Website, customer service calls, customers, suppliers and third parties | Version 2.2

1.  About this policy

Hako Australia Pty Ltd (ABN 43 002 858 059) (“Hako”, “we”, “us” or “our”) is committed to protecting the privacy of the people we deal with. We are the Australian subsidiary of Hako GmbH, Germany and a distributor of cleaning equipment, parts and related services. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), and we handle personal information in accordance with them.

This policy explains what personal information we collect, how we collect, hold, use and disclose it, how we keep it secure, and how you can access or correct it or make a complaint. It is published on our website and is the privacy policy referred to in the recorded announcement you hear when you call our customer service centre.

Who this policy applies to

This policy covers the personal information we handle about:

  • visitors to and users of our website;
  • customers and prospective customers, and their staff and representatives;
  • people who call, or are called by, our customer service centre (see section 5);
  • suppliers, business partners, contractors and other third parties, and their staff and representatives;
  • job applicants; and
  • our employees and other workers (see section 15).
2.  What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form. Sensitive information is a special category of personal information and includes health information and information about a person’s racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record and biometric information. We only collect sensitive information where it is reasonably necessary for our functions and, generally, with your consent or where otherwise permitted by law.

3.  The kinds of personal information we collect

Depending on how you deal with us, the personal information we collect may include:

  • Website users — name, email address, phone number, company and the content of messages you submit through our website forms; account log-in details; and technical information collected automatically (see section 8).
  • Customers and prospective customers — name and contact details, delivery and site details, billing details, ABN, order, rental and service history, machine and site information, and payment details.
  • Callers to our customer service centre — audio recordings of the call, your telephone number, and the information you provide during the call (see section 5).
  • Suppliers, contractors and other third parties — contact details, ABN and bank/remittance details of the individuals we deal with.
  • Job applicants — the information in your application and résumé, references, and the results of pre-employment and background checks.
  • Employees and workers — as described in our internal privacy policy (see section 15).

We aim to collect only what we reasonably need. Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym (for example, a general product enquiry), although we usually need your details to supply goods or services.

4.  How we collect personal information

We collect personal information in a number of ways, including:

  • directly from you: over the phone, by email, through our website, in person, or in the course of supplying goods and services;
  • automatically: when you use our website (see section 8); and
  • from third parties: such as credit-reporting bodies and trade referees (for credit account applications), your employer or the person who refers you to us, freight and logistics providers, and publicly available sources.

If you give us personal information about another person, please make sure they are aware of this policy.

5.  Recording of customer service calls

We record inbound and outbound telephone calls handled by our customer service centre. When you call us, an automated message tells you that your call may be recorded before the conversation begins. When we call you, our team member will tell you at the start of the call that the call may be recorded.

Why we record calls

We record calls to:

  • confirm and accurately process orders, service requests and instructions;
  • maintain service quality and train and support our staff;
  • resolve disputes and handle complaints and warranty matters;
  • help detect and prevent fraud and protect account security; and
  • keep accurate business records and meet our legal and regulatory obligations.

Your choice

By continuing with the call after the recorded announcement (for inbound calls) or after our team member tells you the call may be recorded (for outbound calls), you consent to the call being recorded for these purposes. If you would prefer not to be recorded, please let our team member know; you do not have to give a reason. Where it is practicable to do so, we will continue the call without recording it. Otherwise, we will assist you through an alternative channel, such as email at cs@hako.com.au or in writing.

What is recorded, and payment information

A recording may capture the information you discuss with us during the call. Please do not read out full payment card details during a call unless asked to do so; where possible we take card payments through a secure facility and take steps to avoid retaining full card data in recordings. The recording is paused during card capture.

How we handle recordings

Call recordings are personal information and are protected under this policy. They are stored securely; access is limited to authorised personnel and service providers who need it for the purposes above; and they are retained for 1 month and then securely destroyed or de-identified, unless we are required to keep them longer (for example, for a dispute or a legal obligation). We disclose recordings only as described in section 9.

Compliance

We handle call recordings in accordance with the Privacy Act and the APPs, and we comply with the applicable Commonwealth and State/Territory laws governing the recording of telephone conversations.

6.  How we use personal information

We use personal information for the purpose for which it was collected and for related purposes you would reasonably expect, including to:

  • respond to enquiries and provide quotes, products, rentals, parts and services;
  • set up and manage customer and supplier accounts, process orders and payments, and arrange delivery and service;
  • manage our relationship with you and provide customer support;
  • administer our business, including record-keeping, accounting, risk management and IT;
  • improve our products, services and website;
  • send you service and transactional communications;
  • send you marketing where permitted (see section 7); and
  • comply with our legal obligations and respond to lawful requests.
7.  Direct marketing

We may use your contact details to send you information about our products, services, promotions and events by email, phone or post, where we are permitted to do so. Every marketing email includes an unsubscribe option, and you can opt out at any time by contacting us using the details in section 18. We do not sell personal information. If you ask us to stop sending you marketing, we will action your request within a reasonable time.

8.  Cookies and website analytics

When you visit www.hako.com.au, we and our service providers may automatically collect technical information such as your browser type, version and language, operating system, the pages you view, page access times, and the referring website address. We use cookies and similar technologies for this purpose, to help the site function, and to improve the user experience. We may use third-party analytics tools (such as Google Analytics) that set their own cookies. You can control or disable cookies through your browser settings, although some features of the site may not work properly as a result.

9.  How we disclose personal information

We may disclose personal information to:

  • our service providers — including IT, cloud-hosting and telephony/call-recording providers; freight and logistics providers; payment processors; and marketing and customer-support providers;
  • our professional advisers — such as accountants, lawyers, auditors and insurers;
  • other companies in the Hako Group, including our parent company in Germany, for group support and reporting;
  • government agencies, regulators and other parties, where required or authorised by law; and
  • a buyer or successor in the event of a sale or reorganisation of our business.

We take reasonable steps to ensure our service providers are bound by appropriate confidentiality and privacy obligations. We do not sell personal information.

10.  Disclosure outside Australia

Some of our systems and service providers, and other Hako Group companies, are located overseas — including in Germany (Hako Group) and in the countries where our cloud and IT providers operate. Where we disclose personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs.

11.  Security and data breaches

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, including physical, technical and organisational measures, access controls and staff obligations. No method of transmission or storage is completely secure. If a data breach occurs that is likely to result in serious harm, we will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.

12.  Retention and destruction

We keep personal information only for as long as we need it for the purposes in this policy or as required by law, after which we take reasonable steps to destroy it or permanently de-identify it. Retention periods vary by record type (for example, call recordings 1 month; financial and tax records for the period required by law).

13.  Accessing and correcting your personal information

You may ask us for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Please contact our Privacy Officer using the details in section 18. We may need to verify your identity. For access requests, we may charge a reasonable fee to cover our costs (we do not charge to make a correction). We will respond within a reasonable time, usually within 30 days. If we refuse access or correction, we will tell you why and how you can complain.

14.  Anonymity and pseudonymity

Where it is lawful and practicable, you have the option of dealing with us without identifying yourself, or by using a pseudonym — for example, when making a general enquiry. In many cases, however, we will need your details to respond to you or to provide the goods or services you have requested.

15.  Employees and job applicants

Job applicants are covered by this policy. For our employees and other workers, personal information that is directly related to a current or former employment relationship (an “employee record”) is generally exempt from the APPs under the Privacy Act; our handling of that information is governed by our internal Hako Australia privacy policy, available through the employee handbook and intranet. We remain committed to handling employee information carefully and in line with our legal obligations.

16.  Suppliers, contractors and other third parties

This policy also covers personal information about the individuals we deal with at our suppliers, contractors, business partners and other third parties, such as their contact and remittance details. We use this information to manage those relationships, procure goods and services, make and receive payments, and meet our obligations, and we protect it in the same way as other personal information we hold.

17.  Making a privacy complaint

If you have a concern or complaint about how we have handled your personal information, please contact our Privacy Officer using the details in section 18. We will acknowledge your complaint and aim to respond within 30 days. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC): website www.oaic.gov.au; phone 1300 363 992.

18.  Contact us

For any privacy question, access or correction request, or complaint, please contact:

Privacy Officer
Hako Australia Pty Ltd
Phone: 1800 257 221
Email: cs@hako.com.au