Privacy Policy

Who is PAM Wayfinding?

PAM Wayfinding Pty Limited ACN 653 127 452 (PAM Wayfinding, we, us, our and similar expressions) is a technology company providing wayfinding solutions including the PAM Wayfinding Platform.

This privacy policy (Privacy Policy) explains how PAM Wayfinding manages the collection, storage, use and disclosure of personal information and how to contact us if you have any further queries about our management of your personal information. This Privacy Policy does not cover personal information collected or held by PAM Wayfinding about its employees.

By using any of our products or services, or by providing us with personal information, you confirm that you have read and accept the terms of this Privacy Policy and expressly consent to the collection, storage, use and disclosure of your personal information in accordance with the terms of this Privacy Policy.

This Privacy Policy is in addition to any other terms and conditions applicable to the products and services we provide and your use of our websites.

If you do not agree to the terms of this Privacy Policy, you must not use our products and services, or our Websites.

Our privacy commitment.

Your privacy is important to us. Your personal information will always be collected, used, stored and disclosed by PAM Wayfinding in accordance with our Privacy Policy. If you have any queries relating to PAM Wayfinding’s Privacy Policy or the manner in which we handle your personal information, please contact our Privacy Officer, by email at support@pam.co.

What personal information does PAM Wayfinding collect?

So that we can provide you with our products and services, we may need to collect information about you or others. If you do not provide us with the information we request, we may not be able to supply you with our products and services.

Information we collect may include your name, email address, telephone number, gender, contact details, professional public register information and professional activity details relating to our products and services, information you submit to us in forms, provide to us by email, telephone, online chat or in connection with the use of our products and services, and enquiry or complaint details.

If you purchase products or services from us, our payment gateway provider may also require your credit card details to be provided, however these details are NOT stored in any form by us or on any internal or external databases.

We do not generally collect “sensitive information” as described in the Privacy Act 1988 (Cth) (Privacy Act). If we do need to collect sensitive information from you, we will seek your consent at or before the time we collect it.

How does PAM Wayfinding collect my personal information?

We may collect personal information:

• from people who access our Websites, our products and our services;
• when you create an account with us, or subscribe to receive any publications or newsletters from us;
• during conversations between you and our representatives;
• when you communicate with us via email, chat, post or fax; and
• from other people who are connected to our operations and activities – including employees, service providers and suppliers.

Whenever reasonable and practical to do so, we will collect personal information about you directly from you. In some cases, we may be required to collect personal information about you from third parties. For example, we may collect personal information from companies with whom you work, other organizations with whom you have dealings, credit reporting bodies, information service providers or from public sources. Where we collect information about you from a third party, we will take reasonable steps to ensure that you are made aware of the fact and circumstances of that collection.

Why does PAM Wayfinding collect personal information?

We collect personal information so that we can carry out our business activities in a professional and efficient manner, in particular to:

• advise customers which price plans are most appropriate;
• set-up and configure customer accounts;
• identify our customers, potential customers and people acting on their behalf;
• improve our service offerings;
• record and maintain user details and profile information;
• provide information on services available to subscribers and users;
• provide client and user support;
• deliver targeted marketing regarding new services and offers we believe may be of interest to you;
• collect fees and payments owing to us;
• respond to your enquiries and concerns and resolve disputes;
• contact you by email or telephone (by voice call or SMS); and
• compare information provided by you for accuracy and verify it with third parties.

From time to time, we may also use your personal information to send important notices to you, such as communications about purchases you have made, or changes to our terms and conditions or other policies. This information is important to your interactions with us and you acknowledge that you may not opt out of receiving these communications.

To whom is my personal information usually disclosed?

In carrying out our business, we may need to disclose your personal information to others, including:

• Related entities: to related entities of PAM Wayfinding;
• Service Providers: PAM Wayfinding’s service providers, including information technology service providers, printers and distributors of marketing material; credit reporting agencies, creditors, bankers, financiers, credit providers, mortgage insurers or trade insurers, and external business advisers (such as auditors and lawyers); and
• Users: members of PAM Wayfinding user groups, for example discussion groups where you have opted-in to that user group, or where you take part in any interactive areas of the Websites or your account.

We may also be required to disclose your personal information to a third party who is involved in a dealing or proposed dealing (including a sale) of all or part of our assets or business.

PAM Wayfinding does not sell personal information to other organizations.

Secondary Purpose(s)

PAM Wayfinding will not use or disclose your personal information for a purpose (secondary purpose) other than the main reason for which it was originally collected (primary purpose), unless:

• the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that PAM Wayfinding would use or disclose your information in that way;
• you have consented to the use or disclosure of your personal information for the secondary purpose;
• the use or disclosure is required or authorized by or under law; or
• the use or disclosure is otherwise permitted by the Privacy Act (for example, as a necessary part of an investigation of suspected unlawful activity).

Marketing purposes

Where we use your personal information to send you marketing and promotional information, you will be provided with an opportunity to opt-out of receiving such information. Unless you exercise your right to opt-out of such communication, you will be taken to have consented to the receipt of similar information and communications in the future.

Spam

We will not send you any commercial electronic messages such as SMSs or emails unless this is permitted by the Spam Act 2003 (Cth) (Spam Act) (for example, if we have your express or inferred consent to do so). Any commercial electronic message that we send will identify PAM Wayfinding as the sender and will include our contact details. The message will also provide an unsubscribe facility. If you do not wish to receive commercial electronic messages from us, please:

• unsubscribe from our database using the unsubscribe facility in the relevant electronic communication; or
• let us know by contacting us using the contact details provided at the end of this Privacy Policy.

Do Not Call Register

We will not call you on a number listed on the Do Not Call Register unless this is permitted under the Do Not Call Register Act 2006 (Cth) (Do Not Call Register Act) and related instruments (for example, if we have your express or inferred consent to do so). If we have contacted you on a particular number in error, please let us know by contacting us using the contact details provided at the end of this Privacy Policy.

Website usage information and cookies

We collect limited information about people who use our online resources, in order to track use of those resources and to maintain and improve those resources. Information collected includes:

• server address
• top level domain name
• the date and time of visit
• pages access and documents downloaded
• previous site visited
• if the person has visited our Websites before, and
• type of browser used.

When you access our Websites, we may use software embedded in our Websites (such as JavaScript) and we may place small data files (or cookies) on your computer or other device to collect information about which pages you view and functions you access, how you reach them, what you do when you visit them, the length of time you spend using them, and how we perform in providing content to you.

We may also use similar means to track usage data in relation to our products and services including cumulative operating hours, the hardware type and operating system of the devices you use to access the products and services, and other data connected with the operation of the products like (internal) operating temperature (collectively, Usage Information).

If you register for an account with us, Usage Information will be associated with your registration data. If you do not register your product Usage Information will be aggregated with that of other unregistered users and will not be associated with an identifiable person.

You may decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our Websites, products and services. You can refer to the ‘help’ section of your browser or installed applications for instructions on blocking, disabling or deleting cookies.

Security

We take reasonable steps to protect the privacy and security of your information, including entering into arrangements with third party service providers which require them to maintain the security of your information. However, you acknowledge PAM Wayfinding cannot control the security of data collected and stored on third party platforms and that there are inherent risks in transmitting information electronically and over the internet. PAM Wayfinding takes reasonable steps to ensure the security of data stored on our servers.

In what situations may I deal with PAM Wayfinding anonymously or by pseudonym?

You have the option to deal anonymously or by pseudonym if you contact us and you merely seek general information about our products and services. However, if you require information which is specific to your circumstances then it may not be possible for you to deal with us anonymously or by pseudonym.

Where is my personal information stored?

We take all reasonable steps to keep the personal information we hold about you secure and free from loss, misuse or interference. Personal information we collect and store is stored on secure servers, and is only accessible by those persons who need access to the information in order to carry out their business functions. We also maintain physical security measures to protect the use and storage of physical records containing personal information.

We only retain personal information for as long as it is needed by us, or for as long as we are legally required to retain the information (if that is longer). When we dispose of personal information, we ensure that it is disposed of or destroyed in a secure fashion in accordance with our obligations under the Australian Privacy Principles in the Privacy Act.

Some of the parties with which we exchange personal information are located outside Australia in countries including the United States, Canada and New Zealand.

Although these third parties are subject to privacy and confidentiality obligations imposed by contract or the regulatory frameworks of the jurisdiction in which they are located, you acknowledge that:

• they may not always comply with those obligations, or those obligations may differ from the obligations imposed by the Privacy Act, the Spam Act and the Do Not Call Register Act;
• we will not be accountable for a breach by those third parties of any of these obligations;
• in the event of breach, you may not be able to seek redress under the Privacy Act; and
• the third party may be subject to foreign laws which might compel further disclosures of personal information (e.g. to government authorities).

Access to your personal information

You may request that we provide you with access to the personal information we hold about you by contacting us using the contact details provided at the end of this Privacy Policy. However, the Privacy Act sets out certain circumstances where we may deny, or only partially comply with such a request, for example where:

• access would pose a serious threat to the life, safety or health of any individual or to public health or public safety;
• access would have an unreasonable impact on the privacy of other individuals;
• the request is frivolous or vexatious;
• denying access is required or authorized by a law or a court or tribunal order;
• access would be unlawful; or
• access may prejudice commercial negotiations, legal proceedings, enforcement activities or appropriate action being taken in respect of a suspected unlawful activity or serious misconduct.

If you require access to any information we hold about you, we request that you identify, as clearly as possible, the types of information requested. We will respond to your request to provide access to your personal information within 30 days and you agree we may charge you our reasonable costs incurred in supplying you with access to this information.

Updating your personal information

We take such steps as are reasonable in the circumstances to ensure that:

• the personal information we collect and store, is accurate, up to date and complete; and
• the personal information we use and disclose is accurate, up to date, complete and relevant.

If you believe that information we hold about you may not be complete, accurate and up to date, you may ask us to update or delete the personal information we hold about you at any time by contacting us using the contact details below.

You accept that we will take reasonable steps to verify your identity before granting access or making any corrections to or deletion of your information.

Complaints

If you have any concerns or complaints about the manner in which your personal information has been collected, stored, used or disclosed by PAM Wayfinding, please contact the PAM Wayfinding Privacy Officer.

We will treat your complaint confidentially and, after investigating your complaint, discuss the ways in which we can remedy the situation. We will ensure that we respond to your complaint within a reasonable time (and in any event within the time required by the Privacy Act, if applicable).

Problems or queries

If you have any queries or complaints about our handling of your personal information in accordance with privacy laws or for further information about PAM Wayfinding’s Privacy Policy, please contact our Privacy Officer:

Attention:

Privacy OfficerPAM Wayfinding Pty Ltd10 Carrington St, Level 11, Sydney, NSW 2000