Privacy Policy
1. INTRODUCTION
Commodore Australia Pty Ltd (ACN 137 100 077) (“Commodore Australia“) manages personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act“) and the Australian Privacy Principles as set out in Schedule 1 of the Privacy Act (“APP“).
This Privacy Policy (“Policy“) relates to any personal information that Commodore Australia collects, holds, discloses and/or uses via www.commodoreaustralia.com.au and any related Commodore Australia terms of trade, website, social media page, internal website or intranet (“Websites”) or applications (“Applications“) or any other manner.
In this Policy, “we”, “us”, “our” and Commodore Australia means Commodore Australia Pty Ltd (ACN 137 100 077).
This Policy is effective from 24 January 2025.
Changes to this Privacy Policy
Commodore Australia reserves the right to update or change this Policy at any time and you should check this Policy periodically. Your continued use of our services (including but not limited to our Website) after we post any modifications to this Policy on the Website will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Policy.
Personal Information
Throughout this Policy we refer to “Personal Information” which is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
Sensitive Information
“Sensitive Information” is a subset of Personal Information and includes information or an opinion about a person’s racial or ethnic 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 or biometric information.
2. WHAT KINDS OF PERSONAL INFORMATION IS COLLECTED AND HELD?
Commodore Australia collects and hold information about Commodore Australia’s employees, contractors who provide us with a service, customers, Website users, suppliers, job applicants and other people who may come into contact with us or one of our businesses from time to time.
Personal Information
Examples of Personal Information that may be collected and held by Commodore Australia includes but is not limited to:
- Your first and last name
- Date of birth
- Gender
- Company name and details
- Delivery Address
- Contact phone number
- Mobile phone number
- Email address
- Employment information
- Individual preferences
- Marketing information
- Financial information including credit card and payment details
- Transaction history
Commodore Australia may also combine your Personal Information with other information to provide and improve our products, services, content, and advertising. You are not required to provide the Personal Information that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.
Commodore Australia collects only Personal Information that is reasonably necessary for, or directly related to, its functions or activities. The nature and extent of Personal Information Commodore Australia collects and holds will vary depending on a person’s particular relationship and interaction with Commodore Australia.
Sensitive Information
Commodore Australia will not collect Sensitive Information unless the person to whom it relates consents to the collection of that information, and the information is reasonably necessary for one or more of Commodore Australia’ functions or activities, except where the collection is required or authorised by law, is necessary to prevent or lessen a serious and imminent threat to the person’s (or another person’s) life or health, or is necessary in relation to legal proceedings (current, anticipated or potential), or another permitted exception in the Privacy Act applies.
3. HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?
Directly
- Directly from customers when you provide Personal Information. For example, when purchasing or hiring goods, products and equipment from Commodore Australia and signing terms of trade.
- When you interact and/or browse the Website or any Application associated with it generally or for a specific purpose including making enquiries or corresponding with us.
- When representatives of Commodore Australia such as employees undertake certain business functions for Commodore Australia for example to attend upon customers, in the provision of Commodore Australia’s services.
Indirectly
Third party providers
Data is collected, processed and stored using third-party analytics software, that is to the best of our knowledge secure and confidential. Analytical data is used to gain an understanding of user behaviour, perform system critical operations, and in extraordinary circumstances, for legal reasons. Anonymous user data is shared between third party services in order to gain insight as to aggregate user behaviour.
Analytic data insights are also used to target users through remarketing, demographics, interests and website behaviour. Third party vendors, including but not limited to Google and Facebook may show our ads on sites across the internet. We and third-party vendors, including but not limited to Google, make use of third-party cookies together in order to inform, optimise and serve ads based on past visits to a website. We make use of demographic data (such as age, gender and interests) obtained through third-party tools in order to, but not limited to: influence marketing spend and communicate internally and externally the aggregate behaviour.
Public sources
When you use some Commodore Australia services, or Applications or post on a social networking service such as Instagram or Facebook, the personal information and content you share is visible to other users and can be read, collected, or used by them and Commodore Australia. For example, if your name or email address is contained in a public post, or set out in a review of our products and services in relation to Commodore Australia, that information is then public and can be collected by Commodore Australia.
Combining/linking Personal Information
Other than as referred to elsewhere in this Policy, we will not facilitate the merging of personally identifiable information with non-personally identifiable information without prior user consent to that merger to optimise our Website and Website marketing. For example, we may collate Personal Information data and aggregate data for the purpose of comparing marketing costs with revenue on a transactional basis.
Passive collection of information – Direct Marketing and Behavioural Advertising
As you navigate through our Website and access our Applications, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, and clickstream data).
For example, we may collect information about matters including but not limited to the date, time and duration of visits and which pages of a Website or Application are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website or Application is accessed via links in an email or another electronic message we have sent or where we are able to uniquely identify the device or user accessing a Website or Application, such as when you are logged into an account.
Where we use Personal Information for promotional or direct marketing purposes, a person may at any time request Commodore Australia to not use their Personal Information for sending direct marketing material to that person including if you wish to opt-out of the use of certain hashed portions of your Personal Information. Such a request can be made by contacting Commodore Australia either in writing, by email or by telephone at the contact details below. There is no fee for making such a request.
Direct marketing can include for example: Displaying an advertisement on a social media site that an individual is logged into, using Personal Information, including data collected by cookies relating to websites the individual has viewed.
Cookies & Web Beacons
We use cookies on our Website. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, once you choose to furnish the Website with personally identifiable information, this information may be linked to the data stored in the cookie. You can manage your cookie preferences in your browser settings, but please note that disabling cookies may affect the functionality of the Website.
We may use web beacons on the Websites from time to time. Web beacons or clear .gifs are small pieces of code placed on a web page to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
How Commodore Australia hold information
Data is collected, processed and stored using third-party customer relationship management software together with financial software that is to the best of our knowledge secure and confidential. We hold Personal Information electronically and in hard copy form, both at our own premises and with the assistance of these service providers.
Commodore Australia retains the information you provide to us including your contact and the last four digits of your credit card details to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. This information is held on secure servers in controlled facilities.
Security
We have systems in place to ensure that information is accessible by our staff on a need-to- know basis.
We act to safeguard the security and privacy of your information, whether you interact with us personally, by telephone, mail, over the internet or other electronic medium. We strive to take reasonable steps to protect the information we hold from misuse, interference, loss and unauthorised access modification or disclosure, however we cannot guarantee its absolute security. We store information both in hard copy paper form and in soft copy electronic form. Where the information is of a sensitive nature, we will take particular steps to secure the information.
In certain circumstances we use third party storage providers such as cloud storage and back- ups to hold information that is stored in soft copy electronic form. If you are accessing the Website from outside Australia, please be aware that your information may be transferred to, stored, and processed in Australia, where our servers and central databases are located. By using the Website, you consent to the transfer of your information to our facilities and those third parties with whom we share it, as described in this Privacy Policy.
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. However most Personal Information is stored in client files which will be kept for a minimum of seven years.
4. THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
Commodore Australia collects Personal Information in various ways in the course of conducting our business, to provide and improve our products, services, content, and advertising including for the purposes of:
- Contacting customers
- Providing goods and services to customers
- Undertaking credit assessments (including but limited to doing so through any credit insurers)
- Providing newsletters and discounts to customers via e-mail
- Responding to customer queries in relation to our products and services
- Interaction with customers who utilise our Website
- To better understand your needs, enabling us to improve our products and services
- To make improvements to the Website to enhance the user experience
- Promotional and marketing activities
- Monitor the effectiveness of our advertising
- To customise our Websites according to your interests
- Direct Marketing and Behavioural Advertising
5. HOW CAN YOU CONTROL YOUR PERSONAL INFORMATION?
Accessibility
A person may request to access Personal Information about them held by Commodore Australia. Such a request must be made in writing via our contact details below.
Commodore Australia will take reasonable steps to ensure the accuracy and completeness of the Personal Information we hold. However, if a person believes that any Personal Information that we hold about them is inaccurate or out of date, then they should contact Commodore Australia in writing via our contact details below.
Commodore Australia will grant a person access and/or make any corrections to their Personal Information that may be necessary from time to time as soon as possible, subject to the circumstances of the request.
Verification of identity is required with a request to access (or update) Personal Information so that we can ensure your Personal Information is disclosed only to you.
Complaints
An individual can contact Commodore Australia in relation to lodging a complaint about a breach of the APP or a binding registered APP code, via our contact details below.
Commodore Australia will make an assessment of the complaint and will respond to you within a reasonable timeframe. Any further action following this initial response will vary depending on the nature of the complaint. If necessary, the complaint may be taken to the Office of the Australian Information Commissioner or to another review body if an external review is required.
Opt outs
There may be options for you to use online services or browser settings to manage behavioural based digital advertising that allow you to opt-out or install blocking programs for example through Google.
You may also opt out of our direct marketing emails by clicking on the “unsubscribe” link contained in any such emails or by writing to Commodore Australia at sales@commodoreaustralia.com.au. Please note that even if you opt out of marketing emails, we may still send you non-promotional communications related to your account or orders.
Freedom of Information Act 1982 (Cth)
An individual also has the right under the Freedom of Information Act 1982 (Cth) to request access to documents that we hold and ask for information that we hold about that person to be changed or annotated if it is incomplete, incorrect, out-of-date or misleading.
6. DISCLOSURE OF PERSONAL INFORMATION
Where we receive your Personal Information and we did not solicit the information we will do our best to notify you of our receipt of your Personal Information within a reasonable time. If we determine that we could not have received the information under the APP we will use our best endeavours to destroy the information. We may use or disclose the information to make such a determination.
We may disclose your Personal Information to third-party installers, contractors, and service providers engaged by us to deliver, install, or support the products and services you have requested.
These third parties will only use your Personal Information for the purposes of providing the services requested, unless you have separately consented to receiving additional communications from them.
These third parties may contact you directly for the purpose of arranging, scheduling, and completing installation or related services.
Where permitted by law, these installers or contractors may also use your contact details to inform you about other products or services that may be relevant to you. You may opt out of receiving such communications at any time by notifying us or the relevant installer directly.
We may disclose your Personal Information to our related companies, service providers (including but not limited to service providers that assist us with operating our website, processing payments, delivering products and shipping) and specialist advisers who have been contracted with administrative or other services, insurers, credit providers, our professional advisors including lawyers, or a person authorised by you to access the information. We may also disclose Personal Information to others if required to do so by law. We do not guarantee website links or policies of authorised third parties. We or third parties may disclose your personal information to overseas recipients (including India and the United States), most likely in circumstances where personal information is disclosed, to an entity which is an overseas recipient, by virtue of the personal information being stored on a third party’s cloud based service.
If Commodore Australia is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction.
We do not sell, publish or give away your information to any other party where the information could be linked to you.
Commodore Australia does not disclose personal health information to any other person, including next of kin, unless the individual about whom the information relates has given express consent, or the disclosure is required or authorised by or under Australian law, or would otherwise be consistent with the APPs.
7. COMMODORE AUSTRALIA CONTACT DETAILS
Email: sales@commodoreaustralia.com.au
Postal Address: 20 Callister Street, Shepparton VIC 3630
Phone: 1300 669 256