Introduction

InFront Technologies, New Line Group Pty Ltd recognise that your personal information is important to you and that you are concerned with its collection, use and disclosure. InFront Technologies,  like other companies operating in Australia, is bound by the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) which set clear standards regarding these activities. This policy contains information about: when you can deal with InFront Technologies anonymously; the purposes for which InFront Technologies collects, holds, uses and discloses personal information; the types of personal information that InFront Technologies collects; how InFront Technologies collects and holds personal information; how you may access the personal information that InFront Technologies holds about you, and how you may seek correction of that personal information; and how you may complain about a breach of the Australian Privacy Principles by InFront Technologies and how InFront Technologies will deal with such a complaint.

When can you deal with us anonymously?

Generally, you have the choice to deal with InFront Technologies anonymously (i.e. without identifying yourself). In certain circumstances however, InFront Technologies will ask you to provide personal information because it is required by law or InFront Technologies’ policies to do so, or because it would be impracticable to deal with you anonymously. These circumstances include where you order goods online (including when you pick up such goods from our store), where you purchase InFront Technologies services, where you join a loyalty or reward program, where you apply to purchase goods on finance, where you return goods for repair, where you purchase goods to be delivered or installed, where you enter one of our competitions, where you want to claim a bonus product offered with your purchase , where you participate in customer research or store feedback, when you submit a request, enquiry, complaint, consumer guarantee or warranty claim, when you pre-order goods or where you agree to InFront Technologies collecting information for future purposes such as receipt retention. InFront Technologies will also ask you to provide personal information so that it may promote and market its products and services to you; however, you can choose not to do this or if you receive marketing material after providing your details as part of another service, you may opt out of the receiving marketing material at any time.

Why do we collect, hold, use and disclose personal information?

InFront Technologies collects, holds, uses and discloses personal information for a number of purposes connected with our business operations, which include: 

  • providing you with products and/or services;
  • dealing with requests, enquiries, complaints, allegations, consumer guarantee or warranty claims, and other customer care or brand protection related activities;
  • marketing our products and services and providing advice on our products;
  • developing and improving our products and services;
  • in connection with our loyalty or reward programmes and our competitions;
  • the operation and administration of accounts or subscriptions that you have with us;
  • payment processing
  • processing 3rd party drop ship orders & services
  • carrying out certain checks (for example, for our fraud or theft prevention processes, or if you wish to open an account with us, obtain credit from us or collect goods from us);
  • interacting with companies or organisations with whom InFront Technologies has a business relationship (who you work for, or otherwise represent);
  • reconciling payments due to InFront Technologies from suppliers in relation to goods or services provided to you by those suppliers;
  • interacting with suppliers in relation to products supplied by those suppliers, such as product recalls and updates;
  • purposes relating to any third party acquisition or potential acquisition of an interest in InFront Technologies or of its assets;
  • complying with our obligations under agreements with third parties (for example our arrangements with consumer finance providers); and
  • carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.

We may also use and disclose your personal information for other purposes, related to those described above, which would be reasonably expected by you.

Documents (including hard copy documents and electronic documents such as emails) which coincidentally contain personal information will also be retained in accordance with InFront Technologies normal document retention practices for accounting, legal and business purposes.

Generally, you have no obligation to provide any personal information requested by us. However, if you choose not to do so where we require this information, we may not be able to provide you with the goods and services that you want or deal with a request, inquiry or complaint that you have.

What personal information do we collect?

The kinds of personal information we collect or which we may hold about you may include:

  • your name;
  • your address;
  • your date of birth;
  • your telephone number(s);
  • your e-mail address;
  • payment information;
  • transaction information;
  • your user name and password;
  • details about your earnings (if you are buying products using a finance plan);
  • information contained on identification documents (such as driving licences) and, in some specific cases, copies of such identification documents, where we require these to verify your identity;
  • information on how you use our products and services;
  • your Internet Protocol (“IP”) address, server address, domain name and information on your browsing activity when visiting one of our websites;
  • your user name for social networking sites that you use, to refer to, or in conjunction with, our goods and services;
  • personal preferences regarding products and services; and
  • CCTV images of you whilst you are in our stores.

How do we collect and hold your personal information?

We collect personal information in a number of ways including:

  • when you order goods or services from us (either online, in-store or over the telephone);
  • when you collect goods that you have ordered from us;
  • when you set up an account with us;
  • when you pay for goods on a trading account by cheque;
  • when you subscribe to our catalogues or mailing lists;
  • when you join any of our loyalty or reward programs;
  • when you enter competitions or promotions that we run;
  • when you provide us your details for customer care purposes;
  • when you browse one of our websites (further information is set out later in this Privacy Policy);
  • when you submit an enquiry using one of our websites;
  • when you complete surveys or provide online feedback or product reviews;
  • when you publicly comment about us on social media sites (for example so that we can answer questions about our products); and
  • through the closed circuit video cameras located in our stores, when you visit our stores.

Generally, InFront Technologies will collect your personal information directly from you. However, InFront Technologies also holds information, collected incidentally, concerning individuals who work for companies or organisations that have a business relationship with InFront Technologies.

Additionally, if you apply for a job with InFront Technologies, we may collect personal information about you from any third parties that you nominate as your referees in your application.

InFront Technologies holds personal information in a number of ways, including:

  • as part of customer records and other electronic documents in which personal information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business; and
  • by securely storing hard copy documents in which personal information is contained, at our various premises and/or using third party document management and archiving services.

Marketing

We may use your personal information that we have collected to promote and market products and services to you, including through methods such as email, post, MMS, SMS, social media and via telephone. We will not use your personal information for marketing purposes where you have opted out of receiving such communications.

When we send you marketing communications we may provide you a particular way to opt-out such as via SMS. Otherwise, you may opt-out of receiving marketing communications by sending a written request to The Privacy Officer, InFront Technologies, either by email to privacy@infronttech.com.au or by pre-paid post to PO Box 3282, DURAL, NSW 2158.

Please note that if your order requires delivery services, you create an online account with us, make a purchase online at infronttech.com.au, purchase, or take part in a promotion or competition your details will be added to our marketing database to receive information relating to InFront Technologies and our products. You may also choose to receive such information by subscribing to our marketing database via one of our websites or by agreeing to receive such information when you are in-store. To opt-out of receiving InFront Technologies marketing materials from our marketing database, you will need to unsubscribe from our database. To do this, simply select the “unsubscribe” option in one of the emails that you receive from us. Please note that if you have an account with InFront Technologies, we may still need to send you essential information about your account or product.

Sharing your personal information

InFront Technologies may disclose or receive personal information or documents about you, including to/from:

  • organisations that provide services to us in connection with our business, including customer support, payment processing, administration, archival, data storage, hosting, research, mail and delivery, installation, distribution, logistics, marketing, auditing, share registry, consulting, financial, legal and public relations advisory, banking, debt collection, security or technical services and the operation of InFront Technologies websites. In some cases these service providers may collect your personal information on our behalf;
  • if you return goods to InFront Technologies to be repaired, our repairs system administrator, the manufacturer of the goods and authorised repairers; • law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities;
  • parties involved in any third party acquisition or potential acquisition of an interest in InFront Technologies or its assets;
  • our insurers and insurance brokers;
  • if goods you purchase from InFront Technologies are subject to a product recall, the manufacturer or distributor of those goods; and
  • other third parties where you have specifically consented to the disclosure of information to these third parties.

Additionally, if you return goods to us for repair and those goods contain personal information (for example, on a mobile phone or computer) you consent to InFront Technologies disclosing any personal information contained on the goods to the repairer, by way of InFront Technologies sending the goods to the repairer.

Disclosure of personal information to overseas recipients

InFront Technologies is unlikely (however possible) to disclose the personal information that it collects and holds about you to third parties who are not in Australia (such as third parties who are located in the United States of America, Singapore, the United Kingdom, India and New Zealand). Some of the jurisdictions in which these third parties are located may have less protective privacy and data protections laws than Australia.

Personal information collected on behalf of other parties

InFront Technologies may collect information about you on behalf of third parties. For example, information collected for finance providers if you wish to purchase goods on finance.

In these cases the documentation that you sign will set out (expressly or by reference to third party privacy policies) how the personal information that you provide will be used by these third parties, and the privacy policies of the third parties will apply. InFront Technologies may also receive personal information about you from these third parties where necessary in connection with the provision of goods or services by InFront Technologies.

How do we handle your personal information when applying for a job with us?

If you apply for a job with us, you will be required to provide us with certain personal information, including your name, employment and educational background, in relation to your job application.

We will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. We will disclose only such information as is necessary in the circumstances.

In considering your application, we may also collect personal information about you from any third parties that you nominate as your referees in your application.

Security of your personal information

We will take reasonable steps to ensure that the personal information that we hold is stored in a secure environment protected from misuse, interference and loss & from any unauthorised access, modification or disclosure.

How to access, correct and update your personal information?

Upon your request, InFront Technologies will provide you with access to your personal information that we hold (except in certain circumstances set out in the Privacy Act 1988 (Cth)).

InFront Technologies reserves the right to charge you an administration fee of $25 for providing access to your personal information and will, of course, require proof of your identify before providing information to you. You may also ask us to correct the personal information that InFront Technologies holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, InFront Technologies will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. To request access to the personal information that InFront Technologies holds about you, or to update or correct that personal information, please send a written request to The Privacy Officer, InFront Technologies either by email privacy@infronttech.com.au or by pre-paid post to PO Box 3283, Dural NSW 2158.

In addition:

  • if you are a subscriber to our marketing database you can also update your details via the “unsubscribe” option in one of the emails that you receive from us;
  • if you subscribe to one of our services you can also update your details via that service..

How to make a complaint?

If you are concerned that the way InFront Technologies collects, holds, uses or discloses your personal information may be in breach of the Australian Privacy Principles, please send written details of your complaint to The Privacy Officer, InFront Technologies, either by email to privacy@infronttech.com.au or by pre-paid post to PO Box 3283, Dural NSW 2158.

How will InFront Technologies handle complaints regarding personal information?

After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:

  • conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of the personal information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles; and
  • notify you of the results of our investigation of your complaint.

If the conclusion of our investigation is that our collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles, we will take steps to remedy the breach as soon as reasonably practicable.

We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe.

If you are not satisfied with our response to your complaint you are entitled under the Privacy Act 1988 (Cth) to make a complaint to the Office of the Australian Information Commissioner. Information about how to make a complaint is available from the Office of the Australian Information Commissioner’s website (www.oaic.gov.au).

Additional information for users of our websites

If you visit infronttech.com.au or any other InFront Technologies websites (the “Websites”) to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes; (ii) for website administration, security and maintenance purposes; and (iii) to direct you to material on our Websites that we believe will be of interest to you.

Like many websites, our Website may use “cookies” from time to time. Cookies are small text files that we transfer to your computer’s hard drive through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer usually allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Website may not function fully for users that disallow cookies.

Our Website also uses tags, which are tiny bits of website code that allow us to measure traffic and visitor behaviour, and to understand the impact of online advertising, use remarketing and audience targeting. These tags do not collect any personally identifiable information.

While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we use our best efforts to ensure its security in our possession.

The Websites may contain links/ plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites.

Exemptions

InFront Technologies sometimes handles personal information relying on exemptions under the Privacy Act 1988 (Cth), for example in relation to: (i) employee records; (ii) related bodies corporate; (iii) provision of services to State or Territory authorities; and (iv) operations outside Australia relating to personal information of non-Australians.

Any permitted handling of personal information under such exemptions will take priority over this Privacy Policy to the extent of any inconsistency.

Privacy Queries

If you have any queries or concerns, further information can be obtained by contacting our Privacy Officer by email privacy@infronttech.com.au or by post to The Privacy Officer, InFront Technologies, PO Box 3283, Dural NSW 2158.

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