have directed our staff that Personal Information must be dealt with in accordance with this Policy.

TLD has security systems in place which are intended to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure by the use of various methods including, for example, an IT system which ensures only authorised computers and employees are granted access to our computer network and a security policy which controls what folders and files employees have access to.

If TLD receives Personal Information about you which it did not request and which it does not reasonably require, TLD may destroy or de-identify this information where appropriate.

If you reasonably believe that there has been an unauthorised use or disclosure of your Personal Information, please let us know by contacting our Privacy Officer at: info@the-lowdown.com

Updating Personal Information that we hold about you

TLD aims to keep all Personal Information that we hold accurate, complete and up-to-date. We encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact our relevant Privacy Officer as indicated above.

TLD is required by law to keep some types of information for certain periods of time.  If we no longer require your Personal Information, we have an obligation to destroy or de-identify that information.  TLD reserves the right to retain information for a period longer than that for which it is required to retain the information if TLD considers that it is necessary for its functions, and as long as it is in accordance with the Principles.

How you can access Personal Information that we hold about you

Under applicable Data Protection Laws, you generally have the right to obtain access to any Personal Information which TLD holds about you, to advise TLD of any perceived inaccuracy in that information and to request correction of that information.  There are some exceptions to this right.   

In some circumstances, the applicable Data Protection Laws entitle TLD to deny access, for example, if providing access would impact unreasonably on the privacy of others or prejudice negotiations in which we are involved.  If we do refuse access, we will generally let you know the reasons for our refusal (unless it is unreasonable to do so, in accordance with the Principles).

If you make a request for access to your Personal Information, we may ask you to verify your identity and specify what information you require.  TLD may charge a fee to cover our costs of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, TLD will generally advise the likely cost in advance.

To make a request to access any information that TLD holds about you, please contact our Privacy Officer as indicated above, in writing. 

1. Questions or complaints

If you have any questions or would like to make a complaint about TLD’s compliance with the Principles, please contact our Privacy Officer at: info@the-lowdown.com

1. Minors 

We cannot distinguish the age of visitors to our Websites. If you are a parent or guardian of a minor who has provided us his/her Personal Information without your knowledge and consent, you may request that we remove such information by contacting us.    The age of minors for the purposes of this Privacy Statement is 18 years old except for residents in the following jurisdictions:

• China: 16 years old
• South Korea: 14 years old
• Taiwan: 20 years old

1. Consent

To the extent permissible under applicable Data Protection Laws by using or accessing any of our Websites or providing us with Personal Information:

• you consent to the collection, use and processing of your Personal Information by TLD in the ways described above (which may change from time to time) unless and until you inform us to the contrary. You may submit a request to withdraw your consent at any time by informing us in writing that you withdraw that consent ; and
• you consent to us disclosing your Personal Information to the third parties in the ways described above. You can withdraw your consent at any time by informing us in writing that you withdraw that consent.

If you have provided us with Personal Information of third party individuals, you are required to obtain the individual’s prior consent and you represent and warrant that you had or have their consent or are otherwise entitled to provide their Personal Information to us. By providing us with Personal Information of third party individual(s), you also warrant that the individual(s) is informed of and consents to the terms of this Privacy Policy.

To the extent required by applicable Data Protection Laws:

• TLD or any third party service providers engaged by us will aim to obtain your consent to collect and use your Personal Information at the time of collection;
• TLD will adopt an ‘opt-in’ policy to obtain your express written consent when collecting your Personal Information. You may be asked, for example, to sign a form or tick a box on a Website.

If you do not permit the collection, use, processing or disclosure of some Personal Information as TLD has notified or requests, TLD then may not be able to meet its legal obligations or may not be able to do business with you or engage you to work for TLD.  If that is the case, we will let you know. In most instances, it is obligatory for you to provide us with your Personal Information in order to allow us to satisfy your request or provide you with the service that you have requested. However, you may let us know if you no longer wish to receive marketing, communications, promotional offers, newsletters or any other similar communications from TLD and we will process your request within a reasonable time upon our receipt of your notification.