APG CONNECT PRIVACY & GDPR POLICY
Intent
This is a public and member policy document outlining our privacy management and conditions that you accept and agree to by your acceptance of continuing to access websites, device applications and other associated services provided by the Australasian Project Group Pty Ltd (APG Connect) with ABN 15 612 493 062.
Scope
This agreement is between you and the Australasian Project Group Pty Ltd (APG Connect) and any partnered or subsidiary companies. It applies to all users of APG Connect Services. Further terms and conditions apply to services offered to members and are agreed to in addition to this agreement. "APG Connect", "we", "our" or "us", are references to APG Connect and subsidiary companies depending on the context. References to "you" or "your", are to the individual or entity with whom APG Connect enters into this Agreement by default of your acceptance to use any of the services or purchase any of the products available through our lending platform.
Policy
1.We respect your privacy
1.1.APG Connect respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.
1.2.We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).
1.3.In providing you with our websites apgpro.com.au ("Websites”) including our related products, services such as participating in accessing any of the products and services contained on the Websites; including namely participating in taking loans with APG; participation in member services; or communicating electronically with us (collectively the "Services”) we may collect, process or be provided with your personal data.
1.4.By visiting or continuing to use our websites you are accepting and consenting to the practices described in this policy.
1.5.We may update this Privacy Policy from time to time, so it should be reviewed regularly for updates and changes.
1.6."Personal information" is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.
1.7.You may contact us in writing via email to admin@apgpro.com.au
1.8.Or you can send us in writing any letters to PO Box 1091, Pacific Fair, QLD 4218, Australia.
2.What personal information is collected?
2.1.APG Connect will, from time to time, receive and store personal information you submit to our websites, provided to us directly or given to us in other forms.
2.2. You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.
2.3. We may collect additional information at other times, including but not limited to, when you provide feedback when you provide information about your personal or business affairs, agree to validation of your identity, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
2.4.Additionally, we may also collect any other information you provide while interacting with us.
2.5.We endeavour only to capture information that is necessary to provide our Services to you in compliance with our legal and regulatory obligations.
3.Legal basis for collection
3.1.APG may collect and process your information because:
a.we have a contract with you;
b.you have given us permission to do so;
c.you have applied for a Service from us; or
d.to comply with the law
4.How we collect your personal information
4.1.APG Connect collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we engage in business activities with you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.
4.2.By providing us with personal information and answering of any feedback forms or questionnaires on content preferences, you in turn consent to the supply of that information subject to the terms of this Privacy Policy.
5.How we use your personal information
5.1. APG Connect may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you.
5.2.APG Connect will use personal information only for the purposes that you consent to. This may include:
a.to provide you with products and services during the usual course of our business activities;
b.to administer our business activities;
c.to provide you with information requested from us, relating to our Services and to provide information on other Services which may be of interest to you’;
d.to improve our Website and our Services;
e.to verify your status and confirm any information you have provided to us;
f.to distribute APG Connect products and services to you;
g.to verify compliance with the terms and conditions in relation to the use of our Services;
h.to compare the personal data provided with third party databases in order to verify its accuracy and confirm your identity to comply with relevant regulations that apply to our APG Connect ecosystem.
i.to meet our regulatory, legal and compliance obligations in meeting our obligations to you; or
j.to notify you about any changes to our Website or improvements and changes to our Services.
5.3.We will only contact you when you have provided consent and only by those means you have provided consent for.
a.manage, research and develop our products and services;
b.provide you with information about our products and services;
c.communicate with you by a variety of measures including, but not limited to, by electronic notification, other digital services, telephone, email, SMS or mail;
d.investigate any complaints
e.satisfy Australian and International legal requirements for reporting your participation in our services, purchasing and/or using our products.
5.4.If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.
5.5.We may disclose your personal information to comply with a legal requirement such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.
5.6.If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.
6.Disclosure of your personal information
6.1.APG Connect may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.
6.2.APG Connect may disclose your personal information to government agencies as required by legislation insofar as reasonably necessary, or for the purposes set out in this privacy policy.
6.3.If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy.
7.General Data Protection Regulation (GDPR) for the European Union(EU)
7.1.The GDPR is applicable to residents of the EU or where data is primarily stored or transmitted to EU countries.
7.2.APG Connect will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
7.3.We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
7.4.We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
7.5.We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure according to our GDPR Data Security Policy.
7.6.We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
7.7.We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
7.8.We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
7.9.You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.
8. Deactivating your account
8.1.If you deactivate your account on the Lending platform, your account will be marked in our database as having been "Deactivated” however we will keep your account trading information in our database for such a time period as legally required by any regulatory reporting we need to adhere to.
8.2.The purpose of retaining such information is to ensure we can deter fraud as best as possible by still being able to report any suspicious activity even after the closing of any account and the opening of a new account.
8.3.Upon deactivating your account your personal information will no longer be used for any other purposes except as necessary to prevent fraud and assist with any law enforcement as may be required by law, the Australian Taxation Authority, or in accordance with this Privacy and GDPR Policy.
9.Your rights under the GDPR
9.1.If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. APG Connect complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU
9.2.Except as otherwise provided in the GDPR, you have the following rights:
a.to be informed about how your personal information is being used;
b.access your personal information (we will provide you with a free copy of it);
c.to correct your personal information if it is inaccurate or incomplete;
d.to delete your personal information (also known as "the right to be forgotten");
e.to restrict processing of your personal information;
f.to retain and reuse your personal information for your own purposes;
g.to object to your personal information being used; and
h.to object against automated decision making and profiling.
9.3.Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy and our GDPR Data Security Policy.
9.4.We may ask you to verify your identity before acting on any of your requests.
10.Hosting and International Data Transfers
10.1. Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. These may include but are not limited to Australia and various CDN networks.
10.2. We and our other group companies have offices and/or facilities in Australia and various Content Delivery Networks. Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from APG Connect, Data Protection Officer.
10.3. The hosting facilities for our website are situated in Australia and various Content Delivery Networks (CDN). Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from APG Connect, Data Protection Officer.
10.4. Our Suppliers and Contractors are situated in Australia and various CDN. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website.
10.5. You acknowledge that personal data that you openly submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
11. Security of your personal information
11.1.APG Connect is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
11.2. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
11.3. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
12. Access to your personal information
12.1. You may request details of personal information that we hold about you in accordance with the provisions of the Australian Privacy Act 1988 (Cth), and to the extent applicable to the EU GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us admin@APGpro.com.au
12.2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.
13. Complaints about privacy
13.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to admin@APGpro.com.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
14. Changes toPrivacy Policy
14.1. Please be aware that we may change this Privacy Policy in the future to consider new laws, technology, changes to our operations and any changing regulatory environment. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.
15. Website
15.1. When you visit our website/s
·When you come to any of our websites, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve. our service.
15.2.Cookies
·We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site.
·Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites.
·Our websites may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords.
These ads may. appear on this website or other websites you visit.
15.3. Third-party sites
·Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only.
·Links to third party websites do not constitute sponsorship or endorsement or approval of these websites.
·Please be aware that APG Connect is not responsible for the privacy practices of other such websites.
·We encourage our users to be aware, when they leave our website, to read the privacy statements of each website that collects personally identifiable information.
16.Contacting Us
APG Connect welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday.
Attn: Australasian Project Group (APG Connect)
RE: Privacy Policy
Post: P.O.Box 2268, Runcorn, Qld 4113, Australia
Website: www.apgpro.com.au
Email: admin@apgpro.com.au
Version: Updated on 21st March, 2023
END.
