Privacy policy

1. Introduction
This Privacy Policy covers and applies to all entities within the Pacific National Group (Pacific National). Pacific National is committed to protecting your privacy by complying with the Australian Privacy Principles (APPs), as set out in the Privacy Act 1988 (Cth) (Privacy Act). The APPs are intended to protect your privacy in respect of any personal information or sensitive information that you may provide to us.
This Privacy Policy sets out Pacific National’s policies on the management of personal information and sensitive information. Employees and individuals dealing with Pacific National have the right to know what sort of personal information the Company holds, for what purposes, and how it is collected, held, used and disclosed. You may contact us at the details (below) to request access to your own information and correction of that information if it is necessary and we hold that information.

2. Policy

2.1 What is personal information?
Personal information is information that identifies you as an individual or from which your identity can be reasonably ascertained.
Generally, the types of personal information Pacific National collects include your name, contact details, identification information, organisation, title, information in forms you submit, payment details and enquiry/complaint details. Pacific National may collect other types of personal information depending on the type of dealings you have with Pacific National. For example, Pacific National may collect and hold personal information or sensitive information related to:
• the provision of goods or services;
• making or receiving payments;
• evaluating, responding or investigating job applications submitted to Pacific National;
• verifying your email or IP address;
• fulfilling Pacific National’s contractual rights or obligations;
• evaluating, responding or investigating correspondence sent to Pacific National;
• Pacific National’s responding, auditing, reporting, evaluating and investigating needs or obligations;
• the review of goods and services Pacific National provides or uses;
• the management of the safety of Pacific National’s goods, services, premises and workers;
• managing Pacific National’s customers, suppliers and general relationships with person’s outside of Pacific National;
• providing information about Pacific National’s goods, services and related events (if you opt-into the receipt of such information); and
any purpose that was identified to you at the time of the collection of the personal information or sensitive information. Unsolicited information
If Pacific National receives personal information or sensitive information about you that we did not ask for either directly from you, from someone else on your behalf, or through someone on our behalf, and we determine that we could have collected this information from you had we asked for it, Pacific National will take reasonable steps to notify you, as soon as practicable, that we have collected your personal information. If Pacific National could not have collected this personal information from you (or if you do not agree to us collecting information in this way), we will lawfully de-identify or destroy that personal information. Any unsolicited information provided by you, someone on your behalf or someone on our behalf, will be used for the purposes for which it was provided.

2.2 How is information collected?
Pacific National only collects personal information necessary for business purposes or to communicate with you. Personal information may be collected verbally, in writing, by telephone, by email and through Pacific National’s website, including by monitoring and recording these communications and interactions. For purposes including management, security, dispute resolution and training Pacific National may operate video and audio surveillance devices in Pacific National’s premises.
Pacific National endeavours to collect personal information directly from the individual except where it is not reasonably practical to do so. In some cases, Pacific National collects personal information from third parties, including public sources, other Pacific National companies, contractors, information service providers and the parties described in section 2.5 below.
Where you provide us with personal information about someone else, you must have their consent to provide their personal information to us based on this Privacy Policy.
In general, you can visit Pacific National’s website without revealing any personal information about yourself. The server address, domain name, date and time of your visit and the pages visited may be recorded.

2.3 How is information used?
Pacific National understands how important it is to keep your personal information private, so we will only use and disclose personal information that we hold about you when:
• you agree to the disclosure; or
• we use it for the purposes we collected it; or
• use or disclosure is required or authorised by law.
The purposes for which we may use and disclose personal information include the following:
• to provide, administer and improve our products and services;
• verify your details;
• to maintain and update our records;
• to manage our relationship with you;
• to protect our lawful interests;
• in connection with suspected fraud, misconduct and unlawful activity under specific Australian legislation (including the Crimes Act 1914 (Cth), Customs Act 1901 (Cth) and the Rail Safety National Law);
• in connection with acquisitions or potential acquisitions of Pacific National’s business;
• if you apply for a job with Pacific National, to assess your application, and consider you for and contact you, about other potential suitable roles;
• if you are employed by Pacific National, for purposes relating to managing your employment or engagement with Pacific National including engagement, training, disciplining, payroll, superannuation, health and safety, administration, insurance (including WorkCover) and staff management;
• in the event that you send an email message to Pacific National, to respond to your email; and
• to gather demographic information about Pacific National’s website visitor trends and to improve our website.

2.4 How do we protect personal information?
Pacific National is committed to safeguarding personal information that you provide. All personal information collected by Pacific National is held securely, whether on Pacific National’s physical files, in Pacific National’s systems or in a database (which may be hosted by Pacific National or a third party on Pacific National’s behalf). This information is only made available to Pacific National employees on a ‘need to know’ basis and for the purposes outlined above or to other people as outlined in this Policy who have agreed to treat that information confidentially. A range of measures are undertaken to protect the security of data supplied from misuse, unauthorised access, modification or disclosure. Internally, strict controls and procedures are in place to ensure that the privacy and security of personal information provided to Pacific National is protected.
Pacific National will use all reasonable endeavours to keep your personal information in a secure environment, however this security cannot be guaranteed due to the nature of the Internet. These measures are designed to assist in your personal information not being accessed by unauthorised personnel, lost or misused. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us (see below).
You must not provide to Pacific National any personal information or sensitive information about another individual if you have not obtained either that individual’s, their legal guardian’s or their legal representative’s express consent to do so.

2.5 Sharing information with other organisations
To the extent permitted by law, Pacific National may disclose personal information about you to:
• related companies;
• your authorised representatives;
• third parties who provide services to Pacific National from time to time;
• the Australian Securities and Investments Commission and other government regulators and agencies, as part of our statutory obligations;
• authorities if there is a suspicion of unlawful activity;
• third parties where you have provided consent of such disclosure; or
• as otherwise permitted by law.
Pacific National may disclose your personal information in all countries where the Pacific National’s IT service providers host their servers and as part of Pacific National’s ordinary business practices relating to the storage of data and where permitted by law.

2.6 Is the information we hold accurate?
All reasonable steps are taken by Pacific National to ensure that your personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable timeframe.

2.7 How can you access and correct personal information?
You have rights to access, update and correct your personal information held by Pacific National. We will take reasonable steps to ensure that personal information is up to date, accurate and complete.
When you contact us and request access to your personal information, we will need to verify your identity first and may ask you further questions so that we can respond to your request as quickly as possible.
If you wish to access, update or correct your personal information held by us, please contact our Privacy Officer, whose details appear below.
Depending on the nature of the request, Pacific National may need to charge you for providing access to the information. These charges will be reasonable, and we will let you know if a charge will apply before proceeding with the request.

2.8 What are ‘cookies’ and how are they used?
Some of Pacific National’s web pages use ‘cookies’. A cookie is a small file that is transferred to your computer’s hard drive when you visit a website for record keeping purposes. Cookies are used to track usage patterns on Pacific National’s website to help us understand how our website is being used and to improve its functionality. We may provide the information we gather from cookies to third parties for these purposes and for other purposes connected with our website.
The website will not store personal information such as email addresses or other details in a cookie. 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 do not have to accept cookies and you can set your browser to notify you when you receive a cookie. This will give you the opportunity to decide whether or not to accept the cookies. Please note if you choose to disable cookies, you may not be able to access certain features of the website.
The information that will be collected when you visit a Pacific National website includes:
• the type of browser used;
• the address of your server;
• the type of operating system used;
• your IP address;
• when you used the website and how; and
• the websites your previously visited.

3. Complaint handling process
If you believe:
• someone has gained access to your personal information by mistake;
• Pacific National has breached its privacy obligations or privacy rights in any way; or
• you would like to discuss any issues about this Policy,
please contact our Privacy Officer, whose details appear below.
The Privacy Officer
Pacific National
Level 16, 15 Blue Street
North Sydney NSW 2060
Attention: The Company Secretary
Pacific National takes complaints seriously and will investigate all complaints and will respond in writing within a reasonable time.

4. Effect of Policy
This Privacy Policy relates to Pacific National’s current privacy standard. This Policy may be reviewed and revised from time to time to take account of new laws and changes to Pacific National’s operations and practices. Pacific National reserves the right to modify or amend this Policy at any time. We will notify you of changes by publishing the latest policy from time to time at www.pacificnational.com.au/provacy-policy.
You should note that our website may contain links or references to other websites to which this Policy may not apply. You should review the privacy policy of each of those websites and assess whether those policies are acceptable to you before using those websites.

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