Privacy Statement

Clemenger Group Limited (ABN 98 004 882 928) and its related group of companies and associated bodies corporate (us, we, our) maintain a policy of strict confidence concerning your (you, your) personal information (Privacy Policy).

This Privacy Policy has been developed in accordance with the Australian Privacy Act 1988 (Cth). This Policy sets out what information we gather, how we may use it, and how you may correct or change it. This Privacy Policy applies to information provided to us whether via the site or any other means.

1. Collecting personal information

1.1 We will generally collect personal information directly from you, unless it is unreasonable or impracticable to do so. We may also collect personal information from third parties such as your representatives or external data suppliers. When we have collected personal information about you, we will notify you at the point of collection, or as soon as practicable, to ensure that you are aware of such collection and its purpose.

1.2 If someone other than you provide us with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. However, this notice will not be provided if doing so would be a breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de-identify or destroy the personal information.

1.3 We will only collect sensitive information revealing your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability if:

  • you have given express consent to us to do so and the information is reasonably necessary for us to carry out our functions or activities; or
  • the use of information is:
    • required or ised under Australian law or a court or tribunal order.
    • necessary for the establishment, exercise or defense of a legal claim.
    • necessary for lessening or preventing a serious threat to health or safety.
    • necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
    • for a diplomatic or consular function or activity or certain Defense Force activities outside Australia; or
    • used in relation to confidential alternative dispute resolution process.

1.4 In regard to the collection of data on the Careers page of the site, as a customer of Springboard via our Recruitment Process Outsourcing contract our privacy policy covers any candidates who use the system. The full privacy policy can be found here: https://www.springboard.com.au/privacy/.

If you are a user of the PeopleScout Services and/or website from Australia, your privacy rights include the following:

  • Right to access Personal Data. Subject to certain exceptions, you have the right to access your Personal Data upon request. PeopleScout will provide requests within a reasonable period after the request is made.
  • Right to seek correction of Personal Data. You have the right to have your personal data corrected.
  • Right to complain to the Commissioner. You have the right to submit a complaint to the Information Commissioner about our handling of your personal data in violation of applicable law.

We acknowledge that you have the right to access your personal data. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should also direct their query to the PeopleScout Client (the data controller) pursuant to the PeopleScout Client’s public privacy policies.

Alternatively, if the PeopleScout Client is unable to assist with correction, amendment, or deletion requests, you may access, correct, or request deletion of your personal data by sending an email to privacy@springboard.com.au.

If requested to remove personal data we will respond within a reasonable timeframe and in compliance with all applicable laws.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection ity.

2. Cookies

2.1 We may collect non-personal information about the computer, mobile telephone, smartphone or other device that you use to access our products or services. Where you allow our mobile services and products to deliver content based on your location (by enabling this feature on your mobile device) we may collect location data. This information is used only for the automated delivery of relevant content to you and for no other purpose.

2.2 We may use a cookie file containing information that can identify the computer you are working from. The cookie file is anonymous as it only gives us details of your IP address, PC platform (Windows, Linux or OS X), Browser (e.g. Internet Explorer, Google Chrome, or other, plus the version of Browser) and domain (whether you are accessing the site from Australia , or elsewhere). We may use the information generated by "cookies" to:

  • track traffic patterns to and from our sites such as the pages you visit, the time you spend on each page, the date and time of your visit, where your mouse hovers, and referring pages (pages you came from or go to);
  • enable you to use certain services as a member without having to log on each time and to visit member-restricted areas of the site.

2.3 You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use our websites, but you may need them for customisable areas of sites we may develop in the future. If your cookies are turned off, we will not have any control over the frequency of display of certain ad formats. This could affect your reading experience. Visit https://www.allaboutcookies.org/manage-cookies/ for a comprehensive guide on how to control and delete cookies on a wide range of web browsers and operating systems.

3. Use and disclosure of information

3.1 Your personal information may be used by us in a number of ways, including to:

  • provide the products and services offered on the site and in any other forum to you;
  • enhance and improve your use of the site and our products and services;
  • respond to any questions, comments or queries submitted on the site or by any other means;
  • disperse marketing materials and keep you informed about new products, initiatives and opportunities;
  • for internal business purposes, for example, to research and develop the site and our other products and services; and
  • as required or ised by law, including under the Australian Privacy Principles.

3.2 We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy. In order to deliver the products and services, we may disclose your personal information to other organisations but only in relation to providing our services to you. This disclosure may include providing your personal information to our clients in order to provide the products and services as agreed upon by you and them. We take reasonable steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information.

4. Direct marketing

4.1 We may use personal information about you for the primary purpose of providing you with our services. We may also use it for other purposes for which you might reasonably expect us to use that information. This includes sending you information about new developments, products, services and special offers by post, telephone or any form of electronic communication. We may also contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases your personal information is not transferred to the third party. You ise us to use any email address or other contact information you provide to use at any time for such above purposes.

4.2 You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide.

5. Accuracy of your information

We are based in Australia , any personal information that you provide to us will be collected, held and processed by us in Australia . Under the Privacy Acts of both countries you have rights of access to and correction of personal information that we hold. We offer the ability to correct or change the information collected at any time and as often as necessary. Please contact the Privacy Officers of Clemenger Group if you would like to make any changes.

6. Your consent

You have the right to withdraw consent at any time.

You may sign-up to receive emails from us on some of our websites. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you.

You may opt out of certain other communications that we provide by following the instructions for opting out in those communications.

For any other withdrawals of consent not addressed above, please contact the Privacy Officers of Clemenger Group.

7. Storage and Security

7.1 We will use all reasonable endeavours to keep your personal information in a secure environment, however this security cannot be guaranteed. Our procedures are designed to prevent your personal information being accessed by unised personnel, lost or misused. If you reasonably believe that there has been unised use or disclosure of your personal information please contact us (see section 9.2 below).

NB: No data transmission over the Internet can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of any information you transmit on or through our Sites and you do so at your own risk.

7.2 If we no longer need your personal information, unless we are required under law or a court or tribunal order to retain it, we will take reasonable steps to destroy or securely delete your personal information in accordance with our document retention policy.

8. Changes to Policy

We reserve the right to change this policy at any time by notifying site users of the existence of a revised privacy policy.

9. Privacy breach and access to information we hold about you

9.1. If you have any questions, or if you wish to receive more information on our information practices and Privacy Policy, please contact our Privacy Officers.

9.2. If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by writing to our Privacy Officers:

Australia: Rowan Darling, Clemenger Group Limited, 474 St Kilda Road, Melbourne VIC 3004

Fees may be charged for the provision of this information.

9.3. When contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way or if we are required or ised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

9.4. If you believe your privacy has been breached please contact our Privacy Officer.

10. Children’s privacy

Protecting the privacy of the young, i.e. children under the age of 13, is especially important. For that reason, we never collect or maintain information for our services from those we know are under 13, and no part of our services are structured to attract anyone under 13. If a child has provided us with personal information, we ask that a parent or guardian of the child contact us at rowan.darling@clemenger.com.au if they would like the information submitted by the child deleted from our database. We will use all reasonable efforts to delete such information from our database.

11. More Information

For information about Australia’s Privacy Acts and how they protect the personal information of individuals, please refer to the following link:

• Australia Privacy Act 1988

Your privacy is important to us. This privacy statement describes Clemenger Group NZ’s collection, use and disclosure of information we collect from you and about you when you use Clemenger Group NZ’s websites and associated applications.

Clemenger Group NZ is a New Zealand based company and any information we collect about you is processed and stored according to New Zealand privacy Act 2020.

Collections

Clemenger Group NZ (“we” or “us”) gather various types of information, including information that identifies or may identify you as an individual (“Personal Information”).

We collect any:

  • Personal information provided by you when you interact with us or apply for any jobs;
  • aggregated information generated by our systems or third-party systems we use, which track traffic to and from our sites but does not relate to you personally;
  • Any recordings we make of you – for example, CCTV recordings when you’re in our offices;
  • other information that does not personally identify you.

Use

We may use the personal information we collect:

  • To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
  • to provide information to you about other websites, products and services, which we consider may be of interest to you:
  • To comply with our legal requirements and keep people safe (investigate security events).

Disclosure of Information

We may disclose:

  • all information that we gather, including your personal information, to our related companies;
  • aggregated tracking information and other information that does not personally identify you to third parties;
  • your personal information to third parties when we believe in good faith that we are required to do so by law;
  • your personal information to other third parties provided we have your prior isation, which we will usually obtain at the time of collecting the information from you.

Cookies, and Tracking

We use google universal analytics to collect non-personal information about your visit to our site to help improve your browsing experience. This information collected includes:

  • The IP address of the device;
  • The pages accessed on our site and the links clicked on;
  • The date and time the site was visited;
  • The operating system (e.g., Windows, Mac OSX) on the device used;
  • The type of web browser used (e.g. Internet Explorer, Mozilla Firefox); and
  • Other incidental matters such as screen resolution and the language setting used

You may turn off cookies at any time. Most browsers have a feature that allows the user to refuse cookies, or issues a warning when cookies are being sent. Turning off cookies will not affect your ability to use this site but may affected your experience.

The data is collected and stored on the Google server and is viewable only by ised staff. We do not share this information with any other party. However as detailed within Google’s privacy policy they may share this information publicly and with their partners.

Visit http://www.aboutcookies.org for a comprehensive guide on how to control and delete cookies on a wide range of web browsers and operating systems.

NB: You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the Services. We are not responsible for privacy policies on third-party apps and websites.

Security

Clemenger Group NZ or its related companies uses reasonable strict physical, technical and administrative measures to keep information you provide secure.

NB: No data transmission over the Internet can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of any information you transmit on or through our Sites and you do so at your own risk.

How long we keep your personal Information

We will retain your personal information for as long as is required, and complies with our legal obligations. If you no longer want us to use your personal information, you may request that we erase your personal information.

If we no longer need your personal information, unless we are required under law or a court or tribunal order to retain it, we will take reasonable steps to destroy or securely delete your personal information in accordance with our document retention policy.

Your rights

We are based in New Zealand and any personal information that you provide to us will be collected, held and processed by us in New Zealand. Under the New Zealand Privacy Act 2020 you have the following rights in relation to your personal information:

  • The right to be informed
  • The right to access
  • The right to correction
  • The right to deletion
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • The right to withdraw consent
  • The right to complain.

Please contact us by email at privacy@clemenger.co.nz if you would want to exercise any of your rights. You can also make a complaint, directly to the New Zealand Privacy Commissioner.

Privacy Breach and Contact Us

If you believe your privacy has been breached by us, or need access to your personal information,  contact us by email at privacy@clemenger.co.nz. We may charge a small fee.

Changes to Statement

We reserve the right to change this privacy statement at any time by notifying site users of the existence of a revised privacy statement.