Thank you for using Monarc Global. Your privacy is important to us and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs) and any related privacy codes. This Policy outlines how we collect, use, disclose and store your personal information and lets you know how you can access that information. This Policy applies to our obligations when handling information in Australia about Australian individuals. Please read this Policy carefully and contact us using the details below if you have questions.
By providing personal information, you consent to us collecting, using, storing and disclosing your personal information in accordance with this Policy or as required or permitted by law. If you continue using our services, then we will treat your use as your consent to us handling your personal information in accordance with this Policy.
3. What kinds of personal information do we collect and hold?
The type of personal information we collect will depend on the circumstances of its collection and the nature of your dealings with us. This information may include, but is not limited to:
(a) your name, address, contact details and date of birth;
(b) passport details, including your passport number, issue and cancellation date and nationality;
(c) payment and transactional information;
(d) your preferences and opinion about types of products and/or services;
(e) your device ID, device type and information, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, Internet Protocol (IP) address and standard web log information;
(f) information contained in any communications between you and us; and
(g) any information about you that you provide through our services, including information you provide if you participate in a survey, promotion or competition.
If you choose not to provide information as requested, it may not be practicable for us to service your needs. For example, it will not be possible for us to allow you to book aircraft services if you want to remain anonymous or use a pseudonym. We sometimes receive unsolicited personal information. In circumstances where we receive unsolicited personal information we will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.
4. Why do we collect your personal information?
We collect your personal information primarily to allow individuals to book chartered aircraft through a widget placed on aircraft owner or operators (Operators) site. Collecting your © Law Squared 2019 1 personal information allows us to give you information about or provide you with our products and services. Some ways we use your personal information are:
(a) to identify you;
(b) to interact with you;
(c) for the purpose for which the personal information was originally collected;
(d) to develop consumer insights so we can better understand your preferences and interests, personalise your experience and enhance the services you receive;
(e) to perform administrative and operational functions;
(f) to comply with any legal requirements, including any purpose authorised or required by an Australian law, court or tribunal; and
(g) for any other purpose for which you give your consent.
In relation to the personal information of prospective staff members and contractors, we collect personal information for purposes including to:
(a) enable us to carry out our recruitment functions;
(b) correspond with you, provide training and professional development;
(c) fulfil the terms of any contractual relationship; and
(d) ensure that you can perform your duties.
5. How we collect your personal information?
You give it to us
We collect personal information directly from you when you:
(a) use our services;
(b) set up an account with us;
(c) interact or share personal information with us via our website, app and social media;
(d) interact or share personal information with us via our widget on Operators websites;
(e) communicate with us;
(f) participate in one of our surveys, promotions or competitions;
(g) make a booking to use one of our third-parties products or services.
We collect it
We may also collect your personal information from third parties including:
(b) service providers;
(h) credit reporting bodies;
(i) marketing companies;
(j) referrals who may have referred you to us; and
(k) organisations with whom we have an agreement to share information for marketing purposes.
We will generally obtain consent from the owner of personal information to collect their personal information. Consent will usually be provided in writing; however, sometimes it may be provided orally or may be implied through a person’s conduct. We will endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.
6. Disclosing your personal information
We may disclose your personal information to the following third parties:
(b) to our business or commercial partners, including the owners or operators of any app or platform for which you have subscribed through us or in connection with us;
(c) to our professional advisers, dealers and agents;
(d) third parties and contractors who provide services to us, including customer enquiries and support services, debt-recovery functions, information technology service providers, marketing and advertising;
(e) payment processing service providers; and
(f) any third parties authorised by you to receive information held by us.
We may also disclose your personal information if we are required, authorised or permitted by law. We may send information to third parties that are located overseas. These third parties are located in Canada, United States, United Kingdom, Europe, UAE, although this list may change from time to time. Disclosure is made to the extent that it is necessary to perform our functions or activities.
7. Using your personal information for direct marketing
From time to time, and in support of our future development and growth, we or our business partners may use your personal information to contact you to promote and market our products and services. You can opt-out from being contacted for direct marketing purposes by contacting us at [email protected] or by using the unsubscribe facility included in each direct marketing communication we send. Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time.
We take all reasonable steps to protect personal information under our control from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold your personal information in electronic form, in secure databases operated by our third-party service providers. We protect the personal information we hold through [list security measures e.g. encryption / firewalls and login password protocols / secure and access-controlled premises / monitoring staff access / auditing / network segregation for sensitive information store electronically]. While we take reasonable steps to ensure your personal information is protected from loss, misuse and unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed.
9. Accessing or correcting your personal information
Accessing your personal information If you would like to access your personal information, please contact us using the details below. In certain circumstances, we may not be able to give you access to your personal information. In these circumstances, we will write to you to explain why we cannot comply with your request. While we try to give you access to your personal information free of charge, we may charge you a reasonable fee if necessary. Correcting your personal information We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant. If you believe the personal information we hold about you should be updated, please contact us using the details below and we will take reasonable steps to ensure it is corrected if appropriate.
10. Destroying or de-identifying personal information
We destroy personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.
11. Making a complaint
If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below. We take privacy complaints seriously. If you make a complaint, we will respond within 14 days to acknowledge your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint. We will investigate your complaint and, where necessary, consult with third parties about your complaint. We will decide how to address your complaint and write to you to explain our decision as soon as practicable. If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Privacy Commissioner and/or other enforcement bodies like the Office of the Victorian Information Commissioner.
We may, from time to time, amend this Policy, in whole or part, in our sole discretion. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our website. By continuing to use the services following any changes, you will be deemed to have agreed to such changes.
13. Contact us
All questions or queries about this Policy and complaints should be directed to: Privacy Officer Phone: 1 300 466 6272 Email: [email protected]
This Policy was last updated in October 2019.
1. Overview Monarc
2. User Consent
3. What Personal Information we collect
We will only collect Personal Information from you if it is reasonably necessary for one or more of our functions or activities. Personal Information means any information that allows someone to identify you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
3.3 Information we collect from others (a) Data and content other people upload We may also collect information and communications that other people provide when they use our Services. This can include information about you such as when others send messages, documents and information to you. We may also collect your information if you are invited to participate in our Services this may include information such as your name, mailing address, phone number, email address, contact preferences and is used for the purpose of enabling us to provide our Services to you. We will only collect information about you directly from you, except where it is unreasonable or impracticable to do so.
4. How we use your Personal Information
5. Disclosure of your Personal Information
6. If we can’t collect your data
If you do not provide us with the personal information described above, some or all of the following may happen: − we may not be able to provide the requested products or services to you, either to the same standard or at all; − we may not be able to run the competitions and promotions in a way that benefits you; − we may not be able to provide you with information about products and services that you may want; or − we may be unable to tailor the content of our Services to your preferences and your experience of our Services may not be as enjoyable or useful.
7. Cookies Policy
7.1 What are cookies? A cookie is a small piece of text sent to your browser by a website that you visit. It helps the website to remember information about your visit, like your preferred language and other settings. That can make your next visit easier and the site more useful to you. Cookies play an important role. Without them, using the web would be a much more frustrating experience.
7.3 How to manage cookies Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the Monarc Services may not be available once cookies are disabled.
8. Third party websites
9. Managing your Personal Information
Subject to the Privacy Act and the GDPR you may request to access the personal information we hold about you by contacting us. All requests for access will be processed within a reasonable time. (a) Accessing or rectifying your Personal Information We may, if required, provide you with tools and account settings to access, correct, delete, or modify the Personal Information you provided to us. You can find out more about how to do this by contacting us. In the event that you are unable to access your Account to access or rectify your Personal Information, you may submit a request to us to correct, delete or modify your Personal Information and download the data for you. (b) Deletion We keep data for as long as it is needed for our operations. If you deactivate and delete your Account, your data will no longer be visible on your Account. Please keep in mind that third parties may still retain copies of information you have made public through our Services. If you wish to have us delete your data, please contact us. (c) Object, restrict or withdraw consent If you have an Account on the Services, including the website, you will be able to view and manage your privacy settings. Alternatively, if you do not have an Account, you may manually submit a request to us if you object to any Personal Information being stored, or if you wish to restrict or withdraw any consent given for the collection of your Personal Information. You may withdraw your consent to the processing of all your Personal Information at any time. If you wish to exercise this right, you may do so by contacting us. You may withdraw your consent or manage your opt-ins by either viewing your account on the Services or clicking the unsubscribe link at the bottom of any marketing materials we send you. (d) Portability We may, if required and possible, provide you with the means to download the information you have shared through our services. Please contact us for further information on how this can be arranged. In certain instances, we may not be required or able to provide you with access to your personal information. If this occurs, we will give you reasons for our decision not to provide you with such access to your personal information in accordance with the Privacy Act and the GDPR. There is no application fee for making a request to access your personal information. However, we may charge an administrative fee for the provision of information in certain circumstances such as if you make repeated requests for information or where the information is held by a third-party provider. Where we act as a data processor, we do so on behalf of our client and in accordance with their instructions. This means that should you wish to access, review, correct, transfer, modify or delete any Personal Information we process on behalf of a client you should contact the client with your request.
10. Direct marketing materials
We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
11. Storage and Security of Your Personal Information
12. International Transfer and Disclosure of Personal Information
Where we are required to use suppliers outside of Australia, we ensure that all our suppliers are required to adhere to the Australian Privacy Principles. Where we transfer Personal Information from within to outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws. We may disclose personal information to our related bodies corporate and third-party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information. We may disclose your personal information to entities located outside of Australia, including the following: − our related bodies corporate; − our data hosting and other IT service providers, located in various countries; and − other third parties located in various foreign countries. We may disclose your personal information to entities within Australia who may store or process your data overseas.
13. Notifiable Data Breaches
We take data breaches very seriously. We will endeavour to meet the 72-hour deadline as imposed by the GDPR, to report any data breach to the supervisory authority where a data breach occurs that will likely be a risk to you. Further, where there is likely to be a high risk to your rights, we will endeavour to contact you without undue delay. We will review every incident and take action to prevent future breaches.
14. Automated individual decision-making, including profiling
If you reside in the European Union or EFTA States, you shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between us, or is not authorized by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your explicit consent. If you wish to exercise your rights, please contact us.
15. Integrity and Retention of Data
16. Contact Information