Australian Privacy Act
LAST UPDATED: 14 July 2022
Converlens is an Australian-based business and our policies and practices are guided by applicable Australian law, in particular the Australian Privacy Act 1988 (Cth).
13 Australian Privacy Principles (APPs)
The Privacy Act includes 13 Australian Privacy Principles (APPs) which govern the standards, rights and obligations around:
the collection, use and disclosure of personal information;
an organisation or agency’s governance and accountability;
integrity and correction of personal information; and
the rights of individuals to access their personal information.
This document outlines the measures we have taken to align our business, services and operations with these principles.
Open and transparent management of personal information (APP 1)
Our commitment is to manage personal information in an open and transparent way. We provide a clear Privacy Policy that details what personal information we collect, as well as how we use that information. We maintain technical, procedural and security measures to safeguard how we manage personal information as part of providing the services to you. Where applicable we also provide you with direct access to review, manage and maintain the personal information we collect as part of the services.
Anonymity and pseudonymity (APP 2)
You have the option of dealing with us anonymously or by pseudonym as it is not a requirement to provide us with personal information when using our services or when communicating with us. You maintain full control over the information that you provide to us when using our services.
Collection of solicited personal information (APP 3)
During the normal course of providing our services there are some circumstances in which we may solicit personal information from you, such as when you create an account, contact us for support or information, or make payment to us by credit card or other means. This solicitation does not remove your rights as described in APP 2, except where it may be required or reasonably necessary in order to fulfil or otherwise provide you with the service.
Dealing with unsolicited personal information (APP 4)
There may be circumstances in the course of your use of our services whereby you collect and supply us with the personal information of third parties such as the respondents to your surveys, your research participants or other parties with whom you are engaged in data collection. Such personal information is unsolicited by us and solely provided and held by you. Due to the nature of our services as an information processor on your behalf, It is unreasonable for us to destroy or de-identify unsolicited personal information that you provide to us through your use of the services as this would interfere with our ability to provide you with the services. You are solely responsible for the management of any personal information held by you and provided to us through your use of the services. Unsolicited information that you provide to us is dealt in accordance with these APPs where applicable.
Notification of the collection of personal information (APP 5)
Our Privacy Policy describes the steps we take to notify you about the purpose and circumstance of any collection of personal information by us.
Use or disclosure of personal information (APP 6)
We do not process or disclose personal information for any purpose other than to provide the services to you. Furthermore, we implement measures to ensure that entities authorised by us to process personal informational do so solely to the extent necessary to provide the services to you. In those circumstances where disclosure is required by law (for example, the Notifiable Data Breaches section of the Privacy Act), to the extent legally permitted, we will notify you of such disclosures.
Direct marketing (APP 7)
We may use solicited personal information to communicate with you to advertise and promote our product and services. All direct marketing from us will always include a facility to opt-out of receiving such communications. On request, we will provide our source for an individual’s personal information used in such direct marketing.
Cross-border disclosure of personal information (APP 8)
In limited circumstances as part of providing our services, personal information may be disclosed through transfers to those parts of our services infrastructure that may be based in foreign countries, specifically the United States and the United Kingdom. Details of when this applies can be found in our Privacy Policy. We maintain a list of the Subprocessors we may disclose personal information to as part of our delivery of the services to you, and take reasonable steps to ensure that all cross-border recipients of personal information handle it in accordance with the APPs or other similar laws or binding schemes that have the effect of protecting information in a way that is substantially similar to the APPs.
Adoption, use or disclosure of government related identifiers (APP 9)
We do not solicit the collection of government related identifiers through our provision of the services. In some cases you may provide us with a government identifier in relation to tax identification numbers (such as an ABN) for the purposes of billing, however this is not a requirement in order to use our services. We do not adopt any government related identifiers as our own identifiers in the design or use of our services.
Quality of personal information (APP 10)
We take reasonable steps to ensure that the personal information we collect as part of the services is accurate, up-to-date and complete. We provide you with the ability to review and manage the personal information we collect about you.
Security of personal information (APP 11)
Ensuring the security of your personal information is of utmost importance to us and we take active measures to protect the personal information we collect from you. We implement technical, procedural and organisational security measures to protect personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
Access to personal information (APP 12)
If we hold personal information about an individual we will, provide access to that information to that individual upon request. In circumstances where a request for access is related to personal information held by you then, to the extent permissible by law, we will advise the requester to submit their request to you directly. If you are unable to comply with a particular request then, upon your request, we will provide reasonable assistance to you in addressing the personal information provided we are legally permitted to do so and you have verified the request in accordance with applicable privacy law.
Correction of personal information (APP 13)
We endeavour to keep the personal information we collect as part of the services accurate and up-to-date. We take reasonable steps to correct personal information to ensure that it is accurate, up-to-date, complete, relevant and not misleading. To assist in maintaining the quality and correctness of personal information, we have developed capabilities within the services to enable you to review and manage the personal information that we collect about you.