YELLOW LINES APP PRIVACY POLICY Yellow Lines is genuinely committed to working within the Australian Privacy Principles (APPs) guidelines which are governed by the Privacy Act 1988. Yellow Lines ("we" or "the business") is an APP Entity based in Victoria, Australia. Yellow Lines is the parent of the Time Palette brand, and this Policy applies equally to both. This APP Privacy Policy (Policy) will be made freely available on the websites www.yellowlines.com.au and www.timepalette.com.au, or can be requested via email or post by contacting any Yellow Lines staff member. The person responsible for this Policy, and any related inquiry, is Mr Donovan Ferguson, sole Owner and Director of Yellow Lines. Any individual or organisation is welcome to contact (or complain to) Yellow Lines regarding this Policy, and its application as relates to handling of personal information. Inquiries can be directed to email address privacy@yellowlines.com.au or privacy@timepalette.com.au, or posted to PO Box 245 DIAMOND CREEK VIC 3089, or Mr Donovan Ferguson can be contacted on phone number 0409 054 321. In the event an individual or organisation is not satisfied with how Yellow Lines handles an inquiry/complaint, that individual has the option to contact the Office of the Australian Information Commissioner (OAIC). Further information is available www.oaic.gov.au. Yellow Lines is committed to cooperating and working with the OAIC in such circumstances. Yellow Lines will keep a record of changes made to this Policy, so that any person can retrospectively review any change that occurred. Under this Policy, Yellow Lines aims to acknowledge any inquiry/complaint within 72 hours of receipt (inquiries relying solely on postal services may take longer). Depending on the nature of the inquiry, Yellow Lines will aim to provide a reasonable final/full response within 2 weeks (14 days), if not sooner. Yellow Lines does not, and has no interest in, routinely collecting sensitive personal information (SPI). SPI examples include date of birth (age), sex, personal preferences, racial or ethnic origin, religious affiliation, political opinions. In the event that Yellow Lines does collect SPI, such as a Criminal Record History (sometimes a requirement for sub-contractors), the information will remain bound under this Policy, unless otherwise agreed in advance with the individual that the information applies to. Any information collected by Yellow Lines is done so for the sole purpose of selling and/or delivering the professional services and products which are core to our business. The Yellow Lines and Time Palette websites include an inquiry ("Contact Us") page, to allow potential customers to engage with the business. Such inquiries are transmitted to Yellow Lines by our website hosting provider, via email (SMTP). The detail of the inquiry is not stored in any other location (although our website hosting provider may record it in their logs, and/or create a back-up containing the information). While all (outbound) Yellow Lines email is transmitted via SSL encrypted ports, incoming email may not be encrypted, and so senders of inquiries via our website (or by any email) should not include any SPI. Types of personal information that Yellow Lines will collect and store indefinitely, generally via email, will include email address, name, occupation, contact details such as address and phone number. Additionally, information will of course be collected about the professional services and/or products (goods and services) that Yellow Lines seeks to and/or delivers to customers. Such information is routinely required to conduct business in a professional and diligent manner. Where personal information has been collected/collated by Yellow Lines, the subject of such information may request to review and/or correct it at any time. Yellow Lines does not have any Policy to routinely destroy personal information that has been collected, however, ancient communications may be archived and therefore can take longer to retrieve should the subject of such information request to review it. Yellow Lines may choose, at its sole discretion, to irrevocably destroy information relating to individuals where it is no longer deemed necessary to be collected/collated. Doing so will not discharge our commitment/responsibilities under this Policy to prevent any breach of an individual’s privacy. However, if information is deleted, it will be securely irrevocably destroyed, preventing any access to, review, or update of the information by any party (including Yellow Lines). Deletion means gone/non-existent, there is no longer any information. An individual whose information has been collected/collated by Yellow Lines, may request that it be irrevocably destroyed at any time. Depending on the nature of the information, Yellow Lines may choose to retain the records in a de-identified format (as opposed to irrevocably destroying the information). This would allow for audit compliance type activity e.g. engagement with the Australian Taxation Office. There is no circumstance whatsoever where Yellow Lines will share/sell/barter any personal information that has been collected/collated. Any person providing personal information to Yellow Lines in good faith, is assured that the business has no desire or intent to breach their privacy. Similarly, Yellow Lines will not disclose personal information to any overseas recipient, and this Policy applies to how Yellow Lines will operate worldwide. Yellow Lines does not conduct any targeted and/or unsolicited direct marketing via door to door, telephone call, SMS, or email. Any marketing/sales/proposal material exchanged will be in response to a direct request for information on products and services (goods and services). In the event an individual is contacted (at their request), they may also subsequently reply and request no further contact, and without giving any reason. Yellow Lines deeply values all former, current and potential customers, and the business is committed to this Policy, and to the overarching APPs. In the event an individual wishes to engage with Yellow Lines anonymously, the individual should make this clear to Yellow Lines at the earliest opportunity so that we can assist with maintaining this. Yellow Lines will facilitate anonymous engagement via receipt of phone call, with it being the responsibility of the inbound caller to hide/block their phone number if desired. Yellow Lines loves "cloak and dagger" stuff, but it requires cooperation. Alternatively, an individual can create a pseudonym to use within communications, allowing them to remain anonymous whilst still maintaining some continuity of engagement. Yellow Lines will not attempt to identify an individual who chooses to be anonymous, although under these circumstances it may be impractical for Yellow Lines to facilitate any deep engagement. The Yellow Lines www.yellowlines.com.au and Time Palette www.timepalette.com.au websites are simple customer facing (promotional) websites to provide information on the professional services and products (goods and services) that Yellow Lines provides. Yellow Lines does not leverage cookies for the purpose of covertly or overtly collecting any personal information. Our websites are "dumb" and harmless, unless an individual chooses to submit an inquiry via the "Contact Us" form and includes personal information within. No field in the "Contact Us" form is mandatory, allowing a person to choose to include limited information, be anonymous, or use a pseudonym if desired, however, under these circumstances it may be impractical for Yellow Lines to facilitate any deep engagement or even respond. The "Contact Us" form should not be considered secure, and no Sensitive Personal Information (SPI) should be entered into or sent via the "Contact Us" form. However, in the event that a person does submit SPI via the "Contact Us" form, the information will be bound by this Policy regardless. Yellow Lines encourages people to submit minimal detail via the "Contact Us" form. The "Contact Us" form is a simple (non-secure) tool for an individual to initiate contact/engagement. In the event that Yellow Lines becomes aware of a breach of this Policy which impacts the personal information of any individual, Yellow Lines will take assertive action to notify impacted individual(s), and to any extent possible prevent further breach. Yellow Lines would execute such a notification as soon as possible, and would prioritise such a notification over avoiding reputational damage to Yellow Lines. The following parties, as a part of their day to day business with Yellow Lines, would have access to or use of some of the information that we collect/collate as part of everyday business. Some of these parties may also have infrastructure, systems and resources outside of Australia. - Our legal practitioner - Our accounting practitioner - Our email hosting provider - Our accounting software provider - Our website hosting provider In the event that one of these five (5) parties was to incur and notify a privacy breach, Yellow Lines will proactively treat this as a potential breach of our Policy, and will take action to disclose the potential breach to any impacted individual. In the event of a material change to this Policy, and therefore a change our commitment/responsibility on the handling of information, Yellow Lines will notify any impacted party a minimum of sixty (60) days prior to that Policy change. The notification process will include instructions on how an individual may request to have the handling of current or future collected/collated information changed (such as deleted) prior to the Policy change coming into effect. This Privacy Policy was last reviewed for update on Monday 21 January 2019. At a minimum, this Policy will be reviewed annually. Yellow Lines loves getting feedback of all types. Please send any feedback on privacy related matters to privacy@yellowlines.com.au or privacy@timepalette.com.au ************************************* CHANGE LOG 03/01/2019 V1 * Created new Policy. 21/01/2019 V1 * Added detail of Time Palette, including clarifying that Yellow Lines is the parent of Time Palette, and for the purpose of individuals dealing with us, this Policy applies equally to both. * It was deemed that this change to this Policy will not impact previously collected Personal Information of any individual, and therefore Yellow Lines did not provided 60 days notice of the Policy change, and is not required to actively notify any individual of the Policy change beyond making this newly updated Policy available.