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Privacy Policy

Last Updated 27 February 2024

1.       Our Commitment to Privacy

Clean TeQ Water Limited (Clean TeQ Water) recognises the importance of privacy and is committed to protecting the privacy of its shareholders, employees and other related parties when handling your personal information. From the outset, it should be noted that all information or opinion about you as an identified, or reasonably identifiable, individual (that is in Clean TeQ Water’s control) is handled and managed with the utmost confidentiality by Clean TeQ Water.

2.       Purpose

This Privacy Policy explains how Clean TeQ Water and other companies in the Clean TeQ Water Group collects, holds, uses, discloses, protects and otherwise handles your personal information and credit information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

3.       Terminology

In this policy the expressions ‘the Company’, ‘we’, ‘it’, ‘us’ and ‘our’ are a reference to Clean TeQ Water.

4.       What is Personal Information?

The expression ‘personal information’ used in this policy relates to information or an opinion about you from which you can be reasonably identified.

5.       What is Sensitive Information?

The expression ’sensitive information’ relates to personal information about a person’s racial or ethic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record or health, genetic, genomic and biometric information. Sensitive Information can be inferred from information which is not sensitive information.

6.       Why we collect Personal Information?

The Company only collects personal information about an individual where the information is reasonably necessary for one or more of our functions, operations or activities or to comply with the law. (Primary Purpose). The kinds of personal information collected and held, and how that information is collected and held and the purpose for which that information will be collected, held, used and disclosed will depend on the circumstances. For example, we collect and process your personal information as necessary in order to provide you with our services and/or products, as part of our general business operations, employees and contractors, emergency management, to assist with queries, to consider applications from prospective employees, contractors or service providers or to comply with the law.

7.       What kinds of Personal Information do we collect?

Depending on the circumstance, below are the types of personal information which we may collect from you and hold include, without limitation:

  • contact information such as your name and address, telephone numbers and email address;;
  • identification information such as name, date of birth, current or previous address;
  • trade references – name of entity, ABN, contact name, telephone number, fax number, email, years trading with you;
  • business details, including Tax File Number and Australian Business Number (“ABN);
  • financial information, including bank account details;
  • information about our services and/or products acquired or supplied;
  • information from enquiries made; and
  • communications between us and an individual;

Generally, the Company will not collect sensitive information about you. If the Company needs sensitive information, it will seek your consent when it collects this information and comply with the APPs contained in the Privacy Act 1988 (Cth).

8.       Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our websites, we may collect the following information from you automatically through cookies or similar technology:

  • your server address;
  • your top-level domain name (for example, .com, .gov, .au);
  • the date and time of your visit to the site;
  • the pages you accessed;
  • the previous site you have visited; and
  • the type of browser you are

We use cookies in a range of ways to improve your experience on our website, including:

  • for essential purposes for the basic function of our website;
  • for performance and functionality to manage and improve our website;
  • to improve our business

You can set your browser to accept or decline cookies, however, some of our website features may not function or function fully as a result.

9.       How we collect Personal Information?

Collecting information from you

How the Company collects your personal information will largely depend on whose information it is collecting. If it is reasonable and practicable to do so, the Company will collect personal information directly from you in a number of ways including:

  • directly by our employees when you seek, or enquire about, our services;
  • when you use our website or complete a form on our website or provided directly by our employees;
  • from a third party such as a contracting company or through third party service providers (including recruitment service providers providing services to us).

In some circumstances, where it is unreasonable or impracticable to collect information from you or to supplement information provided, we may collect information about you from a third-party source (including public records). In such a case we will take reasonable steps to ensure that you are made aware of the personal information provided to us by the third party.

You need not provide all the information requested by us, but this may prevent us from providing some or all of our goods or services to you..

Collecting information from third parties

The Company may also collect information about you from other people (e.g. a third-party administrator) or independent sources. For example, the Company may collect personal information about you from its services providers, including the Company’s share registry. However, the Company will only do so where it is not reasonable and practicable to collect the information from you directly. Where the Company has collected your information from a third party, such personal information will be held, used and disclosed by the Company in accordance with this Privacy Policy.

When you provide the Company with personal information, you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments.

Collecting information from visits to the Company’s website

The Company may collect information based on how you use its website including through ‘cookies’, web beacons and other similar technologies. Cookies are small text files that websites or apps may place on your computer or device to collect non identified/anonymous information about the users of its website such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to the website.

The Company uses cookies to provide you with a more consistent experience across our services and reserves the right to ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. This information is collected to analyse and improve the Company’s website, its marketing campaigns and to record statistics on web traffic.

No attempt is made by the Company to use this information to personally identify you. We record a variety of information from interactions with our online services including IP address, locations data (where available and not disabled by the user), dates, times, and other user activity. In most cases we will not be able to reasonably identify an individual from the information collected. However, if cookie information is linked with personal information we hold about you as set out above, this cookie information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser.

Unsolicited information

If the Company receives personal information that it has not requested, or it determines that the personal information received is not reasonably necessary to provide its services, the Company will take reasonable steps to de-identify or destroy that personal information.

10.    How we hold your Personal Information?

The security of your personal information is of paramount importance to the Company and it takes reasonable steps to protect the personal information it holds about you from misuse, loss, unauthorised access, modification or disclosure. The Company has a number of safeguards in place to protect the personal information we hold, including password protected databases, staff training and system firewalls. The Company maintains password security and restricted access to all electronic documents containing personal information

All employee related documentation is kept within a secure server, which is only accessible by the Human Resources department.

The Company’s payroll is outsourced to a third-party provider, ADP Australia. Within ADP, the collection and use of personal data is limited to those elements that are reasonably needed only to achieve the specific purposes permitted by the Company or its employees.

Personal Data is retained in accordance with the records retention schedules to ensure that records containing Personal Data are retained as needed to fulfill the applicable Business Purposes, to comply with applicable laws, or as advisable in light of applicable statutes of limitations.

The Company will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purpose for which the information was used or disclosed.

11.    How do we use your Personal Information?

The Company will not use or disclose personal information that we collect for any purpose other than the primary purpose of collection unless:

  • such use is related to the primary purpose and you would reasonably expect us to use or disclose the information for that other purpose;
  • in the case of direct marketing not related to our activities – we have obtained your prior consent (unless it is not reasonably practicable to seek your consent and we otherwise comply with the requirements of the Privacy Act); or
  • the use or disclosure is otherwise permitted under the Privacy Act or required to comply with any relevant laws, regulations, codes or practice and court orders.

As a general rule, we do not engage in direct marketing activities. To the extent that we do engage in direct marketing in the future, however, you may at any time request us not to provide you with any further direct marketing communications by contacting us via the details set out below.

By using our website, you will be deemed to consent to us using your personal information collected by our website for the following purposes:

  • notifying you about any changes to the information which currently exists on the website;
  • notifying you in the future about new information relevant to our services; and
  • monitoring your use of our

12.    How is Personal Information disclosed to Others?

The Company does not sell, rent or trade personal information to, or with, third parties.

The Company’s website may contain links to other websites. The Company does not share your personal information with those websites, and it is not responsible for their privacy practices.

In some circumstances your personal information may be disclosed to service providers that perform a range of services on behalf of the Company including:

  • mailing houses and printing companies;
  • auditors and solicitors;
  • share registry providers;
  • information technology vendors; and
  • other

Personal information may be disclosed to third parties within or outside of Australia.

When making public or disclosing information that was prepared using personal information, where practical we will de-identify, aggregate or anonymise the information to remove the personal information.

If the Company transmits your personal information over the internet (for example to third parties who hold data outside Australia) we will take reasonable steps to maintain the security of any personal information to prevent misuse and unauthorised access. Despite these protection mechanisms, you should be aware there are inherent risks associated with the transmission of data over the internet and we cannot guarantee any transmission will be completely secure.

Where the Company discloses your personal information to its service providers, it will take steps to ensure that they are authorised to only use personal information in order to perform the functions required by the Company or you and in accordance with the Privacy Act 1988 (Cth).

The Company may also disclose your personal information to law enforcement agencies, courts or government agencies where required to comply with specific legal requirements. In particular, the Corporations Act 2001 (Cth) requires certain information about you to be included in the Company’s registers which are able to be accessed by the public.

13.    Do you have to provide Personal Information?

You can refuse to provide personal information. However, a refusal may mean that we are unable to provide the service you or an organisation has asked for, for example if we propose to provide a service and we are unable to complete the process to do so.

14.    Data Security

We will take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. Any personal information which is no longer required for any purpose by the Company will be destroyed.

The company will also take reasonable steps to ensure that personal information shared with third party service providers, such as ADP, have implemented reasonable technical, physical and administrative safeguards to help protect the sensitive personal data stored within their systems from unlawful use and unauthorized disclosure. Where relevant, the effectiveness of the safeguards and controls in place with third party providers will be reviewed, such as obtaining annual independent System and Organisation Control reports.

In the event of a data breach, we will notify you, as well as the Information Commissioner involving personal information which is likely to result in serious harm.

15.    Ensuring your Personal Information is up to date

It is important that the personal information we collect from you is accurate, complete and up to date.

During the course of our relationship with you, we will ask you to tell us of any changes to your personal information. However, you can contact us at any time to update your personal information or to tell us that the information we hold about you is inaccurate or incomplete.

16.    Access, Correction and Further Information

We will provide you with access to your personal information held by us, unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us on the details below if you:

  • wish to have access to the personal information which we hold about you;
  • consider that the personal information which we hold about you is not accurate, complete or up to date; or
  • require further information on our personal information handling

If you believe that the Company has not protected your personal information as set out in this privacy policy or has denied you access to your personal information in potential breach of the Privacy Act, you may lodge a complaint by writing directly to the Company. We will endeavour to respond to your request within 30 days. All such complaints will be handled with the appropriate discretion.

If you are not satisfied with the result of your complaint to the Company or if your complaint remains unresolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.

Further information on the Act and the Australian Privacy Principles, can be found at www.oaic.gov.au

17.    How to Contact Us?

All correspondence should be directed to the Privacy Officer on:

Tel:               +61 3 9797 6700

E-Mail:          [email protected]

Mail: Clean TeQ Water Limited PO Box 227

Mulgrave VIC 3170

18.    Disclosure

From time to time, we may change our policy on how we handle personal information or the sort of personal information which we hold. Any changes to our policy will be published on our website www.cleanteqwater.com.

19.    Approved and Adopted

This policy was reviewed, approved and adopted by the Board on 27 February 2024.