EP3 has adopted this Policy to ensure that it collects, holds, uses and discloses personal information, credit information, credit eligibility information, credit reporting information and CRB derived information in accordance with the APPs and Act.
EP3 will maintain and regularly review this Policy and intends to comply with the APPs and the Act.
Access Seeker has the same meaning as in the Act.
Act means the Privacy Act 1988 (Cth).
APPs means Australian Privacy Principles.
CRB derived information has the same meaning as in the Act.
EP3 means Episode 3 Pty Ltd (ACN 662455021) as defined by the Corporations Act 2001 (Cth).
Government related identifier has the same meaning as in the Act.
Personal information has the same meaning as in the Act.
Sensitive information has the same meaning as in the Act.
Service Provider means any third party that EP3 engage (or enter negotiations with a view to engaging) to provide services to support the EP3 business.
Open and transparent management of information
EP3 collects personal information which is reasonably necessary to:
*When you visit the EP3 website, our internet Service Provider records the following information: your IP address; the date, time and duration of your visit; the number of pages you have downloaded; and the type of browser you use. Google analytics demographic and interest reporting may be used to develop specific offers or advertising from time to time.
Anonymity and pseudonymity
EP3 will allow its customers to transact with it anonymously or by using a pseudonym, wherever that is reasonable and practicable.
However, this will not be possible if EP3 is required or authorised by Australian law or other instrument (such as an order of a court or tribunal) to deal with customers who have been appropriately identified or where it is impracticable for EP3 to deal with individuals who have not identified themselves or who would prefer to use a pseudonym.
Collection of solicited information
EP3 will only collect personal information and credit information from you if it is reasonably necessary to provide goods or services to you (including on credit) or undertake ancillary functions for you. EP3 will only collect information for the purposes for which EP3 advised you it was collecting it for, or a related purpose which would reasonably be expected, or otherwise with your permission. For example, EP3 may from time to time use your personal information to provide information about products, services, promotions and campaigns which it expects may be of interest to you. Generally, EP3 collect personal information through account opening/application forms, contracts to which you are a party, and other forms completed by you when dealing with EP3 (including when participating in a promotion or competition). EP3 will also collect credit information this way, and from your dealings with us. EP3 may also collect credit eligibility information, credit reporting information and CRB derived information from credit reporting agencies (as detailed above).
EP3 may also collect your information to do one or more of the following:
EP3 collects and uses your credit eligibility information, credit reporting information and CRB derived information for commercial credit related purposes only. Any disclosure (if any) will only occur by lawful means.
EP3 will generally not be required to collect sensitive information about you. EP3 will only do so if it is considered reasonably necessary for EP3 to collect such information for EP3 to perform its functions or activities and you consent, or another circumstance is provided for that enables that to occur (such as collection is required or authorised under an Australian law or by order of a court/tribunal).
Dealing with unsolicited personal information
If EP3 receives personal information about you from a source other than you, or it is information provided by you which EP3 did not request, EP3 will to determine, within a reasonable period, if it could have collected such personal information under APP 3. If EP3 determine that it could have collected the information under APP 3, EP3 may then use, and treat, that information as if it had collected the information in that manner. If EP3 determines that it could not have collected the information under APP 3 and so long as it is lawful and reasonable to do so, it will destroy or de-identify that information as soon as practicable.
Notification of the collection of information
When EP3 is collecting personal information and credit information about you, EP3 will take reasonable steps to notify you, either at or before the time of, or as soon as reasonably practicable after, collection why EP3 is collecting such information (which may have already been outlined in a contract with you). This is particularly relevant if EP3 collect information about you from someone other than yourself. For example, EP3 may receive personal information about you from a credit reporting agency.
EP3 will also take steps that are reasonable in the circumstances to, among other things, make it clear to you if it is required to collect such information by reason of an Australian law or some other legal instrument (such as a court or tribunal order), why it is collecting such information and the potential consequences for you if such information is not collected.
Use or disclosure of information
EP3 collects personal information from you for a specific reason as described in APP 3. This is referred to as the primary purpose. EP3 will not use or disclose the collected information for a secondary purpose unless you consent to EP3 doing so, or under the circumstances involved, EP3 believe you would reasonably expect EP3 to use or disclose the information for a secondary purpose related to the primary purpose.
In the event that EP3 hold sensitive information about you, EP3 will only use or disclose that information with your consent or if the use or disclosure is otherwise permitted under the APPs or the Act, such as where the use or disclosure is directly related to the primary purpose and within your reasonable expectations.
EP3 may also disclose your personal information or sensitive information if it is required to do so by an Australian law, by order of a court or tribunal or if EP3 reasonably believes that the use or disclosure of the information is reasonably necessary for an enforcement related activity, by or on behalf of an enforcement body, in which case EP3 will make a written note of the use or disclosure. A disclosure may also be made where a permitted general situation or permitted health situation exists as provided for in the APPs.
EP3 uses Service Providers to provide services to support EP3’ business. These Service Providers may perform services or assist to provide services to you, by handling your personal information on EP3 behalf or by using their own affiliates to provide these services. For example, EP3 engages Service Providers to provide IT services, cloud storage, workforce management software services, vehicle fleet management services and website analytics services. EP3’ Service Providers may need to access your personal information in connection with providing these services. The Service Providers may be based in Australia or in countries overseas, including in India, Canada and Ireland.
EP3 only discloses your personal information to Service Providers in accordance with this Policy and the Act. EP3 does not authorise use or disclosure of your personal information for any other purposes other than in connection to the provision of the services provided to us.
EP3 will only use any personal information collected for the purpose of direct marketing where EP3:
If EP3 collected the information involved from you and you would not reasonably expect EP3 to use or disclose the information for the purpose of direct marketing, or collect the information from someone other than you, EP3 will only use or disclose the information with your consent or where it is impracticable to obtain your consent. Either way, a simple means will be provided to you by which you may request not to receive direct marketing communications from EP3.
When EP3 uses or discloses any personal information collected for direct marketing purposes, those materials will provide you with an option to declare you do not wish to receive such material in the future. If requested, EP3 will provide you with the source of any information used or disclosed for direct marketing purposes, whether that direct marketing be by EP3 or another organisation. EP3 will also provide you with the opportunity to request that it, or the other organisation, does not send direct marketing information to you. EP3 will not charge for that request and will action it in a reasonable time frame. You may also request that EP3 not use or disclose information to facilitate direct marketing by other organisations.
Cross-border disclosure of information
The Service Providers used to support the EP3 business (including to handle personal information on EP3 behalf where required or for complimentary software to support business functions) may be based in Australia or in countries overseas, including in India, Canada and Ireland. Where possible, EP3 will take reasonable steps in the circumstances to ensure overseas recipients comply with the Act, or any corresponding law in the relevant jurisdiction, when handling information and have precautionary measures in place to protect your information from misuse, interference, loss and unauthorised access, modification or disclosure. This includes credit eligibility information received.
EP3 will only transfer personal information about an individual to someone (other than a member of EP3 or the individual) who is in a foreign country if EP3 reasonably believe that the recipient of the information is subject to a law or binding scheme substantially similar to the way in which the APPs protect the information and there are mechanisms that can be used to take action or enforce those laws or binding scheme. EP3 may also transfer personal information cross-border if you specifically consent to EP3 doing so, or EP3 are required to do so under Australian law or an order of a court or tribunal, a permitted general situation exists, or EP3 are required or authorised by or under an international agreement relating to information sharing to do so. Otherwise, EP3 will take reasonable steps under the circumstances to ensure that the overseas recipient does not breach the APPs in relation to the information.
Adoption, use or disclosure of government related identifiers
Generally, EP3 does not use government related identifiers. EP3 will not use or disclose a government related identifier unless the use or disclosure of the identifier is:
EP3 may use or disclose such an identifier if it is reasonably necessary for an enforcement related activity by, or on behalf of, an enforcement body. EP3 may also use or disclose a government related identifier related to you if that is prescribed for by regulation.
Quality of information
EP3 will take steps as are reasonable in the circumstances to ensure that the information it collects from you is accurate, up-to-date and complete. Where information is collected from you directly, EP3 rely on you to supply accurate information and it may not consider that further steps are required. EP3 will also ensure that steps as are reasonable in the circumstances to ensure that the information it collects, uses or discloses are, when considered in relation to the purpose for which EP3 are using or disclosing the information, accurate, up-to-date, complete and relevant.
Security of information
EP3 will take all steps reasonable under the circumstances to protect your information from misuse, interference, loss and unauthorised access, modification or disclosure. If EP3 no longer require the holding of information, it will take all reasonable steps under the circumstances to destroy or de-identify the information. However, EP3 may retain documents that contain information in accordance with document retention practices and requirements under Australian law or any order of a court/tribunal. For example, EP3 may retain copies of contracts to which you are a party, even though the contracts may contain personal information about you. Similarly, personal information provided for the purposes of establishing or varying the terms of a trading account will be retained on file for document retention purposes.
EP3 will take reasonable steps with respect to information to ensure that any information collected, held, used and disclosed will comply with the Act and any corresponding law where information is collected, held, used or disclosed offshore.
Access to information
You can request access to the personal information that EP3 holds about you by contacting the EP3 Directors whose contact details are available on the contact us page. EP3 may need to verify your identity to provide you with access and consider whether any exceptions to access apply.
In relation to requests to access information, EP3 will generally provide you with access to your information on request, unless:
Where EP3 provides you with access to your personal information it will do so within a reasonable time after receiving your request and in the manner requested by you (if it is reasonable and practicable for EP3 to do so). EP3 may charge a reasonable fee for giving access to the information. Any request will be responded to within a reasonable period (usually within 30 days) after the request is made.
If EP3 determines not to release information to you, it will provide you with written notice setting out the reasons for refusal and your review options.
Correction of information
If EP3 determines that information held is inaccurate, out-of-date, incomplete, irrelevant or misleading, or you request EP3 to correct the information (or any CRB derived information), it will take all such steps as are reasonable in the circumstances to correct the information held, after considering the reason why EP3 hold the information, and to make sure it is accurate, up to date, complete, relevant and not misleading. If EP3 had disclosed the original information to a third party or you request EP3 to advise another party, EP3 will take all reasonable steps to update that other party unless it is impracticable or unlawful to do so. Unless required not to by law or it is impracticable to do so, EP3 will provide you with written notice within a reasonable period as to any correction made to information. If EP3 refuse to correct the information held, EP3 will provide you with written notice as to the reasons for refusal, how you can complain about EP3 refusal and any other matter EP3 may be required to advise you about in the circumstances.
If EP3 have refused to correct information held, you may request EP3 associate a statement from you, with the information held, that you believe that the information held is inaccurate, out-of-date, incomplete, irrelevant or misleading. If such circumstance arises, EP3 will take all reasonable steps under the circumstances to associate any such statement.
If EP3 receives a request from you to correct information held by us, EP3 will respond to that request within a reasonable period after receiving the request. EP3 will not charge for your request, the correction of information or associating a statement.
Enquiries regarding this Policy or the information EP3 may hold on you, should be addressed to the Directors, whose contact details are on the contact us page.
If you have any enquiries, requests, complaints or breaches to report about the collection, holding or management of your information, please contact the Directors of EP3 via the contact details set out on the contact us page so that they may attempt to resolve the issue with you quickly and directly.