1. Introduction

Torres Pilots Pty Ltd (ABN 053 843 646) (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information.  This document is our privacy policy and it tells you how we collect and manage your personal information. We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.

2. What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act.  In general terms, it is any information that can be used to personally identify you.  This may include your name, address, telephone number, email address and profession or occupation.  If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

3. What personal information do we collect and hold?

We may collect the following types of personal information about you:

  • your name and contact details (such as address, email address, telephone and facsimile numbers);
  • if you are one of our pilots (whether employee or contractor), your job title and other information (including banking information and health information) relating to your employment or engagement with us;
  • if you are one of our customers or a shipping agent, details of the services that you have acquired from us or which you have enquired about, the fees payable for those services, together with any additional information necessary to deliver those services and to respond to your enquiries (such as credit card information and other payment related information); and
  • any additional information relating to you that you provide to us directly (for example, through our website).

We may also collect some information that is not personal information because it does not identify you or anyone else.  For example, we may collect information about vessels for which we provide services without associating the information with any individual.

4. How do we collect your personal information?

Except as stated below, we collect your personal information directly from you unless it is unreasonable or impracticable to do so.  When collecting personal information from you, we may collect in ways including:

  • if you are an employee or contractor, or an applicant, when you submit your application to us, or through your employment relationship with us;
  • during conversations between you and our representatives; or
  • when you submit orders to us.

We may also collect personal information indirectly, including:

  • contact details and emails from publicly accessible website, for the purposes of obtaining or confirming your contact details;
  • from third party companies such as shipping agents; and
  • from law enforcement agencies and other government entities.

5. What happens if we can’t collect your personal information?

It is generally not possible to request services from us in an anonymous or pseudonymous manner.  If you do not provide us with the personal information described above, some or all of the following may happen:

  • we will not be able to provide our services to you; or
  • we will not be able to provide you with information about the services that you want.

6. For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service.  We collect, hold, use and disclose your personal information for the following purposes:

  • to provide our services to you and to answer enquiries and provide information or advice about our services;
    • if you are an employee or contractor of us, to manage and maintain our relationship with you, or if you are a job applicant, to manage the job application process;
  • for the administrative, marketing (including direct marketing), planning and quality control purposes;
  • to provide relevant updated personal information (for example mobile phone number) to our contractors and shipping agents;
  • to update our records and keep your contact details up to date;
  • to process and respond to any complaint made by you; and
  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.

Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

7. Our website

Our privacy policy also applies information collected by our website at http://www.torrespilots.com.au/

Cookies and website logs

When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer.  This enables us to recognise your computer each time you visit our website without bothering you with a request to register.  It also enables us to keep track of products and services you view so that, if you consent, we can send you news about those services.  We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate.  We use this to research our users’ habits so that we can improve our website and online services.  Our cookies do not collect personal information.  If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.  However, this may affect certain operations of the website. We or our hosting service provider may log IP addresses (that is, the electronic addresses of computers connected to the internet) date and time of your visit to the site, pages you accessed, type of browser you are using and referring site to analyse trends, administer the website, track users movements, and gather broad demographic information.

Security

As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online.  We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links

Our website may contain links to other websites operated by third parties.  We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.  Third party websites are responsible for informing you about their own privacy practices.

8. Who do we disclose your information to?

We may disclose your personal information to:

  • our pilots and employees for the purposes of providing services to you;
  • our employees, related bodies corporate, suppliers, contractors or service providers for the purposes of operation our business including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
  • external payroll provider for the purposes of providing payroll services to us;
  • suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
  • any organisation for any authorised purpose with your express consent.

9. Direct marketing materials

We may send you direct marketing communications and information about our services that we consider may be of interest to you.  These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).  If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.  In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list. We may use external mail house and email service providers to assist us in sending direct marketing communications, but we do not provide your personal information to other organisations for the purposes of direct marketing.

10. Security and data quality

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form.  Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later).

11. How can you access and correct your personal information?

You can request access to any personal information we hold about you at any time by contacting us (see the details below).  Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you).  We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you.  We will not charge for simply making the request and will not charge for making any corrections to your personal information. As part of this request, we may need it verify your identity. There may be instances where we cannot grant you access to the personal information we hold.  For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality.  If that happens, we will give you written reasons for any refusal. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you can request us to amend it.  We will consider if the information requires amendment.  If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

12. What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.  We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Act, if applicable). After we have completed our enquiries, we will contact you within a reasonable time (such as 30 days), usually in writing, to advise the outcome and invite a response to our conclusions about the complaint.  If we receive a response from you, we will assess it and advise if we have changed our view. You can also submit a complaint to the Office of Australian Information Commissioner.

13. Contacting us

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact our Privacy Officer using the details set out below.  We will treat your requests or complaints confidentially.  Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.  We will aim to ensure that your complaint is resolved in timely and appropriate manner. Please contact our Privacy Officer at: Torres Pilots PO Box 674, Bulimba Q 4171 operations@torrespilots.com.au +61 7 3217 9544 (24 hours)

14. Changes to our privacy policy

We may change this privacy policy from time to time.  Any updated versions of this privacy policy will be posted on our website and will be effective from the date of posting.  Although we intend to observe this policy at all times, it is not legally binding on us in any way.  From time to time we may regard it as necessary or desirable to act outside the policy.  If we do so, we will still comply with any statutory right that you may have under the Act or other applicable legislation. This privacy policy was last updated in July 2014.