PGF Insulation Pty Limited (ABN 39 659 498 889) (PGF Insulation, we, us, our) is a provider of goods in the Australian construction industry, and is bound by the Australia Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act).  We understand the importance of, and are committed to, protecting the personal information of all individuals including you.  This Privacy Policy explains how we manage your personal information (that is, information or an opinion about you, whether true or not, which identifies you or from which your identity is reasonably identifiable), including our obligations and your rights in respect of our dealings with your personal information.

Please take a moment to read our Privacy Policy as it describes what happens to your personal information that is collected in the course of our dealings with you.  For employees of PGF Insulation, see 9 below.

PGF Insulation is a member of the PGF Capital Group (PGF Group), which includes PGF Capital Berhad (listed on the Bursa Malaysia stock exchange) and its subsidiaries in other countries.

1. How we collect your personal information

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.  Where it is reasonably practical to do so, we will collect your personal information directly from you.  We may collect the personal information you directly give us through some of the following means:

1. When information is submitted to the website at pgfinsulation.com.au
2. from an organisation you work for, if the organisation uses our products and services;
3. from you when you make an inquiry or order in relation to goods or services (whether on your own behalf or for your organisation);
4. when you contact us via telephone , in writing or electronically;
5. through any mobile applications provided by our organisation;
6. while conducting customer satisfaction and market research surveys;
7. when administering any of our services; and
8. as otherwise required to manage our business.

However, in certain cases we may collect personal information from publicly available sources and third parties, such as suppliers, recruitment agencies, contractors, our clients and business partners.  Where a business seeks to purchase our products on credit, we may seek commercial credit reports that may include limited personal information about officeholders.

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

2. Types of personal information we collect

The type of personal information we may collect can include (but is not limited to), your name, postal address, email address, phone numbers, billing information and, if applicable, employment information.

If you are a director of an organisation that is our customer and have agreed to act as guarantor, we may collect information about your assets and your other liabilities, to assess the credit risk position of that organisation.

We do not usually collect sensitive information (such as health information) about customers.

Where you do not wish to provide us with your personal information, we may not be able to provide you (or the organisation you work for) with requested goods or services.

We do not provide credit to individuals for consumer purposes, and we do not participate in consumer credit reporting.

3. Our purposes for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances.

We collect, hold, use and disclose personal information to:

1. offer and provide you (or the organisation you work for) with our goods and services;
2. manage and administer those goods and services, including account keeping procedures;
3. communicate with you, including (but not limited to), emailing you tax invoices, dispatch and tracking information, returns and exchange authorisations;
4. comply with our legal and regulatory obligations; and
5. otherwise to manage our business.

Except as permitted by law, we will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure.

We may disclose personal information within the PGF Group and to third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, as necessary for these functions or as otherwise required or permitted under law.

If we disclose information to a third party, we take reasonable steps to require that the third party will hold the information solely for our benefit and will protect your information to the same extent that we do, unless no steps are available.  (For example, if we need to bring court proceedings, we cannot require that the court will protect privacy in the same way that we do.)

4. Protection of personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.

We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information.  This also applies to disposal of personal information.

We further protect personal information by restricting access to personal information to only those who need access to the personal information do their job.  Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.

We take reasonable steps to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

5. Direct marketing

Like most businesses, marketing is important to our continued success.  We believe we have a unique range of products that we provide to customers at a high standard.  We therefore like to stay in touch with customers and let them know about new opportunities.  We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.

We will not disclose your personal information to third parties for marketing purposes without your consent.

If you have preferences about the kinds of messages you receive and the channels to be used, you may express these by contacting our Privacy Officer.  You can also request to opt out of all messages if you prefer.  Contact details are in paragraph 8.

6. Accessing and correcting your personal information

You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to ask for corrections to that information, at any time.  In some cases, the Privacy Act allows us to decline to provide access.  If that happens, we will provide you with a written notice of our reasons.  We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.

We are not obliged to correct any of your personal information if we do not agree that it requires correction, and may refuse to do so.  If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time, and usually complete the response within 30 days, unless we need additional information from you to respond.

7. Overseas transfers of personal information

We may disclose personal information to our parent company in Malaysia in connection with the purposes in paragraph 3.

As at the date of this Privacy Policy, we are not likely to disclose personal information to other overseas recipients.  If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act, which would include modifying this Privacy Policy to specify the relevant countries.

PGF Capital Berhad is regulated under the Personal Data Protection Act of Malaysia, which offers similar rights as under the Privacy Act.  In addition, PGF Capital Berhad has agreed to use reasonable endeavours to make sure that any use or disclosure of information about Australian persons will be for the purposes in paragraph 3, and will not cause a breach of the Australian Privacy Principles.

Where we use cloud-based technology in connection with our products and services, we use reasonable efforts to make sure that the cloud service provider will not do anything that would cause a breach of the Australian Privacy Principles.  For example, we require them to hold the information solely for our purposes.

8. Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our Privacy Officer:

The Privacy Officer
2B Dunmore Drive, Truganina VIC 3029
Telephone: 0482 709 915
Email: privacy@ecowool.com.au

We take all complaints seriously, and will respond to your complaint within a reasonable period, usually within 30 days.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney  NSW  2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

9. Employee information

We collect information in relation to employees as part of their application and during the course of their employment, either from them or in some cases from third parties such as recruitment agencies. Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.

10. Changes

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Website www.pgfinsulation.com.au

The last update to this document was 1 September 2022.