Privacy Policy

1. Policy Purpose

The purpose of this Privacy Policy is to outline how Transmax handles and protects personal information. In this context, "personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

2. Policy Scope

This policy applies to all internal and external stakeholders of Transmax.

3. Policy Statement

The proper management of personal information is important to Transmax Pty Ltd (“Transmax”, “we” or “us”). We comply with all relevant privacy laws where we operate, including the requirements applicable to us under the Privacy Act 1988 (Cth), as well as other applicable laws and codes.

3.1 Types of personal information we collect

The types of personal information that Transmax collects and holds depends on the nature of our engagement with you, and may include:

• identifying information, such as your name and date of birth;
• contact information, such as your postal address, email address and telephone number;
• recruitment information, such as your qualifications, work history, criminal history or right to work, if you apply for a job with us;
• social media handles and other social media profile information that you make available to us or to the public;
• details of any products or services that we provide to you;
• information about how you or your employer use the products and services we provide;
• details about who your work for if your employer is a customer of, or supplier to, Transmax;
• records of our communications with you, including any messages you send us; and
• device information, server log information, IP address, and location information.

Without this information, Transmax may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services), respond to queries or requests that you submit to us, or otherwise properly manage our relationship with you.

If you are a Transmax employee, we will also collect personal information that is necessary for us to manage your employment and meet our obligations in accordance with laws and agreed employment contracts.

In certain circumstances, Transmax may also collect sensitive information, such as health information. We will only collect sensitive information about you with your consent or if we are otherwise allowed or required by law to collect that information.

3.2 How we collect personal information

We may collect personal information about you in the following ways:

• when you order products or services from us;
• when you submit a query or request to us;
• when you visit our offices;
• when you respond to a survey that we run or fill in forms on one of our websites;
• by tracking your use of our websites and mobile applications;
• from public sources;
• from third parties who are entitled to disclose that information to us; and
• when you apply for a job with us.

Where we collect personal information from you, we will generally do so directly ourselves. However, in some cases we may collect personal information from a third party, such as through your representatives, your employer, contractors or suppliers who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services. We will take reasonable steps to notify you of any information we collect about you.

3.3 Purposes for which we use personal information

Depending on the context in which it is collected, we use personal information that we collect about you for the following purposes:

• to verify your identity when you are dealing with us;
• to enable us to provide our products and services;
• to answer your queries and requests;
• to carry out market analysis and research, including using contact information to carry out market research;
• to monitor use of our products and services;
• to assess, maintain, upgrade and improve our products and services;
• to customise our website according to user interests;
• to carry out education and training programs for our staff;
• to consider you for career opportunities with us and inviting you to participate in recruitment activities and events, if you apply for a role with us;
• to manage and resolve any legal or commercial complaints or issues and comply with our legal and regulatory obligations; and
• to carry out planning and forecasting activities and other internal business processes.

We may from time to time use your personal information in order to send you promotional emails or newsletters about new products, special offers or other information we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving these communications from us by contacting us at info@transmax.com.au or following the ‘unsubscribe’ link in the communication.

3.4 People to whom we disclose personal information

We may share personal information about you with:

• your representatives, advisors and others you have authorised to interact with us on your behalf (such as recruitment agencies);
• our staff who need the information to discharge their duties;
• related entities within our corporate group;
• our customers or suppliers, if you are a current or former employee of a customer or supplier;
• our business partners, agents and service providers;
• payment system operators and financial institutions;
• prospective purchasers of all or part of our business or shares in Transmax or a related entity;
• professional advisors who we engage to provide advice on our business; and
• government authorities who ask us to disclose that information, or to other people as required by law.

In some cases the people to whom we disclose your personal information may be located overseas and may be subject to different privacy regimes. The countries in which these people are likely to be located includes:

• the United States of America (USA).

We may also use and disclose your information for other purposes as authorised by you, or in accordance with your requests or instructions.

3.5 Quality of personal information

We take reasonable steps to ensure that all personal information that we hold is accurate, complete and up-to-date. This includes promptly updating personal information when we are advised that the information has changed, checking our contact lists for accuracy, and providing individuals with a simple means to update their personal information. You should contact Transmax if you believe the personal information Transmax holds about you is not accurate, complete or up-to-date (refer to the ‘How to raise a concern’ section below).

3.6 Security of personal information

We store personal information for as long as it is needed for the purpose for which it was collected or as required by law. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.

3.7 Access to, and correction of, your personal information

If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g. because you think it is incomplete or incorrect), please contact us. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.

3.7.1 When you use the Transmax website

When users visit the Transmax website (http://www.transmax.com.au), standard web logs record the visit, log certain information for statistical purposes used to assist in improving the usefulness of the site.

We may collect the following types of information:

• the type of browser you are using
• traffic patterns through the site such as:
  • date and time of your visit to the site
  • pages you accessed and documents downloaded
  • previous page you visited prior to accessing our site
  • internet address of the server accessing our site

We do not attempt to identify personal details unless required or permitted by law.

3.8 How to raise a concern

To raise a privacy-related issue with Transmax, or to discuss any issues about the Transmax Privacy Policy, please contact us. We will deal with your question within in a reasonable period and keep you up to date as things progress.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. You may also contact the Office of the Australian Information Commissioner (OAIC). Contact details can be found at the OAIC’s website: www.oaic.gov.au

Approved by Transmax Board July 2022