(1) About this policy
Loam Bio Pty Ltd ACN 636 407 639 (Loam Bio) is bound by the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APPs) contained in it, which regulate how government agencies collect, use, store and disclose personal information, and how individuals may access and correct personal information held about them.
(2) What is personal information?
The Privacy Act defines personal information as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is:
- true or not; or
- recorded in a material form or not.
What constitutes personal information will depend on whether an individual can be identified or is reasonably identifiable in the particular circumstances. An individual’s name is not required for the information to be personal information. For example, personal information could include:
- photos or videos
- information about an individual’s traits, their opinions or workplace
- combination of a date of birth and post code
(3) What is Sensitive information?
Sensitive information is a subset of personal information with additional requirements under the Privacy Act. Sensitive information might include information about an individual’s health, racial or ethnic origin, political opinions, association memberships, religious beliefs, sexual orientation, criminal history, genetic or biometric information.
(4) Types of personal information collected and held
Loam Bio will, at all times, only collect the personal information needed to perform its legitimate functions and activities. The types of personal and sensitive information we collect about you are set out below:
- Identity Data including name, date of birth, gender, marital status, occupation, education details and images of you
- Contact Data including address phone number, email address and fax
- Background Verification Data including country of birth, passport details, visa details and drivers licence
- Financial Data including payment card details (through our third party payment processors Stripe and PayPal, bank account details, ABN
- Farm Data including data produced by a farmer relating to operations, conditions or characteristics of a particular farm such as production data, soil data, environmental data.
- Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
- Clickstream Data including Internet Protocol (IP) address of our website visitors, date and time of the visit to the website, web pages accessed and documents downloaded, previous site visited, and web browser and operating system used.
- Profile Data including support requests you have made, content you post, send/receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.
- Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
- Professional Data including where you are a worker of ours or applying for a role with us, your professional history such as your work history, referee comments and remuneration
The types of sensitive information we collect about you may include:
- racial or ethnic origin
- membership of trade or professional associations or unions
- criminal record
- health information
Unless otherwise permitted, we will not collect sensitive information about you without first obtaining your consent.
(5) How Loam Bio collects your personal information
Loam Bio collects personal information which you directly provide to us at the time of engagement. For example, when you:
- contact us to make a request in person, by phone or in writing (e.g. via email or electronic forms);
- participate in any Loam Bio activities (e.g. research projects) or events (e.g. registering to participant in farmer events);
- enter into agreements with Loam Bio;
- attend a meeting or webinar run by Loam Bio;
- sign up to receive newsletters and updates;
- submit online enquiry forms, respond to our Grower Interest Survey, or utilise the online data collection forms for carbon project registration;
- apply for a job vacancy at Loam Bio and complete employment documentation.
From other entities or persons
Loam Bio may also collect personal information through other individuals or organisations acting on its behalf, including its contracted service providers as well as financial institutions and government agencies. If this occurs, such collection will be in accordance with the APPs.
Unsolicited personal information
On occasion, individuals or organisations may provide personal information to Loam Bio without it being requested. In such circumstances, we will determine whether or not we could have collected that information because it is reasonably necessary for, or directly related to, one or more of our functions or activities. If this is the case, the information may be used and handled in accordance with this policy. If not, the information collected will be destroyed or de-identified provided it is not in a Commonwealth record and it is lawful and reasonable to do so.
Automatically via website or online services
Loam Bio automatically collects a variety of information when you use our website and online services, some of which may be personal information, such as Clickstream Data.
Our website also uses Google Analytics, a web analytics service provided by Google Incorporated (Google). Reports from GoogleAnalytics are used to help improve our website.
Google Analytics uses ‘cookies’ to analyse how users use our site and this information will be transmitted to, and stored by, Google on servers in the United States of America. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for us and providing other services relating to website activity and internet usage.
Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
Consequences if personal information is not collected
If you do not, or are unable to, provide us with the requested personal information, we may not be able to provide you with the Services or with information, goods or services which you have requested or allow you to participate in Loam Bio’s programs, research projects or events.
(6) Use and disclosure of your personal information
Use of personal information
Loam Bio collects, uses and discloses personal information for the purpose of performing its legitimate business functions and activities.
Unless an exception applies, we will only use or disclose personal information for the primary purpose it was collected. This purpose will be made clear at the time of collection, or as soon as practicable after collection. We will only use or disclose personal information for another secondary purpose if permitted under the APPs.
The main purposes for which we collect, use and disclose personal information include:
- to provide our Services to you, including:
i. co-ordinating and/or funding research activities;
ii. disseminating, commercialising and facilitating dissemination, commercialisation and adoption of results of R&D activities;
iii. monitoring and evaluating our activities and reporting to the Loam Bio Board of Directors and investors;
iv. assessing applications and managing contracts, service providers and funding;
v. assessing eligibility of farm business to participate in Loam Bio’s Carbon Projects;
vi. managing carbon projects on behalf of businesses;
- dealing with correspondence and enquiries and providing support to stakeholders;
- investigating complaints (including privacy complaints);
- to assess whether we can work with you, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you;
- to contact and communicate with you about any enquiries you make with us via our website;
- performing our internal business functions including internal record-keeping, administrative, invoicing and billing purposes;
- for analytics, market research and business development, including to operate and improve our Services and associated applications;
- for advertising and marketing, including sending communications about our upcoming activities and events that we consider may be of interest to you;
- to run promotions, competitions and/or offer additional benefits to you; and
- assessing job applications and managing the employment of staff, consultants and contractors.
Use of sensitive information
If Loam Bio only collect, hold, use and disclose sensitive information for the following purpose:
- for the primary purpose that it was collecting, including to provide the Services;
- secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you;
- to contact emergency services to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent;
- any purposes you consent to i.e. if consent has been given for such use and disclosure (provision of that information is taken as consent); and
- if otherwise required or authorised by law.
Disclosure of personal information
Loam Bio may disclose personal information to:
- third party service providers such as IT service providers, data storage, web-hosting and server providers such as FarmLab, CiboLabs, Webflow, WordPress, and Humaan
- marketing or advertising providers such as Salesforce and MailChimp;
- payment system operators such as Stripe and PayPal;
- sponsors or promoters of any promotions or competitions we run;
- our employees, contractors, agents and/or related entities in order to carry out its functions and activities or operates its business;
- our existing or potential agents or business partners;
- professional advisors, bankers, auditors, our insurers and insurance brokers;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be transferred;
- report to the Commonwealth and comply with its legislative obligations;
- a third party where you have consented to the disclosure or it is required or permitted by law (e.g. if disclosure is necessary to prevent or lessen a serious and imminent threat to the life, health or safety and it is unreasonable or impracticable to obtain consent);
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Meta Pixel or other relevant analytics businesses; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
(7) Overseas Disclosure
While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia, including the United States of America, Canada and Brazil. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.
(8) Your rights and controlling your personal information
Information from third parties
Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe
To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
(9) Storing and securing personal information
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure, including by:
- safeguarding our IT systems against unauthorised access and securing paper files;
- only granting access to those with a legitimate right to access the information by restricting access to electronic and hard copy storage;
- including privacy clauses in all legal documents and agreements to ensure third parties Loam Bio deals with are contractually required to handle personal information in accordance with the APPs; and
- deleting or destroying personal information that is no longer required in a secure manner, unless we are required to maintain it because of a law (such as the Archives Act 1983 (Cth)), or court or tribunal order.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
(10) How to access and seek correction of personal information
Individuals may request access to their personal information and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. Requests for access to, or correction of, personal information should be directed to our Privacy Officer via the contact details below. We will process your request within 30 calendar days, unless we consider there is a reason under the Privacy Act or other relevant law to withhold the information, or not make the changes. If we deny your request, it will provide reasons for doing so.
An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
We take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. Loam Bio should be promptly notified if there are any changes to an individual’s personal information by:
- in the case of employees, advising Finance or Human Resources Department using the ‘change of details’ form; and
- in all other cases, contacting our Privacy Officer via the contact details below.
(11) How to make a complaint
You can make a complaint if you believe we have breached the APPs or mishandled your personal information. Complaints should be directed to our Privacy Officer via the contact details below.
Our Privacy Officer will investigate all privacy complaints. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. Each complaint will be reviewed on a case-by-case basis to determine the steps we need to take to resolve it. We will contact you if we require more information and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns and you also have the right to contact the Office of the Australian Information Commissioner.
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(13) Links to other websites
(15) Contact Details
For any privacy related correspondence, please contact our Privacy Officer via:
Loam Bio Pty Ltd ACN 636 407 639
Building 1120, 346 Leeds Parade, Orange NSW 2800
Ph: +61 2 5317 7047
E: [email protected]