Australian Privacy Policy

Colin Solutions Pty Ltd and its related bodies corporate (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.

This policy does not apply in respect of any acts or practices that are exempt from application of the Australian Privacy Principles (APPs) or acts or practices that are otherwise not required by the Act.

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold?

We may collect the following types of personal information:

Job Applicants:

We may collect information in relation to your job application that may include:

• Your contact and personal details, residential status, relevant accomplishments and work history, resume and references. This may include your passport, visa and relevant employment contract details

• Digital footprints (e.g. physical and logical access logs, website related logs, CCTV footage)

• Information required for background checks

Employees:

We may collect information in relation to your employment that may include:

• Contact details, emergency contacts, health, personal particulars including biometrics and information required for background checks

• Information that relates to your work performance

• Information about how we pay you and what benefits you receive

• Information required for processing payroll, tax and claims

• IT usage including internet and email monitoring and CCTV footage and monitoring, internal social networking information, usage of blackberry and other IT services

• HR information, residential status, travel and immigration information, personal preferences and service transactions

Prospects and Customers:

We may collect information that includes:

• Contact details, personal identification details, personal preferences

• Digital footprints including physical and logical access logs, website related logs, CCTV footage, website preferences

• Information provided through social networking sites like Facebook, LinkedIn or Twitter

• Details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;

• Any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and

• Information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.

Interns:

We may collect information in relation to your application for internship that may include:

• First Name as in Passport, Last Name as in Passport, Email Address, Mobile Number, Permanent Work Authorization, Geo Region, University Name, Current Academic Level, Current Academic Year, Overall CGPA, Academic Concentration, Expected Graduation, Key Skills, Area of Interest, Project Preference, When you can intern with us, Resume (uploaded)

• Alternate Email Address, Additional Phone Number, Cover Letter (uploaded)

In case you are selected, we may collect information in relation to creation of your ID card that may include:

• First Name, Last Name, Intern number, Photograph, Manager email address, Start date/last date of your internship, ID Card number, Emergency contact number (i.e. contact number of local HR person/ intern team person)

Visitors to Colin Solutions Office:

We may collect information in relation to you visit to our physical premises for security purposes that may include:

• First Name, Last Name, E-mail Id, Company /Organization details, Username and Internet usage logs (URL accessed, browsing time, time of access, IP address), signature.

• Colin Solutions representative to be met.

• Date, entry time, exit time.

• Other physical access records include logs and CCTV footage.

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

Participants of Ideathons and Other Competitions

We may collect information in relation to your participation in ideathons and other competitions:

• First name, Last name, Email ID, Phone number, country, name of University, your field of academic study/concentration, expected year and month of your graduation

How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in ways including:

• through your access and use of our website or through social media such as LinkedIn;

• through hard copy forms

• through electronic copy forms

• through our intranet systems

• during conversations between you and our representatives; or when you complete an application or purchase order.

• from third party companies such as credit reporting agencies, law enforcement agencies and other government entities.

• exchange of business cards

Cookies

In some cases we may also collect your personal information through the use of cookies. When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

How do we hold your personal information?

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form.

Appropriate security measures are taken against unlawful or unauthorized processing of personal information, and against the accidental loss of, or damage to, personal information. To this end, your personal information may be held in any of the following: restricted areas where only authorized personnel are permitted access; in physical files and folders that are held in secure lockable desks and cabinets; electronically, on our internal computer systems (subject to restrictions on access such as password protections and accessibility controls).

Personal information is securely destroyed or de-identified when no longer needed.

For what purposes do we collect, hold, use and disclose your personal information?

We collect, hold, use and disclose your personal information for the following purposes (as the context requires):

Job applicants, Employees, Prospects and Customers:

• to manage the job application process and/or to maintain our relationship with you;

• to update our records and keep your contact details up to date;

• for our internal business processing, administrative, marketing and planning requirements;

• to ensure security

• for social networking

• for payroll, tax and claims processing

• for other purposes that are permitted under any agreement with you or made apparent to you at the time of collection;

• to answer enquiries and provide information or advice about our products or services;

• for lead generation and event follow up and providing client hospitality;

• to provide products and services to you and to send communications requested by you;

• to answer enquiries and provide information or advice about existing and new products or services;

• to provide you with access to protected areas of our website; and

• to assess the performance of the website and to improve the operation of the website.

Analysts, Advisors, Journalists and other Influencers:

• To select suitable influencers to brief on Colin Solutions perspectives and news;

• To provide Colin Solutions spokespeople background on what the influencer will be interested to hear about.

Interns:

• For contacting and updating you regarding the internship related correspondences

• For shortlisting you based on your credentials, skills and work authorisation

• For allocating projects to you based on your preferences and availability at the Colin Solutions hub selected by you

• For conducting your background verification subject to applicable law

• For extending the compensation letter to you

• For creating and issuance of your ID card

• For enabling your physical access to office premises and recording your attendance

• For activation/de-activation of your ID card

Visitors to Colin Solutions Offices:

• For registering and providing internet access via Wi-Fi.

• To monitor your usage of internet for security purposes.

• To issue Visitor Passes or Photo IDs or HID/Security Cards as appropriate.

• For authorization and authentication of physical access.

Participants of Ideathons and Other Competitions

• To know your interest of participation in ideathons or other competitions

• To contact you in furtherance to your participation in the ideathons or other competitions

• As a participant of the competition, to publish your name and corresponding details to make them available to larger audience on the Internet

Other purposes which may be applicable to all the above categories of individuals:

• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;

• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of Colin Solutions, its related bodies corporate, contractors or service providers;

• to provide your updated personal information to our related bodies corporate, contractors or service providers;

• to process and respond to any complaint made by you; and

• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

To whom may we disclose your information?

We may disclose your personal information to:

• our employees, related bodies corporate, contractors or service providers for the purposes of operating our business, fulfilling requests by you or providing products and services to you;

• suppliers and third parties with whom we have commercial relationships, for business, marketing and related purposes; and

• other organisations for authorised purpose that we have agreed with you separately.

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).

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.

We do not provide your personal information to other organisations for the purposes of direct marketing.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

How does Colin Solutions deal with anonymous users and user that use pseudonyms?

We may not be able to deal with you, your enquiry, or any other interaction you may wish to have with us if you do not provide information that does not identify you or your organization.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.

Our procedure for investigating and dealing with privacy breaches is to ascertain all relevant facts and correspond with those involved (including where relevant our clients), reach a view as to the existence, scope and cause of the issue, and where relevant and appropriate, implement corrective or rectification measures.

Do we disclose your personal information to anyone outside Australia?

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 but not limited to the following:

• our related bodies corporate, located in Australia, India, New Zealand, United States, European Economic Area, Switzerland, Hong Kong, Singapore, Japan and UK;

• our data hosting and other IT service providers, located in Australia, India, European Economic Area, Canada, United States, Singapore, Hong Kong and UK; and

• other third parties located in Australia, United States and UK.

Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Contacting us

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.