PALE BLUE DOT GAMES PTY LTD (ACN 605 400 780)
Our specific legal obligations when collecting and handling of personal information are outlined in the Privacy Act 1988 and in particular in the Australian Privacy Principles found in that Act.
PALE BLUE DOT GAMES PTY LTD (ACN 605 400 780) is a Smart Phone Application Developer. During the course of its activities it is necessary that we collect, hold, use and disclose personal information of clients, contractors, suppliers, consultants and employees.
The collection, holding, use and disclosure of personal information is critical to enabling us to undertake all of our necessary business and related activities. However, people need to have trust and confidence in PALE BLUE DOT GAMES PTY LTD (ACN 605 400 780) and how we handle their personal information when working with us or undertaking business with us and that we will respect their privacy.
The Privacy Act 1988 relates to:
a) the protection of an individual's personal information which is information or an opinion about an identified individual, or an individual who is reasonably identifiable;
b) the protection of an individual's sensitive information which includes information relating to race, religion, ethnic background, sexual orientation, membership of trade unions or professional associations, health information or biometric information.
The Privacy Act 1988 sets out 13 principles (called the Australian Privacy Principles) that set out standards, rights and obligations for the handling, holding, accessing and correction of personal information (including sensitive information).
3. Collecting personal information
During the course of our dealings with clients, contractors, consultants and employees it is necessary that we collect personal information. However, at all times we try to only collect information that we require for the particular function or activity that we carrying out.
The main way that we collect personal information is when it is provided to us. For example, we collect this information when personal information such as names, business or residential addresses, email addresses, telephone or fax information and tax file number information is provided to us where it is necessary to enable us to undertake the function or activity that we are carrying out. This information is provided in various ways including through electronic and other communications, when receiving contract related documents, when receiving employment related information and similar activities.
If we open a file in relation to a project or matter then it will often include a variety of different forms and personal information which you have provided to us or which we have obtained in the course of undertaking those activities which are necessary for us to carry out.
We may also collect your contact details and some other personal information if you have participated in a meeting or consultation with us.
4. Collecting sensitive information
It may be necessary for us to collect sensitive information about you. For example, we may need to do so to enable us to comply with our security or occupational health and safety obligations. This might include information about your health, criminal history, genetic or biometric information.
5. Indirect collection
During the course of our relationship with you we may collect personal information (including sensitive information) about you indirectly from publicly available sources or from third parties such as sub-contractors, medical practitioners or consultants.
We also collect personal information from publicly available sources to enable us to contact stakeholders who may have a valid connection to our work or in participating in our consultations.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, should you wish to report a breach of our procedures or policies or identify a security or an occupational health hazard we may not ask for your name unless we need to do so adequately deal with the matter that you have brought to our attention.
However, for most of our functions and activities we will need your name and contact information and enough information about the matter with which we are dealing with you to enable us to fairly and efficiently handle your enquiry, request, complaint or to act in relation to the function or activity in which we are engaged with you.
7. Collecting personal information through our website
PALE BLUE DOT GAMES PTY LTD (ACN 605 400 780) has its own public website - www.pbdgames.com.
Where our website allows you to make comments or give feedback we collect your email address and sometimes other contact details. We may use your email address to respond to any feedback. We store this personal information on our computer servers.
a. Storage of data
We store your personal information (including sensitive information) on computer servers which may be located in Australia or which may otherwise be located outside of Australia in (insert locations of computer servers outside of Australia).
b. Analytical, session and cookie tools
The information collected by these tools may include the IP address of the device you are using and the information about sites that IP address has come from, the pages accessed on our website and the next site visited. We use this information to maintain, secure and improve our website and to enhance your experience when using it. In relation to Google Analytics you can knock out the collection of this information by using the Google Analytics Op-Out Browser Add-On.
8. Social networking services
We may use social networking services such as Twitter, Facebook and YouTube to communicate with the public about our work. When you communicate with us using one of these services we may collect your personal information, but we will only use it to help us to communicate with you and the public. Any social networking service that we use will also handle your personal information for its own purposes. These sites have their own privacy policies.
9. Email lists
We collect your email, and if you provide it, other contact details when you communicate with us. We only use this information for the purpose of sending you regular updates on our activities and to administer our email lists.
Circumstances in which we may disclose personal information about you include.
a. Review of PALE BLUE DOT GAMES PTY LTD (ACN 605 400 780)
We may disclose personal information to another review body if you or a third party seeks an external review of our decision.
b. Disclosure to service providers
We use a number of service providers to whom we disclose personal information. These include providers that host our website servers, manage our IT and data storage servers in Australia and outside of Australia and manage our human resources information.
To protect the personal information we disclose we:
- Enter into an agreement which requires the service provider to only use or disclose the information for the purposes of the agreement;
- Include special privacy requirements in the agreement, where necessary
c. Disclosure of sensitive information
We only disclose your sensitive information for the purposes for which you gave it to us or for directly related purposes you would reasonably expect or if you agree to us doing so.
d. Disclosure - Storage of data
Generally we only disclose personal information overseas so that we can properly undertake the work that we are requested to complete. For example, if:
- A party that is connected to the function or activity that we are engaged in with you that is located overseas;
- An Australian based respondent is a related body corporate to an overseas company;
- You have complained to an overseas entity and to us about the same or a related matter;
- We have our electronic data stored on secure cloud servers that are located outside of Australia.
11. Quality of personal information
To ensure that the personal information we collect is accurate, up to date and complete we:
- Record information in a consistent format;
- Where necessary, confirm the accuracy of information we collect;
- Promptly add updated or new personal information to existing records
- Regularly audit our contact lists to check their accuracy.
We also review the quality of personal information before we use or disclose it.
12. Storage and security of personal information
We take steps to protect the security of the personal information we hold from both internal and external threats by:
We destroy personal information in a secure manner when we no longer need it but in any event we will generally destroy unrequired records and data after seven (7) years.
13. Accessing and correcting your personal information
Under the Privacy Act (Australian Privacy Principles 12 and 13) you have the right to ask for access to personal information that we hold about you and ask that we correct any errors in that personal information. You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we will give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to do so.
We will ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible. If we decline to give you access to, or correct your personal information, we must notify you in writing setting out the reasons for the same.
If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We will do so unless there is a valid reason not to do so.
If we refuse to correct your personal information, you can ask us to append to it (for example attach a link) a statement that you believe the information is incorrect and why.
14. How to make a complaint
If you wish to complain to us about how we have handled your personal information you should do so in writing. If you need help lodging a complaint you may contact us for assistance.
If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.
If we decide that a complaint should be investigated further, the complaint will usually be handled by a senior Manager other than a Manager who may be the subject or materially involved with the function or activity that we are carrying out.
We will tell you promptly that we have received your complaint and then respond to the complaint within 30 days.
If you are not satisfied with our response you may ask for a review by a more senior Manager within PALE BLUE DOT GAMES PTY LTD (ACN 605 400 780).
15. How to contact us
You can contact us by email at: firstname.lastname@example.org