Securities Industry Research Centre of Asia-Pacific (SIRCA) Ltd & RoZetta Technology (“SIRCA” “RoZetta”, “we”, “us”, “our”) provide big data solutions to its clients.  SIRCA owns and operates the website, www.sirca.org.au which serves research organisations and RoZetta owns and operates the website www.RoZettatech.com (together the “Website”) which provides big data solutions to commercial clients. Aside from the Website, RoZetta also owns and operates the software “AlphaShapes” (an application provided to customers as a web service as well as an application hosted on Thomson Reuters Eikon App Studio).

We recognise that protecting Your personal information is critical to the success of our engagement with You. We are dedicated to protecting Your Privacy in accordance with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (the APPs).  This Privacy Policy sets out how we manage the personal information we collect, hold, use and disclose about You when You access our products and/or use our Website.


 

Acceptance

By submitting Your personal information to us and/or by accessing or using the Website or our products and services, You confirm Your acceptance of the terms of this Privacy Policy and consent to the handling of Your personal and sensitive information as described in this Privacy Policy.  If You do not agree with the terms of this Privacy Policy, please do not use the Website or otherwise provide us with Your personal information.

This Privacy Policy will answer Your questions about:
  • Why we collect, hold and use personal information;
  • The types of personal information about You that we collect and hold;
  • How we collect and hold personal information;
  • When we disclose personal information including when we disclose it overseas;
  • How and when You can ask to see it or have it corrected;
  • What You need to do if You have a complaint about the way we have collected, used, held or disclosed Your personal information.


Why we collect hold use or disclose Your personal information

This Policy applies generally to our customers, suppliers and business partners.

Customers

It should be fairly clear as to why we would ask You for personal information. For example, we may need to collect Your postal address to be able to send You an invoice or establish the tax jurisdiction or we may ask You for Your name and other personally identifiable information so that we are able to reset Your password at Your request.  In summary, we need to collect and use personally identifiable information so that:

  • We can manage Your account with us;
  • We can ensure that You are the rightful owner of the account;
  • We can ensure that You are provided with the service or product that You have ordered;
  • We can ensure that our service meets Your needs and preferences & help to improve them;
  • We can provide You information about other products and services that may be of interest to You.

You are under no obligation to provide us with Your information and You may be able to visit our Website and deal with us anonymously or by pseudonym.  However, if You choose not to provide us with certain information, we may not be able to provide You with the full services that You seek.

Suppliers & business partners

We may use the personal information provided by suppliers and business partners to manage our accounts with those organisations, including improving our business relationship with those organisations. 

It should be clear to the Supplier, organisation, business partners and their personnel, as to why we collect the personally identifiable information.  For example, if we organise corporate events, we may need to know their name, meal preferences, including that of their partners, if they are invited.  This will be to ensure that we are able to provide corporate hospitality that meets Your expectations.

Direct marketing

We may use Your personal information for the purposes of direct marketing if You gave us that information directly, it is reasonable to expect that You would receive this type of information from us and You have not already asked us to stop.

Collection of information from third parties

We may collect the personal information about You from third parties. We are not responsible for the Privacy practices and procedures of third parties who may have otherwise collected and/or provided Your information to us.   We strongly encourage You to read the Privacy policies of, or contact these third parties directly for further information about their Privacy practices.

We will ensure that in our direct marketing communications, You can tell us to stop sending You marketing communications and we will make it easy for You to tell us to stop.

If You provide us with Your home, mobile telephone number or Your email address, You agree that we can contact You by calling You or using email, SMS or MMS on that number or via that email address until such time as You to tell us to stop.

At any time, You can tell us to stop sending You information about our products and services by contacting us via Privacy@RoZettatech.com and we will stop.

If we receive unsolicited personal information about You from a third party and it is clear to us that we should not have collected that information (as long as it is lawful and reasonable) we will destroy or securely delete that information.

 

The types of personal information that we collect & hold

The type of personal information we may collect and hold depends upon the nature of our interactions with You. In most cases it should be clear as to why we collect that information and the type of information needed to satisfy that need: 

Examples of type of personal information we may collect
Why we may collect

Name, address, telephone no, email address

To address or communicate with you or identify you

Credit card details, banks account numbers

So that we can receive payment or make payment

Tax file no

So that we can deduct the correct amount of tax or provide you a benefit that you are entitled to

Date of birth, passport information, driver licence details

To be able to conduct a credit check (with your permission) or to be able to identify you in future

Employment history, association membership

To establish any conflict of interest

 

We will not collect from You any sensitive information revealing Your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability.

Exceptions to this include:

  • Where You have given us express consent and the information is reasonably necessary for us to carry out our functions or activities;
  • The use of this information is required or authorised under Australian law or a court or tribunal order;
  • When the information is necessary for the establishment, exercise or defence of a legal claim.


How we collect & hold Your personal information

In general, our Policy is that we only collect and hold personal information for the purpose that was specifically or reasonably apparent at the time of collection.

Web logging

Everytime You visit our website, we record standard information such as time, date and request URL, Your company, Your ISP’s IP address, referrer URL (ie the web page You arrived from) and information the internet browser You used to visit our website. This information is recorded by web servers and is used to improve the functionality, structure and performance of our web sites. It is also used as an audit trail to ensure security and integrity of our web servers. It also helps us to understand the browser specific fixes that we may need to make to provide You the service

We seek to understand the pattern of visitor usage across the sites by issuing an anonymous user ID via a cookie. A cookie is a small file of letters and numbers that we store on Your browser or the hard drive of Your computer if You agree. Cookies contain information that is transferred to Your computer's hard drive. This user ID is sent back to our servers each time You view a page from our servers.

There are different kinds of cookies that may be used in our website:

  • 'Session' cookies remain in Your browser during Your browser session only, ie until You leave the website;
  • 'Persistent' cookies remain in Your browser after the session (unless deleted by You);
  • 'Performance' cookies collect information about Your use of the website, such as webpages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous. Performance cookies are used to improve how a website works;
  • 'Functionality' cookies allow the website to remember any choices You make about the website (such as changes to text size, customised pages) or enable services such as commenting on a blog.

The use of Cookies, enable us to provide You a good experience by ensuring that the services and content are relevant to Your preferences and browsing behaviour. You can change the settings of Your Internet browser to disable cookies or to warn You when cookies are being used. This may however preclude You from using some services or enhanced functionality.

Third Party Services: We may use services hosted by third parties, such as Google Analytics, to assist in providing our services and to help us understand how our websites are used. These services may collect information sent by a browser as part of a web page request, including IP addresses or cookies. If these third party services collect information, they do so anonymously and in the aggregate to provide information helpful to us such as website trends, without identifying individual visitors.

Please refer to the preceding paragraph for information about how You can control the use of cookies on Your computer.

Cloud based solutions

In some cases, You might provide personal information to us by entering it into our cloud based solutions because You want us to host that information for You or Your information may be disclosed to us by an organisation with whom You interact and to which we provide a cloud based service.

Examples of such services include Thomson Reuters Eikon App Studio, Amazon Web Services, Salesforce, invoicing and payment gateways, recruitment sites. When we collect or hold personal information in this way, it is only used or disclosed for the purpose contemplated by You or the organisation that has disclosed that information to enable us to provide the service sought.

Integrity & security of Your information

Our obligation is to ensure that information about You that we collect, use and disclose is secure, accurate, up-to-date and complete. We employ a number of different strategies to protect personal information. These include, depending on the service and the nature of the personal information held in the relevant system:

  • Secure Sockets Layer and other encryption technologies;
  • Firewalls and Intrusion Detection Systems;
  • Virus protection Back-ups;
  • Regular vulnerability and penetration testing;
  • Restricted access;
  • Security Policies and Staff Training.

Where we have used cloud based services, we rely on the security protocols, policies and controls of those service providers to deliver and utilise services. RoZetta does not accept any liability for failures of those protocols, policies or controls to protect Your information Privacy.

We strive to protect Your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure, however data transmission over the Internet cannot be guaranteed to be 100% secure because risks do change over time.

Where You are required to log in to access one of our products or services, we recommend that You always log out after each session and close the browser when finished; particularly when accessing the product or service from a public terminal. For obvious reasons, please do not send credit card information through unsecured electronic mail or share Your passwords with anyone else.

If we no longer need Your personal information, unless we are required under Australian law or a court or tribunal order to retain it; we will take reasonable steps to destroy, de-identify or securely delete Your personal information.


Disclosure to third parties & overseas

We may engage services of our related entities and affiliates or business partners or third party suppliers, to assist us in providing services to You.  In order for those parties to assist in providing the services, we may disclose Your information to them.

Examples of such services include:

  • Management of databases and operation of our Website;
  • Business support services like website hosting, information storage services, including data hosting;
  • Technical support and development;
  • Distribution of marketing and promotional materials;
  • Security audits and penetration testing;
  • Marketing support and research;
  • Debt collection;
  • Order processing;
  • Payment processing.

In such cases, we will:

  • Provide only such information about You as they need to perform those services;
  • Not permit them to use information about You for any purpose except to perform the services we have specifically asked them to provide;
  • Make it clear how they should handle Your personal information.

We may also be required to provide Your personal information:

  • To government or regulatory bodies and agencies, law enforcement bodies (such as the police), courts of law, if required or authorised to do so by law. For example, in response to a subpoena or legal order, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats or to exercise legal rights or defend against claims such as intellectual property infringement;
  • As otherwise permitted or required by law.

Countries

Sometimes the RoZetta entity or third party provider is located overseas. The territories to which we currently disclose personal information are listed below. This list may change from time to time and we will update this information.

When we disclose personal information outside of Australia, we will take reasonable steps to require the overseas recipient to comply with Australian Privacy Principles unless the recipient is subject to laws that would protect Your information in a substantially similar way to the Australian Privacy Principles. For example, if that country has laws that enable You to take action to enforce Your rights in a similar way.

By providing Your personal information to us, or to the third party with whom we contract, You consent to the transfer of that information to our third party service providers who are located outside of Australia for that purpose.

Such third party service providers may store and process information provided by You on servers located outside of Australia. Countries include Singapore, India, the Philippines, Canada, the United States of America, United Kingdom.

Links to third parties

Some of the pages on our websites may be hosted by third parties. If personal information is collected from one of those pages and provided to us, we will treat that information in accordance with this Privacy Policy as if it was collected directly by us.

Some of our websites contain links to third party web sites that are not operated or controlled by us. Please note that we cannot be responsible for the Privacy or security practices of those third party websites and those sites are not covered by this Privacy Policy. Third party web sites should have their own Privacy and security policies, which we encourage You to read.

Other companies that place advertising on our websites may collect information about You when You view or click on their advertising or content through the use of cookies or web bugs. We cannot control this collection of information. You should contact these advertisers or content providers directly if You have any question about their use of the information they collect.

Access to information we hold about You

If You ask to see the personal information we hold about You in writing, we will respond to Your request as soon as we reasonably can and where feasible we will provide access to the information in the manner You request at no charge unless it involves a lot of work.

You can send requests for information to Privacy Officer, RoZetta Technology Pty Ltd, Level 4, 55 Harrington Street, The Rocks NSW 2000 or email at Privacy@RoZettatech.com.

Sometimes we cannot provide access, for example if:

  • It would pose a serious threat to life, health or safety or unreasonably impact the Privacy of another individual;
  • Your request is not serious or in good faith;
  • Information relates to existing or anticipated legal proceedings between us;
  • Giving access would reveal our intentions in relation to negotiations with You in such a way as to prejudice those negotiations;
  • Denying access is required or authorised under Australian law or a court or tribunal order;
  • Giving access would reveal information generated by us in connection with a commercially sensitive decision making process;
  • Providing access would be unlawful or would be likely to prejudice an enforcement related activity conducted by, or on behalf of, an enforcement body.

If we refuse to provide access because of an exception listed above, or to give You information in the manner You requested, we will take reasonable steps to give access in a way that meets our needs and Your needs, and we will give You written notice setting out the reasons for refusal (unless it is unreasonable to do so) and the mechanisms available to You to complain about the refusal.


Correcting Your details

If You want us to correct information that we hold about You because it is inaccurate or out-of-date; You can send requests for corrections to the Privacy Officer, RoZetta Technology Pty Ltd, Level 5, 55 Harrington Street, The Rocks NSW 2000, or email Privacy@RoZettatech.com.

If we correct personal information that we previously disclosed to other entities, and You request that we notify those entities of the correction, we will take reasonable steps to notify those entities unless it is impracticable or unlawful to do so.

If we refuse to comply with Your request for amendment of Your details, we will give You written notice setting out the reasons for refusal (unless it is unreasonable to do so) and the mechanisms available to You to complain about the refusal.

If You are a registered user of a web based solution, You may be able to edit Your information at any time directly in the service


How can You make a complaint about a breach of Your Privacy?

If we become aware of any ongoing concerns or problems You may have with our handling of Your personal information, we will work to address these concerns in accordance with our procedures for enquiries and complaints. If You have any queries relating to our Privacy Policy, or You have a problem or complaint, including any complaint that we have not complied with the Australian Privacy Principles, please contact us at Privacy@RoZettatech.com.

 

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time by posting an updated version of this Policy on our websites. We recommend that You review it regularly for any changes.

 

Additional Information

For further information about Privacy issues and the protection of Privacy, visit the Office of the Australian Information Commissioner web site at www.oaic.gov.au.