What is "Personal Information"?

Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable.

Types of personal information we collect

The kinds of personal information we may collect from you will depend on what type of interaction you have with us.  Personal information we may collect from you includes, among other things:

  1. identity particulars - such as your name, address, date of birth, occupation, telephone numbers and e-mail address;
  2. personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list;
  3. your bank, credit or debit account details when you make a purchase;
  4. your records of communication with us;
  5. if you visit our website, your website usage information such as your IP address. 

The purpose for collecting your personal information

We will generally only collect and use your personal information for the primary purposes of:

  1. our general business operations;
  2. effectively providing you with our goods and services;
  3. where applicable, assessing and processing an application for commercial credit, and for administrative purposes in relation to the ongoing management of your commercial credit arrangement;
  4. communicating with you;
  5. responding to your inquires or complaints;
  6. meeting our legal and regulatory obligations;
  7. direct marketing (such as providing you with information about our products and promotional notices and offers); and
  8. conducting business on our website and improving our websites.

When do we collect Personal Information?

  1. Your personal information is only collected by lawful and fair means and where practicable, only from you or from a person acting or authorised to act on your behalf.
  2. We may also collect your Personal Information, where you:
    1. apply for membership to our website
    2. use products or services
    3. contact us by telephone
    4. register for or attend seminars, presentations, meetings, webinars or our premises
    5. complete electronic, verbal or paper-based registrations, feedback, surveys, promotions, emails, instructions or enquiry forms
    6. subscribe to a publication, newsletter or mailing list
    7. apply for a job or volunteer your services
    8. provide information voluntarily.
  3. UBT may also collect Personal Information about you from a third party or from a publicly available source, but only if:
    1. you have consented to such collection or would reasonably expect us to collect information in this way (example: When personal information is updated with another party trading under the UBT brand, this may be updated in our databases as well).
    2. it was not reasonable or practical to collect this information directly from you (example: We may obtain reports from preferred suppliers about services provided to members for understanding use by members, negotiating better terms, auditing supplier reports and improving customer service).

Do we collect Personal Information via websites?

  1. UBT does not collect any Personal Information about visitors to websites except when they knowingly provide it or as otherwise described below.
  2. Click Stream Data – when you visit and browse a website, UBT’s website will collect Personal Information for statistical reporting and maintenance purposes via Google Analytics and Wistia (for video)
  3. Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as:
    1. the date, time and duration of a visit;
    2. whether the visitor has been to the site before;
    3. what site referred the visitor to the web page; and
    4. the number of users visiting the websites and the number of pages viewed
    5. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity browser type or website visiting patterns; if you access UBT’s website a cookie is downloaded onto your computer's hard drive when you first log onto the website and it is automatically deleted from your hard drive after a period of thirty days.
    6. Web beacons are images that originate from a third-party site to track visitor activities; UBT currently uses web beacons to track the visiting patterns of individuals accessing the website
    7. Login audit logs are used to record a user’s usage history and selections
    8. Our website Live Agent Web chat application provided by Salesforce collects data from users online so staff can identify who they are speaking with.

How do we use and disclose the Personal Information we collect about you?

  1. We may use your personal information for:
    1. the primary purposes for which it was collected, such as those described above;
    2. administering and responding to your enquiry or feedback about our products and/or services;
    3. conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity;
    4. promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing)
    5. improving the operation of our websites.
  2. We may disclose personal information we collect from you: 
    1. to our related companies, suppliers, consultants, contractors or agents for the primary proposes for which it was collected or for other purposes directly related to the purpose for which the personal information is collected. For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product; 
    2. for direct marketing but giving you the opportunity to opt out of such direct marketing; we will include our contact details in any direct marketing.
    3. to relevant Federal, State, Territory medical, health and safety authorities (as required);
    4. where the law requires or authorises us to do so; 
    5. to others that you have been informed of at the time any personal information is collected from you;
    6. with your consent (express or implied), to others
  3. UBT may also disclose your Personal Information to the website host in certain limited circumstances for example ensuring that if the website experiences a technical problem it is able to operate in an effective and secure manner
  4. We do not disclose your personal information for any secondary purposes unless your consent has been given or as required by law, and we will not sell or license any personal information that we collect from you.

How do we check the quality of Personal Information?

  1. UBT takes reasonable steps to ensure the personal information we collect is accurate, up to date and complete. We may do this by providing you access to edit some of your personal information, periodic update requests, when interacting with you and where practical electronic synchronisation of UBT databases.
  2. We provide you the right to access and correct Personal Information.

Cross border disclosure

UBT may disclose your Personal Information to organisations that are located in foreign countries solely for the purposes set out in this Privacy Policy provided that such disclosure is permitted under the Australian Privacy Principles. The Australian Privacy Principles permit disclosure to a person in a foreign country where UBT reasonably believes that the recipient of the information is subject to a law binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles. The foreign countries where information may be disclosed are likely to be New Zealand, USA, UK, Canada, Argentine and the Caribbean (which is where other UBT affiliated entities reside) and in countries where our contracted service providers operate or store information such as virtual or cloud-based operations which may include additional countries such as Hong Kong and the Philippines. If you leave our website by way of any hyperlink we advertise or display, we make no representation as to the privacy policy in place in any website visited by means of the hyperlink; you are required to make your own investigation and assessment as to the privacy policy of any website visited by this means. In particular if you visit a telecommunications site or the site of some preferred supplier mentioned on our website, please be aware that the sharing of your personal information on those sites is not within the control or oversight of this privacy policy.

Government identifiers

UBT may collect government related identifiers from you, which will be used or disclosed only where such use or disclosure is reasonably necessary to verify your identity for the purpose of an activity we are undertaking on your behalf such as provision of tax related services requested for a government agency.

Do we use your Personal Information for marketing?

  1. We may use your personal information for:
    1. promoting and marketing of our current and future products and services; 
    2. informing you of upcoming events and special promotions and offers; and 
    3. analysing our products and services so as to improve and develop new products and services.
  2. We may exchange your personal information between our related entities and so they can also assist in the marketing of our products and services to you. 
  3. We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you. 
  4. At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information. You will generally be given the opportunity to “opt out” from receiving marketing communications from us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request.

How do we keep your Personal Information safe?

  1. UBT takes reasonable steps to protect and keep your Personal Information from misuse, interference, loss, unauthorised access, modification or disclosure. The ways we do this include:
    1. using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information
    2. limiting physical access to our premises and files
    3. limiting electronic access to our networks, applications and files
    4. using security related hardware and software
    5. implementing personnel safe practice policies and training
    6. monitoring and reviewing our practices periodically
    7. using third parties who meet obligations under the Australian Privacy Principles.
  2. We periodically consider whether we need to retain your Personal Information in order to continue providing our goods and services to you, and may destroy or de-identify your Personal Information, except where we are required by law to retain it.

How can you see the Personal Information that we hold about you?

  1. You are entitled to access Personal Information that UBT holds about you.
  2. Access to your Personal Information is subject to UBT being satisfied you are the individual we hold Personal Information on or the person requesting is authorised to make a request on your behalf.
  3. If UBT delays or refuses your request to access some or all of your Personal Information it will provide you written notice of the reasons for the refusal, such as access would unreasonably impact upon the privacy of others or would not otherwise be permitted under the Australian Privacy Principles.
  4. A request for access can be done in any of the following ways:
    1. Telephone: +61 1300 01 01 02
    2. Email: admin.global@ubteam.com
    3. Post to: Level 6, 10 Herb Elliott Avenue, Sydney Olympic Park, NSW 2127 Australia

Dealing with unsolicited information

We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately. 

Anonymity when dealing with us

Only where it practicable to do so, we may allow you the option not to identify yourself when dealing with us. 

Collecting sensitive information

UBT does not collect sensitive information, unless it is specifically relevant and necessary for the purpose of our business activities and functions, and your consent is first obtained. All sensitive information that is collected is used in accordance with this Privacy Policy.

How can you correct your Personal Information?

  1. You can update your Personal Information at any time by contacting the relevant UBT department or you may edit your UBT account information and preferences on our website.
  2. Otherwise our Privacy Officer will correct your Personal Information. If we find that we have no further need for your Personal Information we will permanently de-identify it or remove it from our system and destroy all record of it. UBT welcomes any changes to your details so as to keep our records up to date.

What can you do if you have a question, problem or complaint about our use of your Personal Information?

  1. If you feel that your privacy has not been respected or that UBT has conducted itself inconsistently with this Privacy Policy or the Australian Privacy Principles in respect of your Personal Information please contact our Privacy Officer in any of the following ways:
    1. Telephone: +61 1300 01 01 02
    2. Email: admin.global@ubteam.com
    3. Post to: Level 6, 10 Herb Elliott Avenue, Sydney Olympic Park, NSW 2127 Australia, or
    4. Lodge a complaint per our Complaints Process below.

Privacy Complaints Process

  1. Privacy Policy
    This process is to be read in conjunction with the Universal Business Team Privacy Policy as above and words and phrases in this Process have the meanings attributed to them in the Privacy Policy.
  2. Purpose
    This policy sets out our approach to resolving complaints from individuals about the way we have dealt with their personal information and outlines what people can expect when they make a complaint.
  3. Management of Privacy Complaints
    Privacy complaints are managed by the Privacy Officer. The Privacy Officer will:
    1. receive and acknowledge the complaint
    2. seek further information from the complainant if necessary
    3. thoroughly investigate the complaint
    4. respond to the complainant with the outcome of the investigation
    5. provide feedback to the relevant internal stakeholders
  4. Privacy Complaint Process

    Complaint Receipt
    We ask that complaints be made in writing. The Privacy Officer may receive an oral complaint if he considers that making a written complaint would be impracticable or unreasonably onerous for the complainant. In written complaints, complainants should:
    1. include sufficient contact details to enable us to identify them
    2. clearly and succinctly state the nature of their complaints
    3. Include sufficient information for the Privacy Officer to understand the complaints
    4. provide details such as what happened, when they became aware of it, and who was involved
    5. state which Australian Privacy Principle they believe has been breached (if known)
    6. outline the impact the event has had on them
    7. include details of what they would like to see happen to resolve the complaints.

Complaints can be emailed to admin.global@ubteam.com or posted to Level 6, 10 Herb Elliott Avenue, Sydney Olympic Park, NSW 2127, Australia. If a complaint is received from someone other than the individual involved, we will only proceed if we have evidence that the person submitting the complaint has authority to do so.

Complaint Acknowledgement

The Privacy Officer will acknowledge the complaint within five working days of receiving it.

Complaint Investigation

The Privacy Officer will investigate the concerns raised by the complainant. This may involve obtaining further information from the complainant, speaking with the relevant staff members, reviewing relevant documents or client files, and obtaining technical or legal advice.

It is anticipated that in most cases, the duration of the investigation will not exceed 20 working days. If the investigation is likely to take longer than 20 days, the Privacy Officer will notify the complainant.

Complaint Outcome

The Privacy Officer will inform the complainant in writing as to the outcome of the investigation.

If the complainant remains dissatisfied with the response provided, they may wish to contact the Office of the Australian Information Commissioner (The Privacy Commissioner). For more details, see http://www.oaic.gov.au/

Internal Feedback

Where appropriate, the Privacy Officer will provide feedback, including recommendations of process improvements, to the relevant internal stakeholders to ensure continued compliance with the Australian Privacy Principles.


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