BTC.COM.AU PTY. LTD. (ABN: 52 625 367 811) (referred to as BTC.COM.AU PTY. LTD., we, our, us) is bound by the Privacy Act 1988 (Privacy Act), including the Australian Privacy Principles (APPs) and recognises the importance of ensuring the confidentiality and security of your personal information.
'Personal information' means any details about you, from which your identity is apparent or can be uncovered. We may collect and hold a range of personal information about you to provide you with our services. When you register with us, we ask for your information we need to provide you with our service and verify your identity. This includes information such as your full name, email address, street address, phone number and identity verification details (ie: drivers license).
We will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct. Sensitive information is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information.
Generally, we collect personal information directly from you. For example, personal information will be collected through our application processes, forms and other interactions with you in the course of providing you with our products and services, including when you visit our website, use a mobile app from us, call us or send us correspondence. We may also collect personal information about you from a third party, such as electronic verification services (ie: GreenID / VixVerify), referrers, and marketing agencies.
If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services, or meet your needs appropriately. We do not give you the option of dealing anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for BTC.COM.AU PTY. LTD. to deal with individuals who are not identified.
The primary purpose for which we collect, hold, use and disclose personal information is to provide our services to you. We may use and disclose the information we collect about you for the following purposes:
1) to verify your identity;
2) be able to provide you with our products and services;
3) review and meet your ongoing needs;
4) provide you with information we believe may be relevant or of interest to you;
5) let you know about other products or services we offer, send you information about special offers or invite you to events;
6) consider any concerns or complaints you may have;
7) comply with relevant laws, regulations and other legal obligations;
8) help us improve the products and services offered to our customers and enhance our overall business.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.
We also use third parties to collect certain analytics on our site (ie: Google Analytics). We do not pass any personally identifiable information through this function; however the data we collect may be combined with other information which may be identifiable to you. We may also collect information about your computer, including where available your IP address, operating system and browser type, for the purpose of system administration and general security.
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
In connection with the services we provide, we may disclose your personal information to:
1) organisations who help us verify your identity (such as GreenID / VixVerify);
2) organisations we engage to carry out our functions and activities, such as our agents, contractors who supply services to us, or other advisors;
3) organisations involved in managing payments, including payment merchants and other financial institutions such as banks;
4) regulatory bodies, government agencies, law enforcement bodies (including AUSTRAC) and courts;
5) anyone else to whom you authorise us to disclose it or is required by law.
We may also disclose the following personal information in order to comply with our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF obligations):
1) your name;
2) date of birth; and
3) residential address.
We may, upon request and at our own discretion, provide you with an alternative method of verification, however, any alternative verification method must also comply with the AML/CTF legislation. We do not sell, trade, or rent your personal information to others.
In some instances, we may disclose your personal information to our data storage provider (such as ones located in the United States of America). We will only do so if we believe they are regulated by laws that protect your information in a way that is similar to the Privacy Act. We will not send personal information to recipients outside of Australia unless:
1) we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act or the APP;
2) the recipient is subject to an information privacy scheme similar to the Privacy Act; or
3) the individual has consented to the disclosure.
If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
We recognise the importance of securing the personal information of our customers. We strive to ensure that your information is safe by using a range of physical and electronic security measures to protect it from misuse, interference, loss, unauthorised access, modification or disclosure. Your personal information is generally stored in our own database, or those of our service providers (including GreenID/VixVerify), in secure data centres, or in the cloud. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
1) the personal information does not include sensitive information; and
2) you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
3) we provide a simple way of opting out of direct marketing; and
4) you have not requested to opt out of receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.
You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date. We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the BTC.COM.AU PTY. LTD. Privacy Officer by emailing firstname.lastname@example.org or by post at Suite 3.07, 100 Collins Street, Alexandria NSW 2015.
We have an effective complaints handling process in place to manage privacy risks and issues. The complaints handling process involves:
1) identifying (and addressing) any systemic/ongoing compliance problems;
2) increasing consumer confidence in our privacy procedures; and
3) helping to build and preserve our reputation and business.
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992, writing to "Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001" or by emailing email@example.com.
1) regulating the collection, use and disclosure of personal and sensitive information;
2) de-identifying personal and sensitive information wherever possible;
3) ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
4) ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.
1) you may access the personal information we hold about you;
2) you may seek the correction of your personal information; and
3) you may ask us to provide an alternative means of identity verification for the purposes of the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);
4) you may complain about a breach of the Privacy Act, including the APPs; and
5) we will deal with a privacy complaint.
Last updated: October 2018
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