Introduction

We value the privacy of every individual and are committed to protecting all personal information we collect. This policy outlines how we manage the collection, use, disclosure and handling of personal information.

We may amend this privacy policy from time to time. Updated versions of this policy will be placed on our website www.markham.com.pg or can be obtained by contacting our office.

If you are a user of our website, by accepting our terms and conditions, you consent to us collecting, using, disclosing and handling personal information as described in this policy, and agree to be bound by the obligations it imposes on you. As the policy may be amended from time to time, you should review it regularly.

Personal information

In this policy, “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.

Personal information includes “sensitive information” (which means information or an opinion about an individual’s racial origin, political opinions, membership of a political association or trade union, religious beliefs, sexual preferences or criminal record) and “health information” (which means information or an opinion about the health or a disability of an individual, or an individual’s wishes about the provision of health services).

Collection of personal information

We collect and hold personal information mainly about people who purchase our products or obtain information about our products.

Depending on the situation, the personal information we collect may include:

  • name, address and contact details (including phone number and email);
  • information relating to previous purchases or quotes;
  • information about your employment (name of the organisation you work for, position and  authority to make payments).

If information we request is not provided, we may not be able to provide services in the most effective or efficient manner, or at all.

We only collect personal information that is necessary for the operation of our business. This means we only collect information that is necessary to:

  • sell our products;
  • update our customer database;
  • provide marketing materials;
  • organise the delivery of our products.

We generally collect personal information in person, in writing, by telephone, by email or via our website. For example, we may collect information when you make an application to purchase a product, ask for a quote or request other services. We may also collect personal information via third parties, for example, when we process a purchase transaction and you are listed as a contact person, when one of your Facebook friends ‘likes’ or ‘friends’ our Facebook page or when someone subscribes you to our mailing list.

We may collect personal information about you from credit agencies, banks or other organisations to verify your ability to pay for our products if you enter into a credit arrangement with us.

Collection of information via our website

When you visit our website, information about your computer or web device is automatically recorded. This includes your IP address, your top level domain name (eg .com.au, .gov.au), the date and time of your visit to our site, the pages you accessed or downloaded, the address of the last site you visited, your operating system and the type of browser you used. This information may be collected by us or by a third party service provider on our behalf. This information is collected for statistical and system administration purposes and to improve our web based services. It does not readily identify individuals and we will not attempt to identify individuals from the records our server generates unless it is necessary for law enforcement purposes.

We may also use cookies to assign your device a user ID. Cookies contain information that allows us to identify your device. We may use this information to determine whether or not to display standard content. You can usually configure your browser so that it does not accept cookies.

Use and disclosure of personal information

We will generally only use personal information for the purpose for which it was collected or for a purpose that is related to the purpose for which it was collected.

We use personal information to provide, manage and administer our services. In the normal course of our business operations we may disclose personal information to our suppliers, our clients or to third party service providers such as affiliate organisations. Personal information may also be disclosed to our contract service providers, including but not limited to customer service staff, consultants, advisers, IT and internet service providers.

We will also disclose personal information if required by law to do so. If you consent, we will use your personal information to send you details of other products and services that we believe may be of interest to you. If at any time you no longer wish to receive such material, you may unsubscribe or otherwise let us know, and your details will be removed from relevant databases.

Transfer of information outside PNG

Some organisations that we disclose information to may be located, or may store information on computer servers, outside PNG. For example, some of our regular suppliers are based overseas. We do not transfer information outside PNG unless satisfied that the recipient organisation’s legal obligation to protect privacy is equivalent to ours.

Your responsibilities

If you provide us with personal information about other individuals, you must ensure that they are aware or will be made aware that the information is being provided to us, the types of organisations to which we may disclose the information and how they can access the information. If the information you are providing is health information or sensitive information, you must first obtain the individual’s consent to its disclosure.

If we disclose personal information to you, or you collect, use or handle personal information on our behalf, you must comply with all requirements for the collection, use, disclosure and handling of personal information that apply to you.

Security of personal information

We may store personal information in hard copy documents, as electronic data or in our software or IT systems (and those of our service providers). We endeavour to protect all personal information that we hold from misuse and loss, and to protect it from unauthorised access, modification and disclosure. It is important that the personal information we hold is up to date and correct. If you find it is not or that it contains errors, please advise us and we shall correct it.

While we take all reasonable steps to ensure the security of information provided to us via our website, there are risks in transmitting information across the internet. If you are concerned about conveying sensitive information via the internet, you might prefer to contact us by telephone or mail.

Retention of your information

We generally retain personal information as long as is necessary to perform the function or provide the services in relation to which the information is collected. However, we may retain personal information for longer periods to comply with legislative requirements for document retention, such as taxation obligations. If personal information is deleted from our database it may be retained in de-identified form on the servers of our internet service provider.

Accessing your information

We try to ensure that personal information we hold is accurate, complete, and up to date. If you ask us we will provide you with access to, and allow you to correct, personal information we hold about you.

If we do not provide you with access to your personal information we will advise you of the reasons for the refusal and inform you of any exceptions relied upon. In some circumstances we may require you to pay the reasonable cost of providing access to personal information we hold about you.

Dealing with us anonymously

When you use our website or ask us to provide general information, we may deal with you without requiring you to provide personal information. However, aside from those circumstances, the nature of our business is such that it is generally not possible for us to deal with people on an anonymous basis.

Use of our website

Our website may contain links to other websites that are not owned, operated or endorsed by us. We are not responsible for the privacy practices of those websites, or for the content, product or services provided by, or contained on, those websites.

Contact information

If you wish to gain access to your personal information, of if you have a complaint about a breach of your privacy or any other query about our collection, use or handling of personal information, you can speak directly with our staff who will do their best to try to resolve the issue.