PURPOSE
To be published on websites to define visitors data protection rights. When published, only the Policy section should be made available to the public

SCOPE
Visitors to Kingspan Insulation Australia’s Websites

POLICY
Kingspan Insulation Pty Ltd. (the “Company”, “we”, “us” or “our”) collects and processes personal information relating to you in connection with its business dealing with you. We do this in compliance with our obligations under applicable data protection law. This notice explains what personal data relating to you is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how you can exercise your rights in relation to your personal data.

Personal Data Collected
The types of personal data relating to you that we collect and process will depend on the nature of your interaction with us, but may include the following types of information:

• – your name and contact details, including your address, email address and telephone number
• – your credit card details

How We Collect Your Personal Data
Kingspan collects personal data from you directly, if you choose to provide it through one of the following means:

• – when you complete any of our application forms (whether online or not) for the purpose of entering into a contract with us;
• – when you contact us to discuss or inquire about the goods or services we provide to you;
• – when you complete a survey or questionnaire; and
• – cookies when you access and use our website.

Please note that some of the information we require (including information requested in our application forms) is necessary in order for us to provide goods and services to you and, if you do not provide us with these required details, then we may decide not to enter into a contract with you.

Purposes of Processing and Legal Bases
Kingspan uses the personal information (which is not sensitive information) it collects from you for the purposes for which it was provided to Kingspan and for related secondary purposes, to carry out Kingspan’s business purposes, to fulfil its legal obligations, other related purposes or as permitted or required by law.
In particular your personal data may be used for the purposes of:

• – Provisions of services and/or goods
• – Quality assurance purposes regarding delivery of services.

The legal bases on which we collect and process your personal data in the manner described above are:

• – your consent;
• – that it is necessary for the performance of our contract with you;
• – that it is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests, rights and freedoms. The legitimate interests for which we process your personal data including:
  • –  Provisions of services and/or goods
  • –  Quality assurance purposes regarding delivery of services;
• – to comply with our legal and regulatory obligations; and
• – insert any other legal basis on which information is collected, processed and transferred.

Recipients of Data
We may disclose your personal data to third party recipients in connection with the above purposes, including:

• – to credit reference agencies in order to carry out money laundering and identify checks and to comply with legal obligations;
• – to third parties who we engage to provide services to us, such as IT service providers, professional advisers, auditors and outsourced service providers;
• – to other members of our corporate group;
• – to competent regulatory authorities and bodies as requested or required by law; and

Retention
We will only retain your personal data for as long as is necessary to fulfil the purpose for which it was collected or until you tell us that you no longer wish for us to retain such data and otherwise to the extent permitted by applicable law.

We will take reasonable steps to destroy or permanently de-identify personal data we hold if it is no longer needed for Kingspan’s business purposes and it is permissible by law to do so. If requested or authorised to do so, we may shorten the retention period.

We may also retain and use your personal data to fulfil our legal obligations, resolve disputes, enforce any agreements to which we are a party, and protect the legal rights and legitimate interests of others and ourselves

Transfers Abroad
Some of Kingspan’s related entities, or third party service providers to whom we may disclose your personal data, may be located in countries and regions outside Australia or may hold your data on servers located outside of Australia, including in the UK, Ireland and Europe. We will endeavour to take reasonable steps to ensure that these parties handle such information in a manner that is consistent with the Australian Privacy Principles and this privacy policy.

Kingspan reserves the right to disclose any personal data (including sensitive information) to law enforcement or other government officials where we reasonably believe that this may be necessary or appropriate, or where it will prevent or lessen a serious and imminent threat to somebody’s safety, life or health.

To the extent we hold your personal data in the European Economic Area, we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. 

Your Rights
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

• – the right to access your personal data. You may request access to personal data that Kingspan holds about you in writing by using the contact details below. Kingspan will process such requests within a reasonable time and may charge a fee for providing access, which will            cover the costs of verifying the application and retrieving the information requested. If Kingspan denies an access request, it will provide reasons for doing so;
• – the right to request the rectification of your personal data. Kingspan will take reasonable steps to ensure that any personal data we hold about you is accurate, complete and up to date. If there are any changes to your personal data, please let us know using the contact details        below. If you request us to, we will take reasonable steps to correct the personal data we hold about you so that it is accurate, complete and up to date, or will provide reasons for not doing so;
• – the right to request erasure of your personal data;
• – the right to restrict the use of your personal data;
• – the right to object to the processing of your personal data;
• – the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller;1 and
• – where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.2

In order to exercise any of the rights set out above, you can contact us at [ • ]3.

Questions, Comments and Complaints
If you have any questions or feedback about this policy or wish to make a complaint about a breach of this policy, or the Australian Privacy Principles, you can contact Kingspan using the following contact details:

Address: 25 Oherns Rd, Somerton VIC 3062
Attention: Privacy Officer
Email: info@kingspaninsulation.com.au

You will need to provide sufficient details for any complaint, as well as any supporting evidence and information.

Your complaint will be reviewed by our Privacy Officer, who will investigate the issue and determine the steps that Kingspan will take to resolve your complaint. Kingspan will contact you if it requires any further information from you and will notify you in writing of the outcome of the investigation.

If you are not satisfied with Kingspan’s determination, you can contact Kingspan to discuss your concerns or contact the Australian Privacy Commissioner through its website at www.oaic.gov.au

VARIATIONS: KIAU reserves the right to vary, replace or terminate this policy from time to time.