Unlocked Solutions Pty Ltd (trading as CyberUnlocked) is committed to managing Personal Information and the Privacy Policy outlines CyberUnlocked’s ongoing obligations to clients, prospective clients, investors, employees, prospective employees, consultants, contractors, and other individuals in respect of how we manage Personal Information.

CyberUnlocked have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern how we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

1. What is Personal Information?

1. The Privacy Act defines Personal Information as information or opinions that could identify an individual or an individual who is reasonably identifiable.

2. Examples of Personal Information collected include names, addresses, email addresses, phone numbers, employee records, sensitive information, and credit information.

3. If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as Personal Information and will not be subject to this Privacy Policy.

2. What is Sensitive Information?

1. Sensitive information is defined in the Privacy Act to include information or opinions that have a higher level of privacy protection than other Personal Information.

2. Examples of Sensitive Information are an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.

3. Sensitive Information is used by CyberUnlocked only:

a) For the primary purpose for which it was obtained.

b) For a secondary purpose that is directly related to the primary purpose.

c) With your consent, or where required or authorised by law.

3. Disclosure of Government Identifiers

1.   Government related identifiers (including tax file numbers) are defined in the Privacy Act to cover a number, letter, symbol, or a combination of these, that has been assigned by certain government entities and is used to identify an individual or to verify the identity of an individual.

2.   CyberUnlocked complies with laws relating to the collection, storage, use and disclosure of government related identifiers.

3.   CyberUnlocked may collect and hold government related identifiers, such as your tax file number. CyberUnlocked will not disclose any government related identifiers other than as required or permitted by law.

4. What Information Does CyberUnlocked Collect About You?

4.1. Clients, Prospective Clients, and Investors

1. When you enquire about CyberUnlocked’s services or when you become a client of CyberUnlocked, a record is made that includes your Personal Information.

2. The type of Personal Information that CyberUnlocked collects will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

a) Name, e-mail, address and other contact details.

b) Information about employment, profession or an organisation represented.

c) Financial information related to the service.

d) Any additional Personal Information provided to us as part of your interaction with CyberUnlocked.

4.2. Prospective Employees or Applicants

1. CyberUnlocked collects Personal Information when recruiting personnel, such as your name, contact details, qualifications, and employment history. Generally, we will collect this information directly from you.

2. CyberUnlocked may also collect Personal Information from third parties (for example, from recruitment agencies or nominated referees). Before offering a position, CyberUnlocked may collect additional details such as your tax file number, superannuation information and other information necessary to conduct background checks to determine your suitability for the position.

4.3. Other Individuals

1. CyberUnlocked may collect Personal Information about other individuals who are not clients of CyberUnlocked. This includes members of the public who participate in events we are involved with, service providers and contractors to CyberUnlocked, and other individuals who interact with CyberUnlocked on a commercial basis. The kinds of Personal Information we collect will depend on the capacity in which you are dealing with CyberUnlocked.

2. If you are participating in an event CyberUnlocked are managing or delivering, we may take images or audio-visual recordings that identify you.

3. In limited circumstances, CyberUnlocked may collect information that is considered Sensitive Information. 

5. How Does CyberUnlocked Collect Personal Information?

Where reasonable and practical to do so CyberUnlocked collects Personal Information directly from you during interactions, events, and other activities. However, in some circumstances, we may be provided with information by third parties or through publicly available sources. In such a case CyberUnlocked will take reasonable steps to ensure that you are made aware of the information provided to CyberUnlocked by the third party.

You can decline to give CyberUnlocked any Personal Information we request, but that may mean we cannot provide you with some or all the requested services. If you have any concerns about the Personal Information we have requested, please let us know.

6. How Does CyberUnlocked Use Personal Information?

CyberUnlocked uses Personal Information for many purposes in connection with its activities and providing information or a service to you. This may include administrative and marketing purposes.

7. What Personal Information Does CyberUnlocked Disclose?

CyberUnlocked may disclose Personal Information in accordance with this policy in circumstances where you would reasonably expect us to disclose your information, such as:

1. Third parties where you consent to the use or disclosure; or

2. Third parties CyberUnlocked engages to provide services, including contractors, consultants and service providers (for example, IT or marketing); or

3. Where required or authorised by law.

8. How Long Will CyberUnlocked Retain Your Personal Information?

CyberUnlocked will not keep your Personal Information for longer than needed for business purposes or purposes for which it was originally collected.

In most cases, this means that CyberUnlocked will only retain your Personal Information for the duration of your relationship with CyberUnlocked unless we are required to retain your Personal Information to comply with applicable laws.

CyberUnlocked takes all reasonable steps to destroy or erase from its systems all Personal Information data that it no longer requires, this includes requiring any third parties to delete that data where applicable.

9. Does My Personal Information Leave Australia?

We may use third party service providers that are based in or have servers located outside of Australia.

Where we disclose your Personal Information to overseas third parties CyberUnlocked will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. CyberUnlocked will only disclose to overseas third parties if:

1.   You have authorised us to make such disclosure; or

2.   Such disclosure is required for us to provide our services; or

3.   The disclosure is required or authorised by an Australian law or court/tribunal order.

10. How does CyberUnlocked Protect your Personal Information?

CyberUnlocked takes reasonable steps to ensure that the Personal Information that we hold about you is kept confidential and secure, including by: 

1. Having robust physical security of our premises; and 

2. Taking measures to restrict access to only personnel who need the Personal Information to effectively provide services to you; and

3. Having strong cyber security measures in place.

11. How Does CyberUnlocked Maintain Your Personal Information?

It is important to CyberUnlocked that Personal Information is accurate, complete and up to date. If you find that the information CyberUnlocked has is not up to date or is inaccurate, please advise and we will update our records.

12. Policy Updates

This Policy may change from time to time and is available on our website https://www.cyberunlocked.com/.

13. Privacy Policy Complaints and Enquiries

If you have any questions or concerns about our Privacy Policy or CyberUnlocked’s handling of your Personal Information, you can contact us for assistance:

• Email: info@cyberunlocked.com
• Phone: 1300 901 835

If you are not satisfied with CyberUnlocked’s response to a complaint, you have the right to contact the Office of the Australian Information Commissioner (at www.oaic.gov.au) to lodge a complaint.