1. KENT RELOCATION GROUP – PRIVACY POLICY
Kent Relocation Group (referred to as we, us or our in this Privacy Policy) refers to Kent Relocation Group Pty Ltd., as trustee for The Dace Trust ABN 54 712 591 719, and its trading brands, such as Kent Storage, Kent Relocation Services, Kent Removals and Storage and Kent Business Relocation.
We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our removal, transit, and storage services or arranging for third party providers to provide these services to you including acting on your behalf as an agent (for which we may charge a fee), and ancillary services to those services, including the provision of insurance, and real estate services (Services), our website or when otherwise interacting with you.
2. The information we collect
Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
Sensitive Information means information relating to your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, genetic information or biometric information/templates. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as permitted by law or authorised by you.
The types of personal information and sensitive information we may collect about you include, but is not limited to:
- Basic Identity Data including first name, last name, email address, phone number; but not including Sensitive Information.
- Comprehensive Identity Data including gender, date of birth, pronouns, middle name, age, occupation, and your employer; but not including Sensitive Information.
- Contact Data including billing address, pick-up address, delivery address, email address and telephone numbers.
- Financial Data including bank account and payment card details.
- Interaction Data which refers to information that is generated through your engagement with our website and/or services and which includes Technical and Usage Data, Transaction Data, Marketing and Communications Data and details about quotation requests, service enquiries and other service specific information generated through your interaction with our website and/or services.
- Transaction Data including details about payments to you from us and other details of products and services you have purchased from us.
- Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
- Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
- Profile Data which refers to information that can be used to identify an individual user of our services and which includes Basic Identity Data, Contact Data, Financial Data and Professional Data.
- Visa information which we require to arrange and deliver the Services.
3. How we collect personal information
We collect personal information in a variety of ways, including:
- From you: We collect personal information which you provide to us, including when you interact with us on our website, in emails, or over the telephone.
- From third parties: In certain circumstances where it is unreasonable or impracticable to collect personal information from you, we collect personal information from third parties, such as from your employer where they refer you to us for Services, from a government entity with relation to customs and quarantine compliance, from a third party where we are subcontracted to provide Services to you, and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
- From publicly available sources: We may be required by law to collect personal data from publicly available resources such as the Australian Securities and Investment Commission (ASIC).
4. Why we collect, hold, use and disclose personal information
We have set out below, in a table format, a description of some of the main purposes for which we plan to collect, hold, use and disclose your personal information.
| Purpose of use / disclosure | Type of Personal Information |
|---|---|
| To provide you with a quote for our Services, or to contact and communicate with you about any enquiries you make with us via our website. |
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| To provide our Services to you, including to arrange for the Services to be performed by our contractors/ subcontractors or third-party providers whom we have been authorised by you to engage with on your behalf in Australia and internationally. |
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| To contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us. |
|
| For internal record keeping, administrative, invoicing and billing purposes. |
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| For analytics, market research and business development, including to operate and improve our Services. |
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| With your consent, to run promotions, competitions and/or offer additional benefits to you, including to send you promotional information about our events and experiences and information that we consider may be of interest to you. |
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| If you have applied for employment with us; to consider your employment application. |
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| To comply with our legal obligations or if otherwise required or authorised by law. |
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Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:
|
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5. Our disclosures of personal information to third parties
We may disclose personal information to:
- our employees, and/or related entities;
- agents, contractors, subcontractors, shipping agents, and other service providers (including third party providers of the Services), whether current or prospective, so that we can provide the Services to you or arrange for the Services to be provided to you, including on your behalf as your agent;
- utility service providers who can assist in the disconnection and/or connection of services at your new or previous residence;
- any entity for which we act as an ‘authorised representative’ or similar arrangement under that entity’s financial service licence and to relevant insurers, in connection with any insurance products that are sold to you;
- international government agencies, such as customs officers, where the Services we are performing require the goods to cross borders;
- IT service providers, data storage, web-hosting and server providers;
- marketing or advertising providers, but only with your consent;
- with your consent, to professional advisors, bankers, auditors, our insurers and insurance brokers;
- with your consent, to anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time);
- any other third parties permitted by law, including contractors who can assist us improve the Services; and
- any other third parties as required by law, such as where we receive a subpoena.
Google Analytics: We may have enabled Google Analytics Advertising Features including [Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc.]. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. By using any of our online platforms (including our website), you consent to us disclosing your personal information to third party advertising and analytics service providers, including Google Analytics.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
6. Overseas disclosure
While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia. Overseas disclosure is required in connection with a request by you to perform Services requiring your goods to be delivered, or your relocation, outside of Australia. We have and are able to perform those services to most countries around the world (either by us directly or through third party providers), including but not limited to United States, United Kingdom, members of the European Union, China, Japan, New Zealand, Singapore and Canada.
We will only disclose your personal information overseas in accordance with the Australian Privacy Principles. If, to provide you with the Services, we are required to disclose your personal information to an overseas recipient who is not subject to laws that are substantially similar to the Australian Privacy Principles, we will notify you of this and will only disclose your personal information to the overseas recipient with your consent.
7. General Data Protection Regulation
We welcome the General Data Protection Regulation (GDPR) as an important step forward in encouraging high standards of personal data security. Australian businesses of any size may need to comply if they have an establishment in the European Union (EU), if they offer goods and services in the EU (irrespective of whether a payment is required), or if they monitor the behaviour of individuals in the EU (where that behaviour takes place in the EU).
Under the GDPR and the Data Protection Act 2018 (UK), we may have some additional obligations with respect to the processing of “personal data” collected from residents of the EU and/or United Kingdom (UK). The meaning of personal data is similar to Personal Information—however, it is broader as it includes any information relating to an identified or identifiable natural personal.
Where required, we will take appropriate steps to ensure that the personal data of EU and/or UK residents is:
(a) processed lawfully, fairly and in a transparent manner;
(b) collected for legitimate purposes;
(c) accurate and up to date;
(d) kept for no longer than is necessary for the purposes for which it was collected; and
(e) secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.
We will comply with all obligations imposed on data importers under the GDPR and the Data Protection Act 2018 (UK) with respect to the personal data of EU and UK residents, including the Standard Contractual Clauses, to the extent that they may apply to us and our relationships with third parties.
EU and UK residents have the right to access personal data we hold about them and to request that personal data be corrected, updated, deleted or transferred to another organisation. EU and UK residents are also able to request that the processing of their personal data be restricted or objected to their personal data being processed. To make any of these requests, please contact our Privacy Officer.
8. Employment and recruitment
If you send us an application to be considered for an advertised position (or unsolicited), this information may be used to assess your application or suitability for employment with us. This information may be disclosed to our related bodies corporate and service providers for purposes such as aptitude and psychological testing or other human resources management activities.
As part of the application process, you may be asked for your consent to the use and disclosure of certain personal information about pre-employment testing. We may also ask you to consent to the disclosure of your personal information to those people who you nominated to provide references. A refusal to provide any of this information, or to consent to its proposed disclosure, may affect the success of the application.
This Privacy Policy does not apply to our handling of information about our employees. Our handling of employee records is exempt from the APPs under the Privacy Act if the act or practice is directly related to:
- either a current or former employment relationship between us and the individual; and
- an employee record held by us relating to the individual
For information about our practices relating to employee records, please contact us at the contact details listed in section 10 below.
9. Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide a quotation to you, or deliver our Services to you.
Information from third parties: We will only receive personal information about you from a third party if you have consented to us receiving the information or it is unreasonable or impracticable to collect the personal information from you directly. We will protect the personal information in accordance with this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us. However, if you chose not to identify yourself, it may affect our ability to provide a quotation to you, or deliver our Services to you.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access to your personal information: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction to your personal information: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint.
Attention: Joe Lopino
Email: [email protected]
If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner. The OAIC can be contacted at:
Website: www.oaic.gov.au
Post: GPO Box 5218, Sydney NSW 2001
Email: [email protected]
10. Storage and security
Our commitment to securing the personal information that we collect from you is demonstrated through our attainment of ISO27001 certification which recognises that we apply an internationally recognised best practice framework in our approach to information security. To prevent unauthorised access or disclosure of your personal information, our information security framework has in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We will take reasonable steps to destroy or permanently de-identify your personal information when it is no longer required. However, we reserve the right to retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, or for the prevention of fraud and to resolve disputes.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
11. Cookies
We may use cookies on our website from time to time. 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, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
12. Notifiable Data Breaches
A notifiable data breach scheme is currently in place in Australia. We are committed to adhering to this scheme as an important step in preventing and managing serious privacy breaches.
A “data breach” means unauthorised access to, or disclosure, alteration, loss, or destruction of, Personal Information—or, an action that prevents us from accessing Personal Information on either a temporary or permanent basis. An “eligible data breach”, in accordance with the Privacy Act 1988 (Cth), occurs when there is a data breach that is likely to result in serious harm to any of the individuals to whom the information relates and we are unable to prevent the likely risk of serious harm with remedial action.
We, including all our people, take breaches of privacy very seriously. If we suspect a privacy breach has occurred, our priority is to contain and assess the suspected breach. In doing so, we will:
(a) take any necessary immediate action to contain the breach and reduce the risk of harm;
(b) determine the cause and extent of the breach;
(c) consider the types of information involved, including whether the personal information is sensitive in nature;
(d) analyse the nature of the harm that may be caused to affected individuals;
(e) consider the person or body that has obtained or may obtain personal information as a result of the breach (if known); and
(f) determine whether the Personal Information is protected by a security measure.
If we believe an eligible data breach has occurred we will, as soon as practicable, notify the Commissioner and all affected individuals or, if it is not possible to notify affected individuals, provide public notice of the breach (in a manner that protects the identity of affected individuals).
13. Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy, unless otherwise stated.
14. Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our Privacy Officer at:
Kent Relocation Group Pty Ltd as Trustee for The Dace Trust (ABN 54 712 591 719)
Email: [email protected]
Last update: 30 July 2024
