Privacy

1. Introduction

Sykes Group Pty Ltd and its related entities (Sykes Group) are committed to providing customers with the best value products and services, both in the field and online. We also recognise and respect the privacy of your personal information and we understand the importance of managing such information properly. This Privacy Policy provides an overview of how Sykes Group protects the privacy of your personal information, your rights in relation to the personal information collected by Sykes Group and the way in which Sykes Group collects, holds, uses and discloses your personal information. Sykes Group will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) in the Privacy Act.

2. What kinds of personal information does Sykes Group collect and hold?

Sykes Group may collect personal information about you as part of our exchange of goods and services or when you visit and browse our website. The kinds of personal information Sykes Group collects and holds are:

• a) contact information such as your name, company name, business street and postal address, telephone and facsimile number, email address and other personal contact details;
• b) professional information including your position title and job responsibilities;
• c) your interests in goods and services and past purchases;
• d) your payment and delivery information and preferences for purchases; and
• e) credit information, such as identification information, credit liability information including information about credit accounts and credit limits, repayment history information, details about credit defaults and credit eligibility information from a credit reporting agency and references.

3. How does Sykes Group collect personal information?

Sykes Group generally collects personal information directly from you when you:

• a) provide us with an order for our goods or services;
• b) agree to provide goods and services to Sykes Group;
• c) complete a credit application form with Sykes Group;
• d) complete a job application form with Sykes Group;
• e) request a quote from Sykes Group;
• f) provide us with personal information via telephone, email or face-to-face;
• g) take part in our internal market research; or
• h) complete a form on our website.

Sykes Group may also collect your personal information from an information services provider, credit reporting agency or a publicly maintained record. You may choose to deal with us anonymously or under a pseudonym where lawful and practicable (ie provided we are still able to provide the relevant service or do business with you without that information). For example, it might not be practical to deal with you anonymously if we need to process a payment, deliver goods or services or send personalised communications to you. Some information is automatically received and collected from you when you visit our website. We automatically receive and collect the name of the domain from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our site; the geographic location from which you access our site; and the Internet address of the web site from which you linked directly to our site. We use this information to monitor the usage of our site. All of the information we automatically capture provides us with the ability to enhance our customers’ search and shopping experiences and to determine aggregate information about our user base and usage patterns. In general, you can browse our website without revealing any personal information. In these circumstances, we may collect certain information about how you use the site which we use anonymously. However, once you register or otherwise voluntarily provide personal information to us, you are no longer anonymous to us. When you click on links and banners on our site that take you to a third-party web site (ie sites which are not controlled by Sykes Group), you will be subject to the third-party’s privacy policies. While we support the protection of privacy on the Internet, Sykes Group is not responsible for the actions of any third-party web sites and these sites are not subject to this Privacy Policy. We encourage you to read the posted privacy statement of any third-party site you visit, whether you are linking from our site or browsing on your own.

4. How does Sykes Group use electronic mechanisms such as ‘cookies’?

We use data collection devices such as “cookies” to deliver customised visitor experiences and to analyse website user metrics. “Cookies” are small files placed on your hard drive when you visit a website to track the pages you have visited. These cookies do not collect or track any personal data or information about you as an individual. Instead, they are focused on how the website is used, and seek to enhance the accessibility of the website. While you may configure your browser to reject cookies, due to the technology we use, cookies are required to register with, and purchase products and services online from, this website. Most cookies are “session cookies”, which means they are automatically deleted from your hard drive once you close your browser. You may encounter cookies or other data collection devices that are placed by third parties. We do not control the use of cookies by third parties. This Privacy Policy places all users of this website on notice about our use of cookies. Your continued use of this website confirms to us that you are fully aware of and accept our use of cookies.

5. Why does Sykes Group collect my personal information?

Sykes Group collects, holds and uses personal information that is reasonably necessary to conduct our business activities, to enable us to:

• a) provide goods and services to you;
• b) obtain goods and services from you;
• c) maintain your contact details;
• d) identify you and conduct appropriate checks, including credit checks;
• e) undertake accounting, billing and other administrative activities;
• f) identify and inform you of Sykes Group’s goods and services that may be of interest to you;
• g) recruit, manage, train and develop our employees and representatives;
• h) conduct internal research on Sykes Group’s website users’ demographics, behaviours and interests to enhance product development and customer satisfaction; and
• i) capture metrics on the number of visitors to our websites for use in server capacity needs.

Without this information, we may not be able to do business with you. By using Sykes Group’s websites, products or services, you consent to Sykes Group using your personal information as set out in this Policy.

6 How will Sykes Group use and disclose personal information?

Sykes Group treats the handling of your personal information very seriously. To that end, Sykes Group has systems and procedures in place to protect your privacy in relation to the handling of your personal information. Generally, Sykes Group will use and disclose the personal information collected for the purpose for which it was provided to us, or related purposes which would reasonably be expected without your permission. For example, we may use and disclose your personal information:

• a) to do business with you;
• b) to build our relationship with you;
• c) to provide you with goods and services and to send communications requested by you;
• d) for our internal and corporate group management, administrative, planning and marketing purposes;
• e) to obtain credit history information about customers;
• f) for debt recovery;
• g) to inform you of our goods and services that may be of interest to you and to send information about future events and promotions; and
• h) to compile and report statistics using de-identified information.

Additionally, in the event of a re-organisation, merger or sale, Sykes Group may transfer all personal information we have collected from you to the relevant third party. Sykes Group may also be required to disclose your personal information without your consent if the disclosure is:

• a) required or authorised by law;
• b) required in order to investigate an unlawful activity;
• c) required by an enforcement body for investigative activities; or
• d) necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.

Sykes Group does not collect personal information unless it is reasonably necessary for Sykes Group to perform one or more of its functions and activities or supply one or more of its services. Sykes Group may need to disclose your personal information to others who help us to do business with you. Those people may include:

• a) our suppliers and contractors;
• b) network operators;
• c) financial institutions;
• d) our employees, members of our corporate group and service providers;
• e) other organisations with your consent; and
• f) debt collectors when payments are overdue.

7. Overseas disclosures

Generally, Sykes Group will retain your personal information within Australia. However, on some occasions Sykes Group may need to disclose personal information to overseas recipients to enable us to provide goods and services and for other management purposes. Recipients of such disclosures are likely to be members of our corporate group located in Indonesia, United Arab Emirates, South Africa, New Zealand and the United States of America. Sykes Group will take all reasonable steps in the circumstances to ensure that the overseas entity does not breach the APPs in relation to the information or is bound by a substantially similar privacy law or scheme to the APPs unless you consent to the overseas disclosure or it is required or permitted by law.

8. Direct marketing

Sykes Group may use or disclose some of the personal information collected for the purpose of direct marketing or to advise you about our products or services that may be of interest to you. By submitting your personal information to us, you consent to us using your personal information for direct marketing purposes. You may request not to receive any direct marketing material from us by following the prompts on any direct marketing material sent to you or by electing to opt out by contacting us as noted in the Contact section below.

9. How does Sykes Group store and manage personal information?

Sykes Group takes all reasonable security measures to ensure that your personal information is adequately protected from loss, unauthorised access, destruction, misuse, modification or disclosure. Sykes Group holds personal information in both electronic and hard copy forms in secure premises and databases. Sykes Group maintains physical security over its paper and electronic data stores, such as locks and security systems. Sykes Group also uses computer and network security technologies such as firewalls, intrusion prevention software, antivirus software, external email filtering and passwords to control and restrict access to authorised staff for approved purposes and to secure personal information from unauthorised access, modification, disclosure, misuse and loss. To prevent unauthorised access or disclosure, to maintain data accuracy and to ensure the appropriate use of the information, we use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data, such as financial information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window. However, please be aware that there are inherent risks in transmitting information by use of the Internet and other online transmission systems and that we cannot guarantee the security of information transmitted in this way. Sykes Group’s objective is to ensure that all personal information collected by Sykes Group is accurate, complete and up-to-date. To assist Sykes Group in achieving its objective, please contact the Privacy Compliance Officer if any of your details change. Sykes Group will destroy or de-identify personal information when we no longer need it, unless we are permitted or required by law to retain the information.

10. Access and correction of personal information

You have a right to request access to your personal information held by Sykes Group and to request its correction. Sykes Group will grant you access to your personal information in accordance with the Privacy Act and the APPs. We may refuse access in circumstances set out in the APPs and will provide you with reasons as to why access was refused. If you believe that the information we hold about you is inaccurate, out of date, incomplete or misleading, you may request us to correct the information. We will take such steps as are reasonable in the circumstances to correct the information where appropriate. To request access to or correction of your personal information, please contact us in writing as noted in the Contact section below. You must provide as much detail as possible regarding the business entity, department or person to whom you believe your personal information has been provided, and when. This will allow us to process your request faster. You may be asked to verify your identity. We may charge you a reasonable fee for retrieving, copying, or allowing access to the requested information.

11. About children

Sykes Group is committed to protecting the privacy needs of children (persons under the age of 18) and encourages parents and guardians to take an active role in their children’s online activities and interests. We ask that children do not submit any personal information to us via our website. If you are under the age of 18, you should only use this website in conjunction with, and under the supervision of, your parents or guardians.

12. Your consent

By your continued use of this website, registering with Sykes Group to receive any information or providing your personal information to us, you consent to our use of your personal information in accordance with this Privacy Policy.

13. Contact, complaints and further information

If you have questions or require further information about this Privacy Policy, wish to request for access to, or correction of, your personal information, or wish to make any complaints regarding the treatment of your privacy, please contact our Privacy Compliance Officer at:

By Mail:	Privacy Compliance Officer c/- Legal Department Sykes Group Pty Ltd 42 Munibung Road, Cardiff
By Mail:	privacy@sykesgroup.com
By telephone:	+61 2 4954 3333

If you believe that your privacy has been infringed or a breach of the APPs has occurred, you are entitled to complain. All complaints should initially be in writing and directed to the Privacy Compliance Officer. Sykes Group will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. Sykes Group will try to resolve the complaint as soon as possible. If you believe Sykes Group has not adequately dealt with your complaint, you may complain to the Privacy Commissioner whose contact details are as follows:

• Officer of the Australian Information Commissioner (OAIC)
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• GPO Box 5218 Sydney NSW 2001

14. What happens if this Privacy policy changes?

If Sykes Group updates or changes this Privacy policy, the changes will be made on this page. Your continued use of the applications on this website and your continued dealings with Sykes Group, following the posting of changes to this Privacy policy, will mean you accept those changes and terms of this Privacy policy.