PRIVACY POLICY

This Privacy Policy applies to personal information we collect about our customers, visitors to our website, recipients of our electronic communications, employees, independent contractors and members of the public.  It provides information about the personal information we collect, and the ways in which we use and disclose that personal information (which may include sensitive information).

We are bound by the Commonwealth Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles made under the Privacy Act (APP’s).  These principles regulate the way that we collect, hold, use and disclose information.  You can find out more about these principles by calling the Office of the Privacy Commissioner or visiting its website at www.oaic.gov.au

By accessing our website, libertybullion.com.au, purchasing our products or using our services, you agree to be bound by the terms of this Privacy Policy and consent to us using and disclosing your personal information as set out in this Privacy Policy.

What personal information we collect

Types of personal information we will collect from you may include:

• Your name, address, telephone number, email address, date of birth, employment details, driver’s licence and/or passport information, metadata held within a computer system, (including biometric information).

We may collect additional information for the purpose of undertaking market research and direct marketing, such as:

• your preferences concerning types of products or services and
• details about your use of certain types of products or services that you purchase from us.

How we collect personal information

Personal information will normally be collected directly from you when you deal with us by telephone, by correspondence through a letter, fax or e-mail, via our website or social media, or by direct face-to-face contact between you and us when you visit our office. Be aware however that personal information may be collected by indirect means, including by inference, or through system generated data.

The APPs regulate all information collected, whether directly or indirectly.

Other ways in which we may collect personal information include:

• Anywhere you access our products or services.
• Recordings of your image from security cameras located on our physical premises. Footage will only ever be used and disclosed by us in accordance with the APPs.
• Through recording calls to our business for training/security/operational purposes.
• Collection of biometric information through the use of facial recognition or other technology. 

When we collect personal information from Third Parties

We may collect your personal information from third parties from time to time through:

• “business to business” transactions in the ordinary course of conducting our business (including through collection of data through web-based transactions);
• Where you ask our business for goods or services that involves us obtaining information about you from another source;
• Where we source information from a government department, regulatory body or law-enforcement agency where that is reasonably necessary for us to provide goods or services to you; and
• From publicly available sources.

Where we collect personal information about you from a third person, we will take reasonable steps to notify you that we have collected the information and that it will be handled in accordance with our privacy policy.

Where will your personal information be stored

We may store personal information with cloud service providers both in Australia (and overseas, if we need to for operational reasons).  If we store personal information with a cloud storage provider we will take reasonable steps to ensure:

1. that the provider’s security meets the standards required by law in Australia; and
2. that we retain effective control over what that provider does with that information.

If you refuse to provide us with personal information

The general rule is that no individual is required to provide personal information. However, if you refuse to provide personal information in a form required by us, then we may refuse in our absolute discretion to carry out a transaction or otherwise deal with you.

How we use personal information

We will not use personal information for purposes other than those set out in this policy without the consent of the owner of the personal information, unless that use is authorised by this policy or authorised or required under the Privacy Act.

Generally speaking, we use your personal information in the following ways:

• To help us develop, improve, manage and administer the services we provide to our customers.
• To ensure that our business systems are functional and reliable, which may include fulfilling legal obligations.
• To process commercial transactions with you, including your orders.
• To conduct market research and direct marketing activities (including sending out communications by email, SMS or post, in relation to products, services, promotions and benefits offered by our business
• As part of the investigation and analysis of incidents or occurrences (including potential incidents and occurrences) which occur on or in the vicinity of our physical premises.
• To investigate, respond to or defend claims made against, or involving, our business.
• To enforce a contract or agreement we have with you.
• To verify your identity or otherwise comply with laws in relation to our business or the requirements of regulators of our business.
• For other purposes authorised or required by law.

When we disclose personal information to Third Parties

We will only disclose personal information to persons or bodies external to our business where such disclosure is permitted by this Policy or permitted under the Privacy Act. We may disclose your personal information to third parties where:

• You consent to the disclosure;
• the law requires that information be provided to government agencies for any regulated purpose including court action, law enforcement or security, for example, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) requires us, amongst other things, to report all cash transactions of $10,000 or greater to the Australian Transaction Reports and Analysis Centre (AUSTRAC).
• it is to our contractors and agents (for the purpose of the services they provide to us) so that our business can complete a transaction on behalf of you or provide it with a service that you have requested.
• the disclosure is necessary for insurance matters, safety purposes, or the operational purposes of our business. Operational purposes may include our contracts with third parties, such as contracts we have with our cloud-based system, software or storage providers, IT support, printers, couriers and marketing services companies, independent verification of identity providers, telecommunications or data storage providers, and the like, and to establish, bring, join in or otherwise participate in any legal proceedings or prospective legal proceedings, or to defend any action that may be brought against us.

Security and Storage

We endeavour to take all reasonable steps to keep secure any information we store about you.  Personal information we collect is stored in secure electronic databases and where applicable, paper documents. Paper documents containing personal information are stored securely onsite at our premises.

We use SSL (secure socket layer) encryption technology to ensure that your personal information is kept safe when making online purchases.  

We encourage you to play an active role in keeping your personal information secure, by maintaining the confidentiality of any passwords or account details.  It is your sole responsibility to maintain such confidentiality and we will not be liable for any damage, loss or expense suffered resulting from disclosure or misuse of your confidential information (including personal information).

We take reasonable measures to destroy or de-identify personal information that is no longer needed by us for any purpose for which we may use or disclosure the information in accordance with this Privacy Policy, unless we are required by law to retain the information.

Use of Cookies

Our website uses "cookies" to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website.

CCTV Recording

Our premises are monitored by closed-circuit television (CCTV) cameras.  CCTV footage may be stored for such period as we may determine for security purposes.  We may disclose any CCTV records arising from an order of a court or other judicial or administrative body, statutory notice or demand, or request made by any police officer or other officer of or representing Australia or a State or Territory, where it is required or allowed by law or where you have otherwise consented to the disclosure, or such disclosure is otherwise permitted or required under the Privacy Act.

Cross-border Data Transfers

Personal information that we collect may be transferred and stored outside of Australia, including the United States of America.  It may also be transferred between any of the countries in which our service providers operate. 

The Privacy Act and the APPs require relevant Australian entities to ensure that, before disclosing personal information overseas, reasonable steps are taken to ensure that overseas recipients do not breach the Act or the APPs. It is not always possible to ensure that overseas recipients will comply. We do not take any responsibility for the actions of overseas third party recipients of personal information.  By providing us with your personal information in order to transact with us you are acknowledging that your personal information may be disclosed to overseas entities or held on servers overseas.

Other Websites

Our website may contain links to third-party websites.  When you access a third party website through our website we are not responsible for the privacy practices of that website.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time in order to keep it up-to-date. We encourage you to periodically review this Privacy Policy.

Your Right to Access and Amend Information About You

We take reasonable steps to ensure that the personal information we collect, use and disclose in accordance with this Privacy Policy is accurate, complete and up-to-date.

If you have submitted details about yourself to us, you are entitled to access the information which is subsequently handled by us or request correction of such information. There are exceptional circumstances where access to or correction of your personal information may be refused by us such as where access would be unlawful. We will advise you of such circumstances if they arise.

If you would like access or request correction of your personal information, please submit your request to outlining the documents or information you require. We ask that you provide us with as much detail as possible about the particular information sought to be accessed or amended in order to help us retrieve it.  We will endeavour to respond to your request within 10 business days.

In order to access or amend your private information, we will need to re-verify your identity.

Contact Us – Questions or Complaints

If you have any questions or complaints about this Privacy Policy or our treatment of your personal information, please write to info@libertybullion.com.au or Level 3, 257 Collins Street, Melbourne, VIC 3000.

We will endeavour to:

• provide an initial response to your query or complaint within 48 hours; and
• resolve your query or complaint within 10 business days.

If you are still not satisfied, you can contact the Australian Privacy Commissioner (see https://www.oaic.gov.au/about-us/contact-us or call 1300 363 992).