ATAME - Privacy Policy

ATAME PTY LTD – Privacy Policy

Introduction

In this Policy, ATAME, we, our or us is a reference to ATAME PTY LTD (ACN 612 840 605).
Personal information is any information about a person where their identity is apparent, or can reasonably be ascertained, and includes Sensitive Information (Personal Information).
Sensitive Information is information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences, health or medical information or criminal records.
Software means the cloud based trust accounting software owned by ATAME and all related materials and documentation.

What this Policy is about

This Policy explains the key measures we have taken to implement the requirements of the Privacy Act 1988 and the Australian Privacy Principles. This Privacy Policy outlines the Personal Information collection practices utilised by ATAME, how that information is collected, used and disclosed and your rights in relation to your Personal Information.
This Policy covers Personal Information collected directly from individuals, but also Personal Information provided by or collected on behalf of ATAME’s clients (Clients) relating to the Clients’ individual customers.
We endorse fair information handling practices and uses of information in compliance with our obligations under the privacy laws in force in Australia from time to time. Any information provided, including identification of individuals, will be used only for the purpose/s intended and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.
This Policy represents the default position that ATAME will take in its treatment of Personal Information. ATAME will treat all Personal Information in a manner consistent with this Policy unless you (either directly or if applicable, via a Client) have provided your express consent otherwise.

Collection of Personal Information

ATAME collects the following Personal Information:

Personal Information about Clients, including name, address, contact details and credit card details;
Personal Information about Customers, including name and contact details, credit card details and information volunteered through use of the software.

Personal Information will be typically collected:

when provided directly to ATAME by you through our website www.ATAME.com.au(Website) or by other means;
from a Client’s use of the Software;
directly from a Client; and
from a system or application programming interface (API) operated by a Client to which we have been granted access by the Client by its use of the software.

Our Website automatically collects anonymous usage data about visitors, including the URL that the visitor came from, the browser being used and the IP address. This data is utilised to improve the services of ATAME and does not include any personally identifying information.
ATAME also reserves the right to collect anonymous usage data through the Website, the Software and other online systems in order to provide Clients with a better user experience. This data does not include any personally identifying information.
'Cookies' are alphanumeric identifiers that are stored by the web browser on a computer's hard-drive that enable our system to recognise a visitor to our Website. This helps ATAME to track basic visitor information for the purposes of optimising the design of our systems and marketing activities. Where online transactions are made over the Website, we may also use cookies to assist in providing security for that transaction.
Most web browsers automatically accept cookies and this function can be disabled by changing the browser settings of the user.

Use of Personal Information

ATAME uses Personal Information for our own internal administration purposes such as billing Clients and user testing of the software.
We may also use Personal Information we collect for related purposes such as:

to record information about a Client’s usage, preferences and behaviour in relation to the Website and Software, as well as any feedback provided by Clients;
to perform statistical analyses of user behaviour;
to optimise marketing activities, user experience, and content;
to optimise the Software;
protecting individuals, Customers and Clients from fraud; and
any other use for which we obtain permission from the Client.

We do not pass on any Personal Information to a third party except in accordance with this Privacy Policy.
As a user of ATAME's products or services, Clients may occasionally receive email, promotional material or other updates from us about new information, briefings or products or services being offered by ATAME or any of its related companies or business partners, along with newsletters and any noteworthy changes to the Website. Clients may always unsubscribe and opt out from receiving these messages.
ATAME will not use Personal Information collected in the provision of services to Clients to directly market to Customers, unless permission is expressly given.

Disclosure of Personal Information

Other than disclosure to service providers (explained below) or as required by law (for example, disclosure to various Government departments or to Courts), our policy is that we do not give Personal Information to other organisations unless we have disclosed the use in this Policy or the Client has expressly consented for us to do so.
The parties we may share Personal Information with are employees, subcontractors, suppliers and affiliates of ATAME on a need to know basis. Access to Personal Information will be revoked within a reasonable timeframe of access no longer being required.
Occasionally, ATAME might also use Personal Information for other purposes or share Personal Information with another organisation because:

we believe it is necessary to protect your rights, property or personal safety;
we believe it is necessary to do so to prevent or help detect fraud or serious credit infringements – for example, we may share information with other, credit reporting agencies, law enforcement agencies and fraud prevention units; or
we believe it is necessary to protect the interests of ATAME – for example, disclosure to a Court in the event of legal action to which ATAME is a party.

When we share information with other organisations and service providers as set out above, we do so in accordance with this Policy. To the extent that these organisations and service providers gain access to Personal Information, their use is governed by the provisions of the Privacy Act 1988.

Confidentiality and Data Security

Some Personal Information and Sensitive Information may be stored on secure servers located outside Australia.
We take all reasonable steps to manage data stored on our servers to ensure data security and to prevent the loss, misuse or alteration of Personal Information. Notwithstanding the above, ATAME is not responsible for any third-party access to Personal Information as a result of:

interception while it is in transit over the internet;
an unpatched vulnerability, a zero-day vulnerability, or a deliberate malicious attack within 48 hours of a vendor releasing a patch or update; or
spyware or viruses on the device (such as a computer or phone) from which Clients access the Website or Software; or
as a result of a Client’s failure to adequately protect their user name or password (if applicable).

ATAME is also not responsible for any losses, expenses, damages and costs, including legal fees, resulting from such third-party access.

Retention and Disposal of Personal Information

We will retain Personal Information for as long as is required for us to fulfil the purposes for which the Personal Information was collected, including where applicable to provide a Client with our services and to comply with legal requirements.
If we no longer require Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify the Personal Information.
Personal Information is backed up frequently and tested regularly in line with ATAME’s standard backup procedures. Personal Information that has been deleted may therefore persist within backups for a period of time after which it falls outside the backup rotation.

Access to Personal Information

You can access the Personal Information held about you at any time by contacting our Privacy Officer at info@atame.com.au
We will always endeavour to meet requests for access. However, in some circumstances we may decline a request for access. This includes the following circumstances:

we no longer hold or use the information;
providing access would have an unreasonable impact on the privacy of other persons;
the request is frivolous or vexatious;
the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
providing access would be unlawful;
providing access would be likely to prejudice the detection, prevention, investigation and prosecution of possible unlawful activity; and
the information would reveal our Clients’ commercially sensitive information.

If we decline a request for access, we will provide reasons for our decision when we respond to the request.
We reserve the right to charge you, a reasonable fee for access to your Personal Information. These charges will be limited to the cost of recouping our expenses for providing you with your Personal Information, such as document retrieval, photocopying, labour and delivery.

Changing or deleting Personal Information

We will take reasonable steps to ensure that Personal Information is accurate, complete and up-to-date at the time of collecting the Personal Information from a Client (as applicable), using or disclosing the Personal Information, or during other interactions with that Client.
If you believe that any Personal Information we hold about you is inaccurate, incomplete or out-of-date, you may contact our Privacy Officer at info@atame.com.au. If we have collected your personal information on behalf of a Client, we may request that you contact the Client in the first instance.
We will do our best to correct any Personal Information that is inaccurate, incomplete or out-of-date or dispose of it in accordance with this Policy.

Contact Information and Changes to Privacy Policy

If you have any further queries relating to ATAME’s Privacy Policy, please contact our Privacy Officer at info@atame.com.au. If ATAME becomes aware of any ongoing concerns or problems with your Personal Information, we will take these issues seriously and work to address these concerns.
If you have a complaint in relation to the way your Personal Information has been handled by ATAME, the complaint should be made in writing to our Privacy Officer in the first instance. ATAME will investigate the complaint and prepare a response to you in writing within a reasonable period of time.
Our Privacy Officer can be contacted by: Email: info@atame.com.au
From time to time, our policies will be reviewed and may be revised. ATAME reserves the right to change this Policy at any time.

This Privacy Policy was last updated in August 2017.