Exchange for Change Privacy Policy

In this Privacy Policy, 'us', 'we' or 'our' means Exchange for Change (NSW) Pty Ltd | Exchange for Change (ACT) Pty Ltd [(ACN 620 512 469 | ACN 625 238 799) and our related bodies corporate. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website regularly as it is your responsibility to ensure that you are aware of our current Privacy Policy.

What personal information do we collect?

We may collect the following types of personal information:

  • name;
  • mailing or street address;
  • email address;
  • telephone number and other contact details;
  • age or date of birth;
  • bank account details;
  • credit card information;
  • your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
  • details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
  • any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information; and
  • any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties from whom you have authorised us to collect personal information. We usually collect information directly from individuals when they register to use our online portal. We may also collect personal information when you:

  • communicate with us through correspondence, chats, email; or
  • when you share information with us from other social applications, services or websites; or
  • provide us with feedback; or
  • interact with our sites, webforms, services, content and advertising.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.

The applicable privacy legislation to which we are subject (See Privacy Legislation below) contain certain exemptions in relation to certain acts undertaken in relation to employee records and related bodies corporate. Where appropriate we make use of the relevant exemptions.

We endeavour to collect your information directly from you. However, in some circumstances, where authorised by you, we may collect your information from third parties, such as your employer or contracting organisations, a service provider or from a publicly available record.

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for one of the following purposes:

  • to facilitate your participation in the NSW beverage container deposit scheme and the ACT beverage container deposit scheme including allowing you to collect, deposit, receive payment for, buy or sell, containers as part of the NSW and ACT beverage container deposit scheme;
  • to enable you to access and use, and us to monitor your use of, our website and services;
  • to operate, protect, improve and optimise our website, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • if you subscribe to an online mailing list, to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  • to reply to feedback;
  • as part of a sale or transfer of assets or other corporate transaction;
  • primarily to fulfil our functions and responsibilities as the scheme coordinator under the Waste Avoidance and Resource Recovery Act 2001 (NSW) and the Waste Avoidance and Resource Recovery Act 2016 (ACT) respectively and to comply with our other legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
  • to consider your employment application;
  • to investigate any unauthorised or unacceptable use of the website or any content on the website; or
  • to investigate any fraudulent conduct or suspected fraudulent in connection with the scheme.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

We do not use or disclose your personal information to any person or organisation unless it is directly related to or reasonably necessary for, one of the purposes described above.

Do we use your personal information for direct marketing?

We will not send you direct marketing communications and information about our service by email unless you have consented to receive direct marketing materials from us. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link). Direct marketing materials which you may choose to opt-out of receiving excludes general factual information about our service.

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this privacy policy to:

  • our employees and related bodies corporate;
  • the [New South Wales | ACT] government;
  • our scheme partners, including [the New South Wales Environment Protection Authority and Tomra Cleanaway | Transport Canberra, City Services and Re. Turn It (Canberra)];
  • third party suppliers and service providers which are expected to comply with the relevant privacy legislation (including DocuSign which may receive or store the information utilising cloud technology in an overseas jurisdiction, including Germany or the Netherlands, and other service providers or contractors we use for our websites and/or our business or in connection with providing our products and services to you);
  • professional advisers, dealers and agents;
  • payment systems operators (eg merchants receiving card payments);
  • our existing or potential agents, business partners or partners;
  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • specific third parties authorised by you to receive information held by us;
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law; and/or
  • other persons, as necessary to facilitate our dealings with you.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other devices. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. These include using encryption technologies and deploying anti-malware and anti-virus software. Our IT environment is audited annually by Independent IT Auditors. However, we cannot guarantee the security of your personal information transmitted over the Internet as no data transmission over the Internet can be totally secure given the prevalence of interception or hacking of data by unauthorised third parties.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

We will take reasonable steps to ensure the personal information we collect, use or disclose is accurate having regard to the purpose of use and disclosure. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected. We will respond to all requests for access and/or correction within a reasonable time.

Making a complaint

If you think we have breached the relevant privacy legislation, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details provided below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. We may notify the ACT and NSW governments of your complaint; however, we will not disclose personal information in connection with the complaint unless we have your consent to do so. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Exchange for Change

PO Box 3414

Rhodes NSW 2138

Phone: +61 2 9119 8810

E: info@exchangeforchange.com.au

Privacy Legislation

We are subject to the following privacy legislation under our respective contractual agreements with the ACT and NSW governments:

  • Privacy Act 1988 (Cth) and the Australian Privacy Principles set out in that Act
  • The Privacy and Personal Information Protection Act 1998 (NSW)
  • Information Privacy Act 2014 (ACT)

Effective: May 2020