This privacy policy (the Policy) sets out in accordance with the Privacy Act 1988 (Cth) the way in which Australian Rail Track Corporation Ltd (ARTC) (ACN 081 455 754) and its associated entities (together ARTC, we, us, or our) may collect, store, use, manage and protect your Personal Information in relation to the use and operation of the KM2Me mobile application (KM2Me).
By:
- downloading and installing KM2Me;
- accessing and using KM2Me;
- otherwise providing Personal Information to ARTC, its officers, agents or employees
you acknowledge and consent to the use collection, storage or disclosure of your Personal Information in accordance with this Policy and the Privacy Act. If you do not agree to the use of your Personal Information in the manner set out in this Policy, you must immediately cease to use KM2Me.
What is Personal Information?
We follow the definition of Personal Information given in the Privacy Act:
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
What kinds of Personal Information might we collect and hold?
We may collect (and hold) different Personal Information about you depending upon how you interact with us. This information may include, but is not limited to:
- access to your device’s camera;
- your email address;
- your location;
- in-app messages, broadcasts and other correspondence with KM2Me or our officers, agents, employees or contractors;
- your device ID, name and device type;
- responses to surveys;
- your preferences;
- your employment;
- queries, complaints, enquiries, feedback and comments;
- how and when you use KM2Me;
any information regarding your dealing with us.
How do we collect Personal Information?
We collect Personal Information:
- directly from your device (when KM2Me is in use)
- directly from you (when you contact us, or when we contact you)
- from third parties who you have authorised to provide us with information.
How do we hold and secure your Personal Information?
Personal Information is stored digitally, on site or with a third party storage provider. ARTC does not store personal information related to the use of KM2Me in hard or physical copies. Where appropriate, ARTC has agreements with its storage providers to keep all Personal Information they store secure, using reasonable and appropriate security methods. ARTC uses data storage providers located inside Australia.
Why do we collect, hold, use and disclose Personal Information?
ARTC may collect Personal Information via the KM2Me App for a number of reasons, including:
- to enable operation of KM2Me;
- providing you with information/ communications about the operation of the KM2Me & our operations, services or projects;
- developing or refining the user experience of KM2Me;
- providing support to users in the use of KM2Me;
- internal business purposes;
- corporate governance, auditing and record keeping.
Our use of Personal Information may extend beyond these uses, but will be restricted to purposes that we consider to be related to the operation and improvement of KM2Me and ARTC related functions and activities.
What about device-based location information?
KM2Me requires access to device-based location information as a part of its core function. By ‘allowing’ ARTC to access your device-based location information you are consenting to the collection, use, transmission, processing and maintenance of your location data, including the real-time geographic location of your device. Such information may include, but is not limited to, your device ID and name, device type and real-time geographic location of your device whilst downloading or using KM2Me.
Can you access your Personal Information or request it be corrected?
You may request access to the Personal Information that we hold about you by contacting us by any of the methods as set below.
Upon receiving an access request we may request further details from you to verify your identity.
We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction.
An administrative fee may be charged to cover our costs in providing you with access to your Personal Information.
This fee will be explained to you before it has been incurred.
We will respond to your access request within a reasonable period of time by:
- providing you with access to your Personal Information;
- rejecting your access request, and providing you reasons for this rejection.
Access requests may be denied where:
- we believe your request is frivolous or vexatious;
- we are entitled to reject a request by law;
- we are unable to verify your identity; or
- you have not paid the administrative fees referred above.
If you believe that the Personal Information that we hold is inaccurate or otherwise requires correction, you may send us a correction request by contacting us by any of the methods as set out below. We will review your Personal Information and respond to the request within a reasonable period of time.
Does this policy ever change?
From time to time we may make changes to this Policy. When we do, we will highlight those changes in yellow highlight for a period of 14 days. Changes come into effect from the time when they are brought to your attention, or when you next use KM2Me, whichever is earlier. Please make sure you review the Privacy Policy each time you use KM2Me to keep up to date on any changes.
What happens if you have a question or complaint about how we have handled your Personal Information?
For further information about our privacy policy and related information practices, or to make a complaint, please contact us by one of the following methods:
Emailing: km2me.support@artc.com.au
or Sending a letter: PO Box 10343, Gouger Street Adelaide SA 5000
We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious or if we are unable to verify your identity. If you aren’t satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at http://oaic.gov.au.