Internet Privacy Policy

This privacy statement is effective as of September 11th , 2020. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws. 

In this policy, “Ampion”, “us”, “we” or “our” means Ampion Holdings Pty Ltd (ACN 626 522 852) and all subsidiaries operating under the Ampion group.

We will identify how we will protect you ("your personal data"; "Your Data") and the rights you have in relation to the processing of your personal data.

When handling personal information, we will comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) and other applicable legislation (such as Australian State and Territory health privacy legislation) where required.

This Internet Privacy Policy relates to the collection and use of personal information, as relates to the APP, and is in reference to the data supplied to us through your conduct on the web site. If you have objections to the privacy policy or the collection of Your Data, you should not access this site. 

We collect data in two ways: 
•    directly – for example when you provide personal data to sign up or register for a service on our site; and
•    indirectly – for example through usage of industry standard website technology using such means as server-logs and cookie-content.

We recognise the importance of protecting the privacy of information collected relating to visitors to our web site, or the actions they perform. We attach great importance to your right to particular information that is capable of identifying an individual (“Your Data“). 

This Internet Privacy Policy governs the manner in which your personal data, obtained through the web site, will be dealt with. 
This Internet Privacy Policy should be reviewed periodically so that you are updated on any changes. We reserve the right, at our discretion, to modify or remove portions of this Internet Privacy Policy at any time. This Internet Privacy Policy is in addition to any other terms and conditions applicable to the web site and we do not make any representations about any third-party web sites that may be linked to this web site.
 
If our information practices change or are updated at some time in the future, only data collected from the time of the policy change forward will adhere to our updated practices.

Data Collection
Ampion undertakes to collect Your Data by means that are fair, legal and transparent.

If you visit this web-site, your web-browser automatically discloses, and our web-server automatically logs, the following information: the date and time, the IP address from which you issued any request to our site, the type of browser and operating system you are using, the URL of any page that referred you to our page, the URL you requested, and whether your request was successful. 
This data may or may not be sufficient to identify you.

Any additional data that you provide, e.g. in a web-form or by completing our contact request form or adding comments in a blog or any other community commentary section, may also be logged and be identified as Your Data
This data may or may not be sufficient to identify you.

Any additional data that your web-browser automatically provides may also be collected and logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in ‘cookies’ and submits them each time you request a web-page within a particular domain (such as ampion.com.au). 
This data may or may not be sufficient to identify you.

Should you disclose personal data to Ampion in conjunction with an identifier such as your name or your contact details, Ampion will collect Your Data. Moreover, any data that becomes available to Ampion through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.

Subject to the qualifications immediately below, Ampion undertakes to collect Your Data directly from your interaction with our site, and not from other parties.

This undertaking is qualified as follows:
Where Ampion reasonably considers that the protection of its financial interests requires that it gather Your Data from other sources, or from additional sources. This applies in particular where Ampion has a lending exposure to you, and seeks information about your creditworthiness;
where Ampion reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your Data from other sources. This applies in particular to consumer profile data.

Where Ampion collects Your Data from sources other than you, it undertakes:

To do so only by legal means;
To do so only with your Consent; and
To declare to you what sources it uses, and under what circumstances.

Data Security
Ampion undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Ampion undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
Ampion undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Ampion undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by Ampion’s staff-members and contractors.

These include:
General awareness sessions for staff in relation to privacy; access control.
Taking steps to limit access to Your Data for those staff and contractors who have legitimate reasons to access it; particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour; declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour clear communication of policies and sanctions; and
processes to audit, to investigate and to impose sanctions.

Data Use
Data use refers to the application of Your Data by any part of Ampion, or any staff-member or contractor of Ampion in the course of their work.
Ampion undertakes to use Your Data only for: The purposes for which it was collected; such other purposes as are subsequently agreed between Ampion and You; such additional purposes as may be required by law. In these circumstances, Ampion will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and such additional purposes as are authorised by law (in particular to protect Ampion’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Ampion or have committed a breach of the criminal law).
Ampion undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
Ampion undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.

Data Disclosure
Disclosure refers to making Your Data available to any party other than Ampion or its subsidiaries and you. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
Ampion undertakes to disclose Your Data only under the following circumstances:
In the course of business being conducted between You and Ampion or a member of the group, where disclosure is necessary to a contractor. Where Your Data is disclosed in this way, Ampion undertakes to exercise control over Ampion’s contractors to ensure that their actions are compliant with these Terms; in other circumstances that are directly implied by the purpose agreed between You and Ampion at the time of data collection or subsequently. Where Your Data is disclosed in this way, Ampion undertakes to exercise control over Ampion’s contractors to ensure that their actions are compliant with these Terms; with your consent, or at your request;
where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, Ampion will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Ampion believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life or health of some person), provided that Ampion will apply due diligence to ensure that the exercise of the permission is justifiable.
In all cases, Ampion undertakes to disclose the minimum amount of Your Data as is necessary for the particular circumstances.

Data Retention and Destruction
Subject to the qualifications immediately below, Ampion undertakes:
To retain Your Data only as long as is consistent with its purpose; and to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.

This undertaking is qualified as follows:
Your Data may be retained in Ampion’s logs, backups and audit trails within short-term retention cycles that are devised to protect the company’s operations. In such cases, Your Data will be destroyed in accordance with those cycles; Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena or a warning by a law enforcement agency that delivery of a court order is imminent.

In these circumstances, Ampion:
Will take any reasonable steps available to it to communicate to you that Your Data is being retained, unless it is precluded from doing so by law; and will only retain Your Data while that provision is current, and will then destroy Your Data; will take any reasonable steps available to it to communicate to you that Your Data is being retained, unless it is precluded from doing so by law; and will only retain Your Data while that provision is current, and will then destroy Your Data; Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect Ampions’ interests, e.g. if it believes on reasonable grounds that You have failed to fulfill your undertakings to Ampion or have committed a breach of the criminal law). In these circumstances, Ampion will only retain Your Data while that situation is current and will then destroy Your Data.

Access by You to Your Personal Data
Ampion undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, Ampion undertakes to enable access: Conveniently; without unreasonable delay; and without cost.
Ampion undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Ampion (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, Ampion undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.

You undertake:
Not to seek access for frivolous purposes, or unreasonably frequently;
to accept that deletion of some data may not be consistent with the provision of particular services by Ampion to you.

Information about Data-Handling Practices
Ampion undertakes to make information available to you about the manner in which Ampion handles Your Data:
In general terms, in a readily accessible manner; and in more specific terms, on request. Where Your Data is disclosed to a contractor, Ampion undertakes to make information available to you on request about the manner in which Ampion’s contractors handle Your Data.
Ampion undertakes to ensure that the information provided is meaningful and addresses your concerns.

You undertake:
Not to seek such information for frivolous purposes, or unreasonably frequently; and
to accept that the disclosure of excessive detail may harm the security of Your Data and Ampion’s business processes, and may harm Ampion’s commercial interests.
Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these terms, or about Ampion’s behaviour in relation to these terms, you undertake: To communicate them in the first instance: to Ampion only; in sufficient detail; through a channel made available by Ampion for that purpose; Ampion undertakes: To provide one or more channels for communications to Ampion, which are convenient to users; to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of communication, the date and time it was registered, and Ampion reference-code for the communication; to promptly provide a response to the communication, in an appropriate and meaningful manner. You further undertake to not pursue Ampion through any Regulator or the media: until and unless Ampion has had a reasonable opportunity to respond to the initial communication; and while Ampion and you are conducting a meaningful dialogue about the matter.

Additional Definitions
Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.
Consent means your concurrence with an action to be taken by Ampion. Consent may be express or implicit, but in either case must be informed and freely-given.

Contact
If you have any questions or concerns regarding your privacy, or if you would like to make a complaint, please contact the Ampion Privacy Officer at:

Privacy Officer
Ampion Holdings Pty Ltd
Level 7, 440 Collins Street
Melbourne VIC 3000
Australia
privacy@ampion.com.au