If you would like a printed version of this policy, you can print this page using your browser, or contact us for a copy. Our contact details are listed at the end of this Policy.
To meet your expectations about privacy and confidentiality Two Crows has operational processes and procedures to comply with:
- Australian Privacy Principles (APPs) contained in the Privacy Act 1988
- Australian Direct Marketing Association (ADMA) Code of Practice in relation to how we market to our customers;
- Spam Act 2003 in relation to electronic marketing;
If you have any questions not addressed in this policy, please feel free to contact us using the methods at the end of this policy under the heading “How to contact Us”.
Should there be any inconsistency between this policy, the Privacy Act and other Acts mentioned above, this policy shall be interpreted to give effect to and comply with the legislation.
This policy includes examples but is not intended to be restricted in its application to such examples. Where the word ‘including’ is used, it shall mean ‘including without limitation’.
Our websites may contain links to non-Two Crows websites. We are not responsible for the privacy policies of those other websites. We recommend you review the privacy policies of each site you visit.
Collection of personal information
‘Personal information’ means information we hold about you where your identity is either clear or can be reasonably determined. When you give us your personal information, it imposes a serious responsibility on us. Protecting your privacy when handling your personal information is very important to us and is fundamental to the way we serve you.
Generally, we will collect personal information directly from you, and only to the extent necessary to provide the product or service (including our agency functions) you requested or to carry out our internal administrative operations or meet relevant regulatory requirements. An ‘agency function’ means a service that we provide to you on behalf of another organisation. We may also collect personal information for the purpose of enhancing our ability to improve service delivery to you and other customers in the future.
We may collect personal information from you when:
- you fill in an application form;
- deal with us over the telephone or over web chat;
- register for, or use, our online products and services;
- e-mail us;
- create an account with us;
- participate in an online promotion
- provide us with feedback
- complete online surveys
- contact, register with, post to, like or follow any of our social media websites, pages, forums or blogs
- ask us to contact you after visiting our website.
We will collect personal information from you by lawful and fair means.
If you choose to not provide your personal information when requested, we may not be able to deliver the product or service that you have requested. We will endeavour to make this as clear as possible for each service.
In some cases, where it makes sense and is lawful, you can interact with us anonymously or by using a pseudonym (an alias). We will endeavour to make this option clear when it is available to you.
As noted above, we will only collect personal information from you that’s necessary to provide the product or service or to carry out internal administrative functions, or any other personal information you submit to us. We collect different personal information depending on the product or service that you have requested.
We may also collect personal information from third parties such as retailers, other individuals or any other third party in order to provide our services to you. In such instances we assume the person providing the information is authorised to provide us with your personal information. There may be occasions when we collect information about you from a third party where it is reasonably necessary or normal business practice to do so, for example from payment gateways relating to payments made through third party providers.
Newsletters – We may offer newsletters, or Promotions and Offers from time to time. We collect your name and your email address which we keep until you choose to unsubscribe from this service.
“Unsolicited” personal information is personal information about an individual that an organisation has unintentionally received. This is an uncommon occurrence, but when it does happen, we will protect your personal information with the same rigour as we treat personal information that we intended to collect. If we could not have collected this information through our normal processes, we will de-identify that information as soon as we can.
Uses and sharing
We use the personal information you provide only for purposes consistent with the reason you provided it, or for a directly related purpose. We may also use your personal information where required or permitted by law. We may also use your information where you have provided us with your express or implied consent.
We may also use your personal information, or aggregate your personal information with the personal information of other customers (so that the aggregated information is no longer personal) for the purposes of:
- analysis to help us better understand the needs of our customers so that we and third parties can better develop products and services for you;
- providing information that is tailored to what we believe are your areas of interest; and;
- analysing your product and services to improve your experience and to enable us to develop new or enhanced functionality for you.
We do not share your personal information with other organisations unless:
- you give us consent, or
- where sharing is otherwise required or permitted by law, or
- where this is necessary on a temporary basis to enable our contractors to perform specific functions.
We may contact you periodically to advise you of new or enhanced functionality which is available in connection with our products and services. You will not be obliged to adopt any such functionality.
When we temporarily provide personal information to companies who perform services for us, such as specialist information technology companies, mail houses or other contractors to Two Crows we require those companies to protect your personal information as diligently as we do. Strict contractual and other quality assurance measures are used to ensure your personal information is protected.
We have a strict duty to maintain the privacy of all personal information we hold about you. However, certain exceptions do apply. For example, where disclosure of your personal information is:
- authorised or required by law.
- with your consent – your consent may be implied or express and it may also be verbal or written.
From time to time we may use the personal information we collect from you to identify particular products and services which we believe may be of interest to you. We may then contact you to let you know about these products and services and how they may benefit you. We will generally only do this with your prior consent (where practical) and we will always give you a choice to opt out of receiving such information in future.
Direct Marketing generally takes the form of Direct Mail or Electronic Marketing (email). In rare cases, we may use Telemarketing. Each of these channels is handled as follows:
- Direct mail – Where we use your personal information to send you marketing information via the post we may do so with your implied consent or, if this is impracticable, we will ensure that you are provided with an opportunity to opt out of receiving future such communications. By not ticking a clearly displayed “opt out” box, we will assume we have your implied consent to receive similar marketing communications in the future. We will always ensure that our opt out notices are clear, conspicuous and easy to take up.
- Electronic marketing – Where we use your personal information to send you marketing information by e-mail, SMS, MMS or other electronic means we may do so with your express or implied consent. You may give us your express consent by, for example, ticking a box on an electronic or paper form where we seek your permission to send you electronic or other marketing information. Consent may be implied from our existing business relationship or where you have a reasonable expectation of receiving an electronic marketing communication.
Every directly addressed marketing contact sent or made by Two Crows will include a means by which customers may unsubscribe (or opt out) of receiving further marketing information.
Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to the channels provided under ‘How to contact us’.
Accessing your personal information
You have the right to request access to the personal information we hold about you. This right is subject to certain exceptions allowed by law.
Two Crows will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type (or types) of information requested. Two Crows will deal with your request in a reasonable time – usually within 30 days.
Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information.
Updating your information
It is inevitable that some personal information which we hold will become out of date. We will take reasonable steps to ensure that the personal information which we hold remains accurate and, if you advise us of a change of details, we will amend our records accordingly.
Where your information has been disclosed to a third party, Two Crows will take reasonable steps to notify the third party of the correction.
Where we are unable to update your information, we will provide an explanation in writing as to why the information cannot be corrected.
Two Crows is committed to protecting and securing your personal information.
We employ appropriate technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse or alteration.
We limit access to personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by the law.
Website security and privacy
We understand that you may be concerned about the security of the personal information we collect from you online.
Accordingly, we have systems in place to ensure our online dealings with you are as secure as your dealings with us in person, or on the telephone.
In those instances where we secure your personal information in transit to us and upon receipt, we use the industry standard encryption software, Secured Socket Layer (SSL) 128 bit encryption. The URL in your browser will change to “HTTPS” instead of “HTTP” when this security feature is invoked. Your browser may also display a lock symbol on its bottom task bar line to indicate this secure transmission is in place.
Information collected on our websites
We may collect non-personal information from you such as browser type, operating system, and web pages visited to help us manage our web site.
Our internet server logs the following information which is provided by your browser for statistical and content optimisation and personalisation purposes:
- the type of browser and operating system you are using
- your Internet Service Provider and top level domain name (for example – .com, .gov, .au, .uk)
- the address of any referring website (for example – the previous web site you visited), and
- your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).
All of this information is used by Two Crows for aggregated statistical analyses or systems administration purposes only. No attempt will be made to identify users or their browsing activities, except where required by law.
A “cookie” is a packet of information stored on your computer that allows the Two Crows server to identify and interact more effectively with your computer.
Our websites use two different kinds of cookies:
- Session cookies – temporary cookies that only last until you close your browser
- Persistent cookies – cookies that are stored for a longer term on your computer.
When you access our web site, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user’s internet browser type. When you close your browser, the cookie is deleted and no longer exists on your computer.
You are free to disable cookies in your browser (see details below). If you have disabled cookies you may not be able to take full advantage of all of our website features.
We use session cookies in the following manner:
Log-on and log-off administration – Session cookies help with the log-on and log-off processes for those users who have decided to register to use one of our online services. The cookies enable us to recognize your user ID when you log on so that we do not establish a duplicate registration record for you.
Transactions and site usability – We use session cookies to improve how you navigate through our website and conduct transactions. As examples, session cookies are used to maintain your online session as you browse over several pages; to store and pre-populate information so that you do not have to re-enter the same information twice. Session cookies may also be used to collect referral statistics when you click on a link or ad banner to or from auspost.com.au, and associated websites.
Two Crows may also use “persistent cookies”. A persistent cookie is a small piece of text stored on your computer’s hard drive for a defined period of time, after which the cookie is erased. Two Crows will not collect or link to personal information through persistent cookies without your express consent.
- Microsoft Internet Explorer
- Mozilla FireFox
- Google Chrome
- Apple Safari
Links to other sites
The Two Crows website may contain links to other sites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read and understand the privacy policies on those websites prior to providing any information to them.
Some of the content appearing on the Two Crows website may be supplied by third parties, for example, by framing third party web sites or the incorporation through “framesets” of content supplied by third party application service providers. In such cases, Two Crows will ensure that our contractual arrangements with these third parties protect your personal information in compliance with privacy laws.
Search terms that you enter when using our search engine are collected, but are not associated with any other information that we collect. We use these search terms for the purpose of aggregated statistical analyses so we can ascertain what people are looking for on our website, and to improve the services that we provide.
We may use external companies to provide us with detailed aggregate statistical analyses of our website traffic. At no time is any personal information made available to these companies, nor is the aggregate information ever merged with personal information such as your name, address, email address or other information you would consider sensitive or would compromise your privacy.
Loss of personal information
Despite our every effort to protect your personal information, there remains the possibility that a breach of our security could occur. In the event of loss of personal information Two Crows will:
- Seek to rapidly identify and secure the breach to prevent any further breaches
- Engage the appropriate authorities where criminal activity is suspected
- Assess the nature and severity of the breach including the type of personal information involved and the risk of harm to affected individuals
- Notify the affected individuals directly if appropriate and where possible
- If appropriate, put a notice on our website advising our customers of the breach
- Notify the Privacy Commissioner (at the OAIC) if the breach is significant.
How to contact us
Two Crows is committed to working with its customers to obtain a fair resolution of any complaint or concern about privacy.
To contact us with a compliment or complaint or a privacy question, you can:
write to us at:
PO Box R165
ROYAL EXCHANGE NSW 1225
call us on +61 438 783 893 between 9.00am and 5.00pm EST Monday to Friday.
Last updated: April 2017