Last revised and updated in March 2021
TM Insight Operations Pty Ltd ACN 638 506 340 trading as TMX Transform and its related entities (collectively referred to as “TMX Transform”, “we”, “us” or “our”) recognise the importance of your privacy and are committed to the protection of your Personal Information in accordance with the Privacy Act 1988 (Cth) as updated or amended from time to time (“Privacy Act”) and the Australian Privacy Principles set out in the Privacy Act.
By using or accessing our website https://tmxtransform.com/
”) and any services operated or made available to you by TMX Transform (“TMX Transform Systems
- What is Personal Information?
is defined in section 6 of the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
- What kinds of Personal Information we collect?
We only collect Personal Information about you that is necessary to provide our services to you and to perform our functions and activities.
The categories of Personal Information which TMX Transform may collect and hold includes the following types of Personal Information:
- contact information (including full name, email address, mailing address and telephone/mobile phone number);
- information provided in connection with the use or purchase of any services supplied by TMX Transform; and
- information provided by you through TMX Transformrelated communication channels such as social media sites managed or owned by TMX Transform, telephone and/or email support, customer service or customer surveys.
- When and how we collect information?
We collect Personal Information in a number of ways, including:
- directly from you, including when you:
- buy or use our services;
- when you provide information online, by phone, in application forms or in agreements;
- request information about us or our services;
- provide feedback to us;
- contract with us; and
- contact us by our Website, telephone, facsimile, email, post or in person;
- from an associated entity of TMX Transform; and
- from social media sites managed, used or owned by TMX Transform.
- Information collected via our Website
TMX Transform will not collect any Personal Information from you when you use our Website except when you knowingly provide it or as otherwise described below. For example, TMX Transform may collect Personal Information from you when you:
- complete an online form on our Website; and/or
- complete one or more of our surveys; and/or
- otherwise correspond with TMX Transform.
When you use our Website, the relevant server may cause a small data file called a “cookie” to be saved to your computer’s memory.
For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
TMX Transform tracks visitor and prospect activities on our website and landing pages by setting cookies on their browsers. Cookies are set to remember preferences (like form field values) when a visitor returns to our site. TMX Transform (Pardot) cookies don’t store personally identifying information, only a unique identifier.
Types of Cookies used
There are two cookies used
The visitor cookie, set by the tracking code on website visitors.
This is shown as “visitor_id” followed by the unique identifier for that visitor, eg. “visitor_i6780”. You can see an example below. No personally identifiable information is stored in the cookie, and the visitor remains anonymous.
If Tracking Preferences Opt-in banner is enabled, and:
The visitor clicks ‘yes’: they will be tracked
The visitor clicks ‘no’: they won’t be tracked
The visitor does nothing: they won’t be tracked
- Use of Personal Information
TMX Transform uses the Personal Information it collects about you to provide services and for our business functions and activities, which may include the following:
- to provide you with information or services you have requested;
- to communicate with you;
- to operate, protect, administer, maintain and manage the TMX TransformSystems;
- to personalise and customise your experiences on our Website or any TMX Transform System;
- to screen for potential risk or fraud;
- to help TMX Transform research the needs of its customers;
- to conduct research for the purposes of improving existing services or creating new products or services;
- to provide you with information, marketing or promotional messages or advertising which we believe may be of interest to you, including information on our services or activities and information on third parties (who may or may not have a relationship with us);
- to comply with regulatory or other legal requirements;
- for purposes related to the employment of our personnel and providing internal services to our staff; and
- for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
TMX Transform may use your Personal Information for a secondary purpose if that secondary purpose is related to the purposes listed in the previous paragraph, and you would reasonably expect us to use it for that secondary purpose, if we have your consent or if otherwise provided for under the Privacy Act.
TMX Transform may use your Personal Information to provide you with direct, targeted, or other marketing materials on an ongoing basis. Subject to and in accordance with applicable law, TMX Transform may provide you with these materials by telephone, electronic messages (e.g. email), through social media sites managed, used or owned by TMX Transform and other means. TMX Transform will only provide you with direct marketing materials where you would reasonably expect us to, or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing communications may include promotional material about TMX Transform or may relate to the services TMX Transform, and our related entities provide and other products and services which may be of interest to you.
You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in the “Contact us” section below.
Who we may disclose Personal Information to
- Disclosure of Personal Information
Depending on the nature of your engagement with TMX Transform, we may disclose your Personal Information to our shareholders, officers, employees, contractors, consultants, advisers, agents and related bodies corporate of TMX Transform, third parties that provide products and services to or through TMX Transform or our Website or TMX Transform Systems, directly to you (at your request), suppliers and other third parties, or otherwise as required by law.
TMX Transform may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.
We use every reasonable step to ensure data is stored onshore (within Australia). However, we cannot guarantee that data never leaves Australian shores due to technical limitations with internet routing systems. However, all data is encrypted in transit. We may also share data with our related bodies corporate that are located in Singapore and New Zealand.
We will only consciously transfer your Personal Information overseas if:
- we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds privacy principles substantially similar to the privacy principles set out in the Privacy Act;
- you have consented to the transfer; or
- we are otherwise required or authorised by law.
By consenting to provide us with Personal Information (whether by using the TMX Transform Systems, through a Privacy Statement or otherwise), you consent to the disclosure of your Personal Information to third parties who reside outside Australia and, if you are a European Union (EU
) citizen, to third parties that reside outside the EU. Where the disclosure of your Personal Information is solely subject to Australian privacy laws (and not subject to the European Union’s General Data Protection Regulation), you acknowledge that we are not required to ensure that those third parties who reside outside Australia comply with Australian privacy laws.
- Employee records
Employee records are not generally subject to the Privacy Act. As such this policy may not apply to the handling of officer, employee, contractor or consultant information. Please contact us directly for information about these information handling practices.
How you can access your Personal Information
- Access to Personal Information
You have a right to access your Personal Information. If you would like to do so, please direct your request to TMX Transform by email or post using the contact details set out in the “Contact us” section below.
Sometimes, we may not be able to provide you with access to all of your Personal Information. This may include where giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals. If we refuse you access, we will tell you why.
We reserve the right to charge a fee for searching for and providing access to your Personal Information (but not for the request itself). We may need to verify your identity as part of this process.
Accuracy of Personal Information
We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You have a right to request that your Personal Information be corrected. If you think that Personal Information we hold about you is not accurate, complete and up-to-date, please contact us using the contact details set out in the “Contact us” section below and we will take all reasonable steps to correct the information.
- Security of Personal Information
We understand the importance of protecting your Personal Information. We take all reasonable precautions to protect the Personal Information we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure.
TMX Transform aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on any TMX Transform Systems.
How long we keep your Personal Information for
If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).
- Contact us
If you have any questions or would like further information about our privacy policies or practices, please contact us by any one of the following means:
- Email: email@example.com
- Telephone: +61 3 9908 3040
- Post: 387 City Road, South Melbourne, Victoria 3205
- Data breaches or complaints
If you wish to report a data breach or make a complaint about the way we have collected, used, held or disclosed your Personal Information, please contact us using the contact details listed in the “Contact us” section above.
To assist us in helping you, please gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
We will use the information you provide to investigate and respond to your data breach report or privacy complaint. We aim to resolve all complaints as quickly as possible. Some complaints are resolved within weeks, but more complex complaints may take longer. You may withdraw your complaint at any time.
If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.