The last update to this document was February 2022.
Glow Technologies Pty Ltd ABN 44 645 413 207 of First floor, 121 High Street, Kew, Vic 3101 (Glow, we, us, our) and its related companies are committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business.
Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices.
In this document:
• "APPs" means the Australia Privacy Principles set out in the Privacy Act;
• "App User" means a person who access or uses the Plant App on behalf of a Glow Customer, using the Glow Customer's account or login credentials or otherwise with the authorisation of the Glow Customer;
• "Glow Customer" means a business or other organisation that has a licence with us to use the Plant App;
• "personal information" has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
• "Plant App" means our plant and equipment risk management application, which assists App Users to assess plant and equipment for Glow Customers (or their clients) against certain criteria and applicable standards, and allows App Users to generate reports for the plant and equipment that have been assessed;
• "Privacy Act" means the Privacy Act 1988 (Cth); and
• "sensitive information" has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person's racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.
1. How we collect your personal information
We collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.
Some of the common ways in which we may receive personal information directly from you include:
• if you are an App User:
(i) when you register a user account with the Plant App and provide us with your account details (such as your name and e-mail address); and
(ii) when you upload content to, or interact (in an identifiable manner) with, the Plant App while you are logged into your user account (for example, where you upload new or updated plant or equipment templates);
• when you make an inquiry or order in relation to goods or services, including through our website located at www.plantriskassessment.com.au (the Website);
• when you enter into contracts with us for our goods or services;
• in administering and performing any contracts with service providers;
• when you apply for a role with us;
• from correspondence (whether in writing or electronically) or when you contact us via telephone, social media platforms or other means;
• when you upload content to or interact (in an identifiable manner) with our Website or our social media pages;
• while conducting customer satisfaction and market research surveys;
• if you attend any of our premises, we may record certain contact details so that we can comply with applicable laws, and we may also record your image and/or voice if we have surveillance systems operating at those premises;
• when administering any of our services; and
• as otherwise required to manage our business.
Where it is reasonably practical to do so, we will collect your personal information directly from you. However, in certain cases we may collect personal information from publically available sources and third parties such as:
• Glow Customers that you work for;
• the clients of Glow Customers, if you are using the Plant App to provide services to such clients;
• our suppliers, contractors and business partners; and
• where you are applying for a position with us: recruitment agencies, your employers, your referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications).
If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
2. Types of personal information we collect
The types of personal information we collect about you depends on the circumstances in which the information is collected.
Typically, the types of personal information we may collect can include (but is not limited to) your name, address, email address and phone numbers.
For App Users, the types of information that we commonly collect include:
• your user account registration information (which you provide when registering with the Plant App);
• usage data about how you have used the Plant App (for example, templates that you have accessed and uploaded / modified);
• details of your device details and operating systems; and
• if you have provided us with permission to access your device location when using our app, we may collect information about your geographical location.
If we enter into contracts with you, or if you request or receive goods or services from us or have any other commercial dealings with us, we may also collect your signature, date of birth and your billing and payment information.
If you are an individual contractor to us or apply for a role with us, we may collect information relevant to your engagement with us including qualifications, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).
If you attend a premises we operate or manage, we may:
• collect certain contact details that you provide to us (which may be via digital check-in apps), including the date and time of attendance, including so that we can comply with applicable laws (such as public health directives). If we collect such information to comply with a particular law, we will only use and disclose it in accordance with applicable laws; and
• record your image and/or voice through the use of Closed-Circuit Television (CCTV) systems footage of you via our CCTV devices, for the purposes of managing security of the premises and health and safety of occupants and the public generally.
If you call us via telephone, we may monitor and in some cases record such telephone conversations for staff training, quality assurance and record-keeping purposes.
If you access our Website, we may utilise cookies to collect additional information about your use of our Website. Please see the cookies section below (paragraph 7) for further details for further details of the types of information collected and how you can control what information is collected. If you are on our Website and you have provided us with permission to access your device location, we may collect information about your geographical location.
If we communicate with you by email, we may use technology to identify you so that we receive feedback on how you have engaged with our email. This may include collecting data on matters such as which emails you open, which links you click, which e-mail client you use, the type of device that you used to open the e-mail (mobile device or desktop computer) and the country geolocation of your IP address.
We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. The main types of sensitive information we may collect include:
• details of injuries (i.e. health information) that may occur on our premises or arising through the use of our goods or services;
• details of disabilities or allergies (i.e. health information) you notify us of so we can accommodate any special requirements when you attend our premises;
• details of an individual's membership of professional associations and affiliations with relevant industry bodies or organisations, where this is relevant to our business dealings or employment relationship with you.
If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services and/or certain functionality of the Plant App or our Website.
3. Our purposes for handling your personal information
The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
We may use or disclose your personal information:
• for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
• for other purposes to which you have consented; and
• as otherwise authorised or required by law.
In general we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.
Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:
• to provide you with our goods and services, including use of the Plant App;
• to receive goods or services from you;
• to verify your identity;
• to consider you for a job (whether as an employee or contractor) or other relationships with us;
• to provide you with tax invoices for our goods and services;
• to operate, monitor, develop and improve our Website, the Plant App and our goods and services;
• to optimise and customise the user experience (including content and advertising) for users of our Website, the Plant App and our services;
• to facilitate communications via our Website, the Plant App and our social media platforms, including communications with us or with other users of those platforms via direct messaging and posting to forums;
• to facilitate your entry and participation in a competition or trade promotion;
• to protect the security and integrity of the Plant App, the Website and our services;
• to contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our goods and services;
• to comply with our legal and regulatory obligations;
• to protect the security, health and safety of our premises, facilities, personnel and visitors;
• to address any issues or complaints that we or you have regarding our relationship; and
• to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
4. Who we disclose your personal information to
• our suppliers, contractors and organisations that provide us with technical and support services or who manage some of our business functions;
• our related entities (who may use and disclose the information in the same manner we can);
• our accountants, insurers, lawyers, auditors and other professional advisers;
• any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees); and
• in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors.
If you subscribe to our mailing list your contact information may be collected and processed by our e-mail marketing service provider. Our e-mail marketing service provider will use these details to send you the newsletters and other materials you have requested, and to allow you to manage your subscriptions with us (for example if you wish to unsubscribe). We also use our e-mail marketing service provider to conduct analytics on your engagement with our e-mails, as described in section 2.
We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.
If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
If we have public sections on the Plant App and you post information to those public sections, you acknowledge that such information may be available to be viewed by other users of the Plant App. You should use discretion in deciding what information you choose to post to any public areas on our Plant App.
5. Social media platforms
We use social media platforms such as Facebook, Twitter and LinkedIn to communicate with the public about our services and businesses. We may collect the information that you choose to share with us through these platforms, including photos, videos and comments and posts.
These social media platforms have their own privacy policies, and may handle your information for their own purposes. You can access the privacy policies for Facebook, Twitter and LinkedIn on their websites.
If you choose to use these social media platforms to communicate with us or with other parents and guardians, please be mindful that certain pages within these platforms may be publically available. We encourage you to use the privacy settings available on each platform. If you would like to contact us directly, you can do so using the contact details in section 13.
6. Overseas transfers of personal information
Some of the third parties to whom we disclose personal information may be located outside Australia. The countries in which such third party recipients are located depend on the circumstances.
These overseas recipients may provide us with services such as billing, payment, IT and other administrative services (including offshore data hosting and processing, data analytics, help desk and data-entry).
Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.
By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
7. Storage and protection of personal information
We will hold personal information as either secure physical records, electronically on our network, in cloud storage, and in some cases, on third party servers which may be located overseas.
We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases.
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law. We may need to retain records containing personal information to comply with record keeping obligations, and for other legitimate business purposes (such as quality assurance).
8. Direct marketing
Like most businesses, marketing is important to our continued success. We therefore like to stay in touch with customers and let them know about new offers and opportunities. We may provide you with information about products, services and promotions either from us, or from third parties which may be of interest to you, where:
• you have consented to us doing so; or
• it is otherwise permitted by law.
You may opt out at any time if you no longer wish to receive direct marketing messages from us. You can make this request by contacting our Privacy Officer.
We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Website and other internet activity. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Website.
10. Accessing and correcting your personal information
You may contact our Privacy Officer (see section 13) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access (which we will only do in accordance with applicable laws), we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
We will respond to all requests for access to or correction of personal information within a reasonable time.
We collect information in relation to employees as part of their application and during the course of their employment, either from them or in some cases from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications). Such information may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).
Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.
12. Resolving personal information concerns
When contacting us please provide as much detail as possible in relation to your question, concern or complaint.
We take all complaints seriously, and will respond to your complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]
13. Contact details of Privacy Officer
The contact details for our Privacy Officer are as follows:
Postal address: 20 Ramsay Avenue, East Kew, 3102
Telephone: 1300 018 306
Email: [email protected]
Our Website may contain links to other websites operated by third parties. We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices and procedures.