Version as at June 2018.

This is the Bowen Group Australia Pty Ltd Privacy Policy.

This policy sets out how and why we collect, hold use and disclose certain information. This policy reflects that most of the personal information that we deal with relates to our own customers or projects involving them.

We are bound by the Australian Privacy Principles under the Privacy Act 1988. A copy of the Privacy Act 1988 which includes the Australian Privacy Principles can be found at:

https://www.legislation.gov.au/Series/C2004A03712

This Privacy Policy shall be governed by and construed in accordance with the laws for the time being in force in the State of Victoria, Australia.

Who we are and how can we be contacted
As we collect information, we are obliged to tell you about us and how we can be contacted. On this basis, please be advised that our details are as a follows:

Bowen Group Australia Pty Ltd
11 Ramage Street, Bayswater VIC 3153
Phone: 03 9721 5600
Fax: 03 9721 5622
www.bowengroup.com.au
solutions@bowengroup.com.au

The kinds of personal information that we collect and hold
We will only collect information about our customers which is reasonably necessary for us to collect in order for us to provide a normally accepted level of customer service and to market our products and services.  As our customers are typically businesses we only collect personal information about individuals in limited cases, mainly if the customer is an individual (as opposed to an entity) or if we require a personal guarantee from an individual on behalf of the customer.  If we require a personal guarantee specific consent for this will be provided in our credit application document.

As our customer, there is certain personal information that we ordinarily collect as part of doing business with you. This information includes names, contact information (including current business addresses, phone numbers and email address), and some banking information depending on how you choose to transact with us. We will not collect private contact information where the business/professional contact information is not satisfactory for our purposes.

Depending on the nature of a transaction, we may need to collect other personal information, sensitive information and credit information. We may require information about you and/or your company such as credit history and creditworthiness.

We will only collect such information as is necessary to give you the best possible level of customer service possible in the circumstances in accordance with the law.

At times we may obtain your personal information from other complimentary service providers within our industry. We will take reasonable steps to ensure that you have consented to us collecting this information before we collect it.

The purposes for collecting, holding, using and disclosing the information
The purpose of us collecting information is to provide appropriate advice to those purchasing our products and services and to market our products and services. We will only collect and hold such information as reasonably necessary to give effect to these purposes.

We retain contact information about you indefinitely.  This allows us to serve you in the future and send you information regarding industry updates and our products and services. (direct marketing.)

We may also disclose the information to an Affiliate, for example: our accountants need some information about our billing history and projects we are working on in order to give us proper advice about our business. For this purpose “Affiliates” includes our agents, contractors and professional advisors.  We will only provide information to Affliates with whom we have an agreement regarding the confidentiality of our information or to Affliates who are otherwise obligated to maintain our confidences.  Nonetheless, we disclose de-indentified information to Affiliates wherever possible. De-indentified information is information that has had personal information removed such as aggregate data, an example would be giving our accountant our billing history for a matter without giving them any other information about you.

An Affiliate who is acting on our behalf may use or disclosure your information in accordance with this Privacy Policy and may contact you directly regarding your information.

In all cases, we will not disclose personal information where the disclosure would be a breach of the law.

Anonymity & Pseudonymity
You can request to deal with us anonymously or by using a pseudonym. We will assess such requests on a case by case basis and will try to accommodate such request where practicable.

However, it is very difficult for us to deal with an anonymous or pseudonymous customer (as opposed to an individual making the order on behalf of a customer).  The exception to this would for any orders made on a COD cash basis.

Also, we will only collect banking information if you choose to transact with us that way, for example: payment of our account by a credit card.

If you choose not to provide information
If we request information and you choose not to provide it to us, it may affect our ability to service you in providing goods and services.  If refusing to provide the information has a specific consequence to you, you will be notified at the time of requesting collection.

Unsolicitored information
Sometimes we receive personal information which we have not requested, this may be because it has been provided to us by mistake. Within a reasonable time of receiving such personal information, we will assess whether we could have requested to collect it and whether it is required by us for our purposes.

If you supply us with personal information that we do not need to retain for our purposes then we will take reasonable steps to return it to you.

If we are provided with personal information about you and we would not otherwise have been entitled to collect such information ourselves, we will destroy such information or ensure that it is de-identified provided that it is lawful and reasonable to do so.

Our Complaints procedure
We have a complaints procedure for all issues relating to our service, this includes privacy issues. In general, our complaints procedures is that the matter is referred to one of the Directors of the company who will personally make all enquiries and ensure the complaint is dealt with appropriately. We welcome your queries and concerns about our business, including privacy. If you have a query or concern, please attention your query to:

• Mark Phillips – Director & General Manager
• John Phillips – Director

Sending personal information overseas
We are based solely in Australia however our server is hosted in the USA.  Our ERP database is housed within Seattle, Washington USA.  While we have an agreement with our service provider regarding our information, our providers may not always follow Australian privacy laws. By the fact of having dealings with us, you the customer, provide consent to information being housed on our overseas server on this basis. We do not otherwise usually send personal and business information overseas.

How can you access and correct information held by us
Within a reasonable time of a written request by you, we will either grant you access to information stored by us on your behalf or refuse to grant you access and provide reasons for our refusal.

We may withhold information about you where we are required or authorised by law to do so, specifically the pursuant to the grounds for refusal set out in Australian Privacy Principle 12. However we will take all reasonable steps to provide a compromise option instead of outright refusal wherever possible, such as using a mutually agreed intermediary.

We may demand reasonable payment for the provision of the information requested by you.

If either you or we become aware that your information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take all reasonable steps required to update our database and files with the new information.  If we have already disclosed the old information to another party, you can instruct us to advise them of the correction.

If we refuse to accept a correction provided by you, we will notify you in writing. Regardless of whether we accept or refuse your request, we will respond to you within a reasonable time.

Obtaining copies of our policy
You can access our Privacy Policy yourself at any time at www.bowengroup.com.au .

We will also supply you with a free copy of our Privacy Policy within 7 days of a request by you. We will take reasonable steps to provide you with a copy in the form requested by you, for example: if you require a hard copy, we can post one to you.

Direct marketing
If you are a customer, we may use your personal and business information where you have provided us the information (other than your sensitive information as defined by the Privacy Act 1988) for the purpose of direct marketing our products and services to you.  If we have obtained your information from someone else (such as a complimentary service provider) then we will take reasonable steps to ensure that you have provided consent to us using that information for the purpose of direct marketing our products and services.

In all cases, you can request not to receive direct marketing from us at any time. You can make this request by contacting our office on 03 9721 5600 or sending us an email at solutions@bowengroup.com.au.  Each instance of direct marketing by us will also have an “opt out” function built into the offer itself such as an unsubscribe button in the case of email promotions.
We will not provide your personal information to third parties for the purpose of direct marketing by them without your specific consent.

If you need to speak to us about any other matters please contact us.