Privacy policy

Updated 4 December 2018

Sterning Group Pty Ltd ATF Sterning Group Trust ACN 166 867 849 (we, us, our) is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). We understand the importance of, and are committed to, protecting your personal information (that is, information or an opinion about you, whether true or not, which identifies you or from which your identity is reasonably identifiable). This Privacy Policy explains how we manage your personal information, including our obligations and your rights in respect of our dealings with your personal information.

Please take a moment to read our Privacy Policy as it describes what happens to your personal information that is collected via our website at sterning.com (the Website).

How we collect your personal information

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:

  • when you make an inquiry or order in relation to products or services through the Website;
  • in administering and performing any contracts with service providers;
  • when you contact us via telephone or facsimile;
  • from correspondence (whether in writing or electronically);
  • through any mobile applications provided by our organisation;
  • while conducting customer satisfaction and market research surveys;
  • when administering any of our services; and
  • as otherwise required to manage our business.

However, in certain cases we may collect personal information from publically available sources and third parties, such as suppliers, contractors, our clients and business partners.

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

Types of personal information we collect

The type of personal information that we may collect can include (but is not limited to), your name, email address, phone numbers and billing information.

Where you do not wish to provide us with your personal information, we may not be able to provide you with requested products or services.

Supplied Information

In addition to the personal information collected above, we also collect the information which you supply to us from time to time for processing through our services (Supplied Information). Supplied Information means the information (including personal information) contained in resumes and other materials submitted to us, including desired salary, visa status, notice period, upcoming holidays, other interviews, candidate description and such other information from time to time. We will not use or disclose the Supplied Information to any third party unless you have consented to that use or disclosure.

Our purposes for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances.

We collect, hold, use and disclose personal information to:

  • offer and provide you with our products and services;
  • manage and administer those products and services, including account keeping procedures;
  • communicate with you;
  • comply with our legal and regulatory obligations; and
  • otherwise to manage and improve our business.

We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure.

As at the date of this Privacy Policy, we are not likely to share your personal information with any third parties. If in future we do propose to disclose personal information, we may disclose personal information between our organisations or to third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

Protection of personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.

We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.

We further protect personal information by restricting access to personal information to only those who need access to the personal information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

Direct marketing

Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.

We will not disclose your personal information to third parties for marketing purposes without your consent.

You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting our Privacy Officer.

Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We may use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website. This information will help to better adapt the Website to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

Google Analytics

We may use the services and information available from Google Analytics to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website. This information will help to better adapt the Website to suit personal requirements. The services and information available from Google Analytics do not permit any reference to a specific individual nor will it be connected to personal information that we collect.

Accessing and correcting your personal information

You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information we hold about you.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

Overseas transfers of personal information

From time to time we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider. However, by providing us with your personal information, you consent to the storage of such information on overseas servers and acknowledge that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.

As at the date of this Privacy Policy, those facilities are located in the United States.

Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our Privacy Officer:

The Privacy Officer

PO Box 1693
Strawberry Hills NSW 2010
Australia

Phone: +61 435 386 453
Email: joseph.merz@sterning.com

We take all complaints seriously, and will respond to your complaint within a reasonable period. If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218
Sydney NSW 2001
Australia

Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

Changes

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you.