Olinqua’s philosophy is simple in this regard. Our company is committed to protecting the privacy and data of customers.  While there are times when Olinqua systems handle and store data, it is solely for the purpose of providing products and services to our customers.  Olinqua is required by law to spell out these instances in a particular way which is provided here in our Privacy Policy.

OLINQUA PRIVACY POLICY

Olinqua Pty Ltd (“Olinqua”) is committed to protecting your privacy.

Olinqua is bound by the Privacy Act 1988 (Cth) (“the Privacy Act”), including the Australian Privacy Principles (“APP(s)”). Olinqua will collect, manage, use and disclose Personal Information in accordance with its Privacy Policy and all relevant Australian legislation.

Legislation

The Privacy Act outlines a comprehensive national privacy scheme for private sector organisations. Minimum standards are established for the handling of Personal Information by private organisations. The AAPs are the standard principles Olinqua complies with in relation to the Personal Information it holds.

Collection and Ownership of Your Data

Nothing in this Privacy Policy transfers ownership of your data to Olinqua, which only collects and holds Personal Information that is reasonably necessary for its functions and activities. Furthermore, Personal Information and Sensitive Information is collected through our website and mobile application, as they exist from time to time.

Olinqua may collect and temporarily hold Personal and/or Sensitive Information about you, including your:

• Name;
• Address;
• Gender;
• Address;
• Contact Details (phone number, facsimile number, email address);
• Location Information;
• Date of Birth;
• Language;
• Bank account details;
• Academic history;
• Employment record;
• Membership of a professional or trade association;
• Membership of a trade union;
• Nationality;
• Visa details;
• Passport details;
• Photograph;
• Accommodation preferences;
• Dietary requirements;
• Physical attributes;
• Medical history;
• Health cover details;
• Next of Kin details;
• Nominated person’s contact details;
• Other information relevant to providing you with the services you, or someone else you know.

The Personal Information that Olinqua collects and holds about you, depends on your interaction with Olinqua. Generally, Olinqua will collect and hold your Personal and/or Sensitive Information for the purpose of:

• Providing you with access to our website and mobile application, as they exist from time to time;
• Testing, improving and/or monitoring the functionality of our website and mobile application, as they exist from time to time
• Assessing of your, or some else’s application to use our website and mobile application, as they exist from time to time;
• Providing services to you or someone else you know;
• Recording concerns, complaints and resolutions;
• Recording payment details;
• Facilitating Olinqua’s internal business operations, including the fulfilment of any legal requirements; and
• Analysing Olinqua’s services and customer needs with a view to developing new and/or improved services.

Olinqua does not collect Personal Information for the purpose of advertising revenue or transacting that information to third parties for financial gain.

Personal Information will generally be collected by Olinqua directly from you using Olinqua’s, or its authorised agents, standard forms or by direct communication. If Personal Information is collected from you indirectly because it is unreasonable or impractical to collect it directly from you, we will endeavour to notify you in advance, or as soon as reasonably practicable after the information has been collected.Use and Disclosure

Olinqua only uses and/or discloses Personal Information and/or Sensitive Information about you for the purposes for which it was collected. In some instances, Olinqua may also disclose Personal and/or Sensitive Information about you to:

• Service providers who assist Olinqua in operating its business. Please note that service providers are required to comply with Olinqua’s Privacy Policy and Confidentiality policies handling your Personal and/or Sensitive Information;
• A purchaser of the assets and operation of Olinqua’s business, providing those assets and operations are purchased as a going concern;
• Its related entities;
• Commonwealth and State Governments and Agencies; and
• Offshore Entities. In accordance with APP 8, Olinqua takes reasonable steps to ensure that offshore entities do no breach any of the APPs other than APP 1 in relation to open and transparent management of personal information

Anonymity and pseudonymity

The APPs provide for the option of having you dealt with anonymously or by pseudonym. You can request that you be treated as anonymous or use a pseudonym during your interaction with Olinqua. However, please note that Olinqua is not required to provide this option where:

• We are required or authorised by law or a Court or tribunal order to deal with identified individuals; or
• It is impracticable for Olinqua to deal with individuals who have not identified themselves.

Retention of your Data

Olinqua claim no ownership over your data and will ensure that Personal and Sensitive Information is kept for no longer than is necessary for the purposes for which it may lawfully be used.

Records will be  securely destroyed or de-identified in accordance with any requirements for the retention and disposal of Personal and Sensitive Information under the Privacy Act, and in accordance with the access provisions set out in this Privacy Policy.

Security

Olinqua stores your data in electronic record keeping methods in secure, trusted databases. Personal information may be collected in paper-based documents and converted to electronic form for use or storage. We take reasonable steps to protect your personal information from misuse, interference, and loss and from unauthorised access, modification, or disclosure.

Olinqua maintains computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems

Access to Personal Information and Sensitive Information

Olinqua will provide you with access to your Personal and/or Sensitive Information about them upon receipt of a written request sent to our contact details provided below. Olinqua will endeavour to acknowledge such requests within 14 days of its receipt and provide the requested information/documentation within 30 days. A reasonable fee may be charged to cover costs of processing such requests.

Please note that there may be certain circumstances where Olinqua may decline a request for access to Personal and /or Sensitive Information:

• The request for access is frivolous or vexatious;
• Providing access would pose a serious threat to the life or health of an individual;
• Providing access would have an unreasonable impact upon the privacy of other individuals;
• The information relates to existing or anticipated legal proceedings between Olinqua and you, and the information would not be accessible by the process of discovery in proceedings;
• Providing access would reveal information about a commercially sensitive decision making process;
• Providing access would be unlawful;
• Denying access is required or authorised by or under law;
• Providing access would be likely to prejudice an investigation of possible unlawful activity; or
• Providing access would be likely to prejudice the activities of enforcement bodies.

Correction of Personal Information

If you believe Olinqua holds inaccurate or outdated information about you, you should notify Olinqua immediately by contacting us via contact details provided below. Olinqua will take reasonable steps to correct the information so that is accurate, complete and up to date.

Complaints

If you believe Olinqua has breached the APPs, you may make a complaint in writing to Olinqua via email to inbox@olinqua.com.

Olinqua will endeavour to acknowledge such complaints within fourteen (14) days of its receipt and will thereafter propose a deadline for a response. Olinqua’s main objective in responding to privacy complaints is to conciliate an outcome which is acceptable to the complainant and which addresses any broader or systemic privacy issues which may arise. If you do not agree with Olinqua’s response, an internal review process is available or a complainant may refer the matter for independent mediation by the Office of the Information Commissioner.

Further Information

Please see Australian Privacy Principles Guidelines.

Related Procedures

Information and notification will be provided in the event that the law changes and those changes affect Olinqua’s use of Personal and/or Sensitive Information.

Definitions

Personal Information is defined in the Privacy Act to means information or an opinion, whether forming part of a database or not, whether true or not and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable:

1. Whether the information or opinion is true or not; and
2. Whether the information or opinion is recorded in a material form or not.

Location Information allows us to infer that you are either interested in the place or that you might be at the place. For example, if your device connects to, or appears to be within range, of a particular location, we infer that you may like to see information about that shop. We use that information to provide you with information about that shop, or similar shops, to you.

Sensitive Information is defined in the Privacy Act to mean information or an opinion about an individual’s:

1. Racial or ethnic origin;
2. Political opinions;
3. Membership of a political association;
4. Religious beliefs of affiliations;
5. Philosophical beliefs;
6. Membership of a professional or trade association;
7. Membership of a trade union;
8. Sexual orientation or practices;
9. Criminal record – that is also personal information;
10. Health information about an individual;
11. Genetic information about an individual that is not otherwise health information;
12. Biometric information that is to be used for the purpose of automated biometric verification or biometric identification;
13. Biometric templates; and/or
14. Psychometric information.