ZIPLINE.IO PTY LTD (AustralianCompany Number (ACN) 88 619 791 187) and its related bodies corporate (“Zipline”,“we”, “our” or “us”), are committed to protecting and respecting yourprivacy and will take all reasonable steps to secure the personal informationit holds.
Zipline understandsthe importance of privacy and is committed to collecting and handling personalinformation in accordance with the Australian Privacy Principles (APP’s)contained in the Privacy Act 1998 (Cth) (“Privacy Act”).
1 What kinds of information do we collect?
1.1 The Privacy Act defines“personal information” as information or an opinion, whether true or not, andwhether recorded in a material form or not, about an identified individual, orindividual who is reasonably identifiable”.
1.2 In order to provide a betterservice to you, we may collect and process the following personal information aboutyou:
(a) anonymised usage information
(b) personal information youprovide. This could include:
(i) your photograph;
(ii) your contact details;
(iii) your identity documents;
(iv) results of background checks onyou performed by our customers or by us on behalf of our customers; and
(v) other personal information ourcustomers might request from you during the course of ensuring their compliance.
(c) health information
(i) your body temperature;
(ii) your vaccination records; and
(iii) other health information ourcustomers might request from you during the course of ensuring their compliance.
1.3 We only retain personal &health information for so long as it is necessary. Information may be archivedas long as the purpose for which the information was used still exists.
1.4 We only collect personal &health information after obtaining an explicit consent from you.
2 How we collect yourpersonal information
2.1 For marketing purposes:
(a) We collect your contactinformation through our website, where you elect to provide it.
2.2 For the purposes of providingvisitor compliance services to our customers:
(a) We collect your informationthrough our customers uploading this information into our software.
(b) We collect your informationthrough our kiosks when you interact with them and provide such information tous.
2.3 For the purposes of providingcandidate and employee compliance services to our customers:
(a) We collect your informationthrough our customers uploading this information into our software.
(b) We collect your informationwhen you interact with our system and provide such information to us.
(c) We collect your informationthrough our background checking service when we perform a check on you onbehalf of our customers.
2.4 For the purposes of performinga reference check on a candidate:
(a) We collect your contactinformation through our system when a candidate elects you to provide areference for their future prospective employer.
(b) We collect the referenceinformation you provide through interaction with you.
2.5 Any personal information isusually collected directly from you where practical.
2.6 We may also obtain yourpersonal information from third parties we deal with.
2.7 When collecting personalinformation by whichever means, we will take reasonable steps to provide theappropriate notices and obtain relevant consents in accordance with theAustralian Privacy Principles.
2.8 Although most information iscollected directly from the individual, where we collect personal informationfrom third parties you refer to us, we will assume, and you will ensure, thatyou have made that third party aware of the referral and the purposes ofcollection, use and disclosure of the relevant personal information. In suchcases we will require a warranty from the third party that the information hasbeen collected in accordance with Australian Privacy Principles, includingnotification that the information may be disclosed to organisations such asZipline or requisite consents had been obtained.
2.9 We may also keep unsolicitedpersonal information (personal information we receive that we have taken noactive steps to collect) if the information is reasonably necessary for one ormore of our functions, services or activities.
3 Uses made of your personal information
3.1 The purposes for whichinformation may be used by us include:
(i) ensuring that content from oursite is presented in the most effective manner for you and for your computer;and
(ii) allowing you to participate ininteractive features of our service, when you choose to do so,
(i) providing you with alerts,newsletter, education materials or information that you requested or signed upto; and
(ii) researching, designing andlaunching services or products including seminars/events/forums,
(c) Providing services to ourcustomers
(ii) carrying out our obligationsarising from any contracts entered into between you and us;
(iii) performing background checks onbehalf of our customers when you provided an explicit consent to us and/or ourcustomer; and designing and conducting surveys/questionnaires for clientprofiling/segmentation, statistical analysis, improving and furthering theprovision our products and services,
(d) complying with laws andregulations applicable to us or any of our affiliates in or outside Australia;
(e) legal proceedings, includingcollecting overdue amounts and seeking professional advices; and
(f) purposes directly related orincidental to the above.
3.2 Your information will not beused for any other purposes unless you explicitly provide your consent.
4 Dealing with us anonymously
4.1 In most cases, when you engage with us for any of the purposes set out insection 3 of this Policy, we will need to deal with you as an identifiedindividual. For this reason, if you choose to remain anonymous or use apseudonym, we may not be able to fulfill your request or otherwise provide youwith our services.
5 Disclosure of your information
We will keep the personal information we hold confidential but mayprovide information to:
(a) personnel, agents, advisers,auditors, contractors, financial institutions, and service providers in for thepurposes of delivering services to you or our customers on your behalf;
(b) our offices, affiliates,business partners and counterparts (if any);
(c) persons under a duty ofconfidentiality to us;
(d) persons to whom we are requiredto make disclosure under applicable laws and regulations in or outsideAustralia; or
(e) actual or proposed transfereesor participants of our services in or outside Australia.
The above entities may in turn disclose your personal information toother entities as described in their respective privacy policies or notices.
Zipline may disclose personal information for secondary purposesthat are related to the primary collection purpose but only in situations whereit is reasonable to expect such information to be disclosed. Typically, thiswould be for internal business practices (auditing, product development, ITsupport and service providers).
6.1 Securing and protecting data isan issue that Zipline takes very seriously.
6.2 Zipline has implementedtechnology and security processes to protect the personal information that wecollect and we take all reasonable steps to protect it. Our internal systemsand data storage facilities have electronic security systems in place, includingthe use of firewalls and data encryption. User identifiers and passwords arealso used to control access to your personal information.
6.3 Other examples of Ziplinesecurity measures include: regular penetration testing, log review, random spotchecks, information segregation, robust access control, etc.
6.4 In the unlikely event of asuspected data breach, we will assess the breach to determine whether it islikely to result in serious harm to any of the individuals to whom theinformation relates. In which case, we will notify the individual(s) at risk ofserious harm and the Office of the Australian Information Commissioner as soonas practicable.
6.5 The transmission of informationvia the internet is not completely secure. Although we will do our best toprotect your personal information, we cannot guarantee the security of your informationtransmitted to our site; any transmission is at your own risk.
7.1 We make changes to this policyfrom time to time to ensure compliance with the Australian Privacy Principles.
8 Data retention and disposal
8.1 Except as otherwise permittedor required by applicable law or regulatory requirements (in particular, dataretention periods), Zipline will take reasonable steps to retain your personalinformation only for as long as it is necessary to fulfil the purposes forwhich the personal information was collected.
8.2 We will also retain and useyour personal information for as long as necessary to resolve disputes and/orenforce our rights and agreements.
8.3 Outside of reasonable retentionand other legal requirements, we will take reasonable steps to destroy orde-identify personal information where it is no longer necessary to beretained.
8.4 Non-personally identifiable,anonymised and aggregated information may be stored indefinitely.
9 Transfers of information outside of Australia
9.1 We process and store yourpersonal information on servers in Australia. We may store anonymised informationoutside Australia, in countries including Singapore and the USA.
9.2 Any overseas disclosures willonly be made once Zipline has taken all reasonable steps to ensure any personalinformation will be treated at least in accordance with the Privacy Act andother applicable privacy laws.
9.3 This may include (but notlimited to) taking steps to ensure that contractual arrangements with overseasrecipients include obligations on those recipients to:
(a) handle any personal informationthey receive in accordance with the Privacy Act; and
(b) maintain administrative,technical, and physical safeguards to help protect the security,confidentiality and integrity of personal data consistent with applicablerequirements of the Australian privacy laws.
10 Direct marketing
10.1 We never use personal or healthinformation provided to us by you or our customers or collected by us duringthe course of performing services for any marketing services
10.2 We only use contact informationfor marketing purposes when you expressed interest in receiving marketingmaterials from us and provided your express consent for us to do so (which youcan withdraw at any time).
10.3 We will never sell, trade,lease or rent any personally identifiable information to other organisationsexcept as stated and agreed when collecting information from the individualconcerned.
11 Your consent and rights
11.1 By using our service, making anapplication or visiting our website, you consent to the collection and use ofyour information and other activities as outlined in this policy.
11.2 Under the Privacy Act (the"Act"), individuals havethe right:
(a) to check whether we holdpersonal information about you and to access such information;
(b) to require us to correct assoon as reasonably practicable any information relating to you that isinaccurate;
(c) to ascertain our policies andpractices in relation to personal information and the kind of personal informationheld by us; and
(d) to withdraw your consent to theuse of your personal information for marketing purposes and we shall not useyour personal information for marketing purposes after you communicate yourwithdrawal of consent to us.
11.3 You may exercise your opt-outright by notifying us if you wish to withdraw your consent to the use of yourpersonal information for direct marketing purposes. Please send requests toopt-out and for access to information, correction of information, informationregarding policies and practices and kinds of information held, questions orcomplaints to: firstname.lastname@example.org
11.4 If the complaint is notresolved to your satisfaction you can refer it to the Office of the AustralianInformation Commissioner. Such complaints generally are resolved throughconciliation.
11.5 In accordance with the Act, wehave the right to and may charge a reasonable fee for processing any informationaccess request.
Lastupdated: 01 September 2023