The Company commitment to privacy
My Spare Key Pty Ltd (ACN 632 635 388), its subsidiaries and affiliates in Australia (collectively referred to as ‘My Spare Key’) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.
About My Spare Key
My Spare Key is an Australian business supplying spare key services to its clients enabling them to access their homes and buildings when they have lost their keys.
What information does My Spare Key collect about you?
(a) Customers and prospective customers
When you enquire about our products, request our services or when you become a client of My Spare
Key, a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of products that you request from us, but will typically include:
(i) your name, e-mail, address and other contact details;
(ii) any additional personal information you provide to us, or authorise us to collect, as part of your interaction with My Spare Key.
(b) Visitors to our websites
The way in which we handle the personal information of visitors to our websites is discussed below.
How and why does My Spare Key collect and use your personal information?
My Spare Key collects personal information reasonably necessary to carry out our business, to assess and manage our customers' needs, and provide our services and products including spare key services. We may also collect information to fulfil administrative functions associated with the supply of our products and services, for example billing, entering into contracts with you or third parties and managing client relationships.
The purposes for which My Spare Key usually collects and uses personal information depends on the nature of your interaction with us, but may include:
(a) supplying our services and products;
(b) responding to requests for information and other general inquiries; (c) informing you of our services and products; and
(d) responding to enquires and complaints.
My Spare Key generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example
(a) our affiliated and related companies; and
(b) third party suppliers and contractors who assist us to operate our business.
My Spare Key also collects and uses personal information for market research purposes and to innovate our delivery of products and services.
How does My Spare Key interact with you via the internet?
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
My Spare Key’s website may contain links to third-party websites. My Spare Key is not responsible for the content or privacy practices of websites that are linked to our website.
Can you deal with My Spare Key anonymously?
My Spare Key will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for My Spare Key to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to purchase our products, utilise our services or participate in our events, programs or activities we manage or deliver.
How does My Spare Key hold information?
My Spare Key stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
My Spare Key maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain 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.
Our website does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our website are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
Does My Spare Key use or disclose your personal information for direct marketing?
My Spare Key may use or disclose your personal information for the purpose of informing you about our products, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, My Spare Key may still contact you in relation to its ongoing relationship with you.
How does My Spare Key use and disclose personal information?
(a) For customers
The purposes for which we may use and disclose your personal information will depend on the products and services we are providing you. For example, if you have engaged us to deliver a service or product, we may disclose information about you to service providers where this is relevant to our services or products.
(b) Disclosure to contractors and other service providers
My Spare Key may disclose information to third parties we engage in order to provide our products and services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
Personal information may also be shared between related and affiliated companies of My Spare Key, located in Australia and overseas.
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
(c) Use and disclosure for administration and management
My Spare Key will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
(i) administering billing and payments and debt recovery;
(ii) planning, managing, monitoring and evaluating our products and services; (iii) quality improvement activities;
(iv) statistical analysis and reporting;
(v) training staff, contractors and other workers;
(vi) risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
(vii) responding to enquiries and complaints regarding our products and services; (viii) obtaining advice from consultants and other professional advisers; and
(ix) responding to subpoenas and other legal orders and obligations. (d) Other uses and disclosures
How can you access or seek correction of your personal information?
You are entitled to access your personal information held by My Spare Key on request. To request access to your personal information please contact our privacy officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information, we hold about you and letting us know if your personal details change.
However, if you consider any personal information, we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
What should you do if you have a complaint about the handling of your personal information?
You may make a complaint about privacy to the privacy officer at the contact details set out below.
The privacy officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that My Spare Key may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
How can you contact My Spare Key? The contact details for My Spare Key are: Privacy Officer
My Spare Key
44 Kellett Street
Points Point NSW 2011
Phone: 0439 456 660