1. Privacy Policy

Borely Pty Ltd (“BORELY” or “We”) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your personal information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.

A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/ (the “OAIC Website”).

1.1 What is personal information and why do we collect it?

Personal information is information or an opinion that identifies an individual, either directly or indirectly. Examples include your name, address, email address, phone number, IP address, and location data.

We may collect your personal information in many ways, including by telephone, email, via our website (www.borely.com.au), from your website, from media and publications, from other publicly available sources, from cookies, or from third parties. If you are a client, we may also collect additional personal information, such as your language, gender, date of birth, fax number, social network accounts, job title, work email address, and your company’s name, postal address, ABN, and/or company number. We take reasonable steps to ensure the personal information we store is accurate, complete, and up to date.

We collect your personal information primarily to provide our services to you, share information with our clients, and for marketing purposes. In doing so, we may share your personal information with third parties acting on our behalf. We may use your personal information to:

• Carry out our contract with you, if you are a client.

• Conduct research about the use of our website.

• Identify and develop new services and products for you, your organisation, or our clients.

• Conduct, monitor, and analyse our business and internal operations, including staff management.

• Communicate with you and maintain relationships with you, your organisation, and our clients.

• Carry out market research.

• Conduct investigations of suspicious or harmful activity.

• Comply with applicable laws and our regulatory, accounting, reporting, and professional obligations.

• Process and respond to your requests, inquiries, or complaints.

We may also use your personal information for secondary purposes closely related to the primary purpose, where you would reasonably expect such use or disclosure. If we wish to use your personal information for a purpose beyond that for which it was originally collected, we will seek your consent or rely on another valid legal basis in accordance with applicable law.

We do not sell your personal information to others.

1.2 Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, political associations, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:

• For the primary purpose for which it was obtained;

• For a secondary purpose that is directly related to the primary purpose; or

• Where required or authorised by law.

1.3 Third Parties

Where reasonable and practicable to do so, we will collect your personal information only from you, however, in some circumstances we may be provided with information by third parties. In such circumstances we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. In circumstances where you submit information on behalf of another person, you confirm that you have informed them of how we may collect, use, and disclose their information, the purpose for providing it, how they can contact us, the terms of this policy, and that they have consented to such collection, use, and disclosure.

1.4 Disclosure of Personal information

We may elect or be required to disclose your personal information to third parties, but only in compliance with applicable laws and for the purposes outlined above. These scenarios include disclosure to:

• our affiliated companies, offices, or service partners, including Future-Proof Solutions Pty Ltd (ACN 162 972 232);

• our outsourced service providers or suppliers to support the delivery of our services, for instance, our data centre provider for secure storage of your personal information;

• third-party service providers and consultants to ensure the security or integrity of our business, including our databases and systems, and to maintain business continuity;

• legal advisors to manage or litigate claims; and

• specific third parties authorised by you to receive information held by us.

While we aim to use suppliers or service partners that are located in Australia, however some of our suppliers and other parties are based, or may receive, access, process, host or store your information in overseas locations. Where personal information is transferred overseas, we take reasonable steps to ensure that the overseas recipient complies with the APPs or is subject to a law or scheme providing a substantially similar level of protection.

We may share your information with any individual or entity as required by law, including government agencies, if we believe in good faith that such disclosure is necessary to comply with our legal obligations or to prevent, detect, investigate, or address improper conduct that could impact BORELY or its service providers.

1.5 Security of Personal information

We take reasonable steps to ensure your personal information is stored in a manner which reasonably protects it from misuse and loss, and from unauthorised access, modification or disclosure. In doing so we are committed to:

• safeguarding all personal information that you provide to us;

• taking all reasonable steps to ensure that your personal information remains confidential and secure; and

All data is stored in written or electronic format on our servers, computers, and at various physical locations. We implement physical, electronic and procedural measures to safeguard your personal information against misuse, unauthorised access, disclosure or loss due to computer viruses or other threats. Access to personal information is limited to staff and third parties who require it for the purposes outlined in this privacy policy.

We cannot guarantee the security of your personal information and by providing or permitting the collection of your information you agree, to the maximum extent permitted by law, that you will not hold BORELY liable or make any claims against BORELY for any demands, losses, or damages, whether direct or indirect, arising out of the collection, misuse, unauthorised access, disclosure, loss or corruption of that information due to computer viruses or other sources of harm. Additionally, you will not hold BORELY liable for any loss or damage arising from the collection, use or disclosure of your personal information, except where such loss or damage results from our failure to comply with our obligations under the Privacy Act or other applicable laws.

Please be aware that our websites and electronic communications may contain links to other websites operated by third parties and unless expressly stated otherwise, BORELY is not responsible for the privacy practices or the content of those linked websites. As the privacy policies that apply to those other websites may differ from our privacy policy, we encourage individuals to read them before using those websites.

1.6 Retention

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. We will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. However, please be aware that most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years.

1.7 Access to your Personal information

The Privacy Act provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. For further information about your rights, we encourage you to visit the OAIC Website.

If you wish to access your personal information, please contact us in writing. We will not charge any fee for your access request although reserve the right to charge an administrative fee for providing a copy of your personal information. Please be aware that to protect your personal information in responding to your request, we may need to verify your identity before providing a response.

1.8 Policy Updates

BORELY complies with the data protection and privacy laws to which it is subject. You should be aware that privacy laws in various jurisdictions may change from time to time and accordingly, BORELY reserves the right to change this policy from time to time to maintain compliance with these changes.

1.9 Policy Updates

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information or a request from you to access or correct your personal information, you can contact us using the details set out below. Please include your name, email address and telephone number and clearly describe your complaint.

If you are not satisfied with the outcome of our response to your complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at enquiries@oaic.gov.au or on 1300 363 992. More information is available on the OAIC Website.

Contact

Borely Pty Ltd
177 Wellington Road, East Brisbane QLD 4169
T: +61 1300 391 434 (AUS)
E: info@borey.com