Privacy policy

1. About this policy

Holt Systems (ABN 81 691 926 020) ("Holt Systems", "we", "us" or "our") provides industrial controls and automation services from Brisbane, QLD. We respect the privacy of the people we deal with and are committed to handling personal information in line with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

This policy explains what personal information we collect, how we collect, use, disclose and protect it, and how you can access or correct it or make a complaint. It applies to personal information collected through our website at holtsystems.com.au and in the course of our business, including enquiries, site assessments, proposals and project delivery.

"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form.

2. Personal information we collect

We only collect personal information that is reasonably necessary for our business functions and activities. Depending on how you deal with us, this may include:

• Contact details: your name, job title, employer or company, business address, email address and telephone number.
• Enquiry details: the information you provide in our enquiry form or in correspondence, such as your industry, area of interest, site suburb and a description of your requirements.
• Project information: information provided or collected in the course of site assessments, proposals and project delivery, such as the names and contact details of your site personnel, site access and induction requirements, and correspondence about the work.
• Commercial information: details needed to prepare quotes, issue invoices and receive payment, such as billing contacts and purchase order details.
• Supplier and contractor information: contact and business details of suppliers and subcontractors we work with.
• Employment applications: if you apply to work with us, the information in your application, such as your resume, qualifications, licences and referees.
• Technical information: limited technical data generated when you visit our website, as described in section 4.

We do not seek to collect sensitive information (such as information about health, racial or ethnic origin, religious beliefs or criminal record). If sensitive information is required for a specific purpose, for example a site induction or an employment application, we will only collect it with your consent and where it is reasonably necessary, or where the collection is required or authorised by law.

3. How we collect personal information

Where practicable, we collect personal information directly from you, for example when you:

• submit the enquiry form on our website;
• email or telephone us;
• meet with us, including during a site assessment or project; or
• apply for a position with us.

We may also collect personal information from third parties where it is unreasonable or impracticable to collect it from you directly, such as from your employer or colleagues when they provide your details as a site contact, from our clients, suppliers and subcontractors, or from publicly available sources such as business websites and directories.

If we receive personal information that we did not request and could not have collected under this policy, we will destroy or de-identify it as soon as practicable where it is lawful and reasonable to do so.

4. Our website, cookies and analytics

Cookies. Our website does not use cookies, and does not store information in your browser.

Analytics and advertising. We do not use analytics, advertising, remarketing or social media tracking tools on our website.

Hosting. Our website is hosted on Google Firebase Hosting. As with most websites, our hosting provider automatically processes standard technical information when you visit, such as your IP address, browser type, device information, the pages you request and the date and time of your visit. This information is used to deliver the website and to maintain its security and reliability. We do not use it to identify individual visitors.

Enquiry form. When you submit our enquiry form, the information you enter, together with the page you submitted it from and the date and time of submission, is sent to our enquiries inbox by email. Access to submitted enquiries is restricted to authorised personnel who handle enquiries on behalf of Holt Systems. The form cannot be used to read or change information already submitted.

Links to other websites. Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.

5. How we use personal information

We use personal information for the purposes for which it was collected, including to:

• respond to your enquiry and communicate with you;
• arrange and carry out site assessments;
• prepare scopes of work, proposals and quotations;
• plan, deliver, commission and support projects, including coordinating site access, inductions and shutdowns;
• issue invoices, receive payments and manage our accounts;
• manage our relationships with clients, suppliers and subcontractors;
• assess employment applications;
• maintain the security and operation of our website and systems;
• meet our legal, regulatory, insurance and work health and safety obligations; and
• establish, exercise or defend legal claims.

We may also use personal information for a related secondary purpose that you would reasonably expect, or where you have consented, or where the use is required or authorised by law.

6. Direct marketing

We do not sell personal information, and we do not add people to mailing lists without their consent. We may occasionally contact existing clients and business contacts about services relevant to them, where they would reasonably expect us to do so.

You can ask us to stop sending you marketing communications at any time by using the unsubscribe option in the message or by contacting us using the details in section 16. Commercial electronic messages we send will comply with the Spam Act 2003 (Cth).

7. Disclosure of personal information

We may disclose personal information, where reasonably necessary for the purposes described in this policy, to:

• service providers who support our business, such as website and database hosting, email, file storage, accounting and payment providers;
• subcontractors and suppliers engaged to help deliver a project, limited to the information they need for that work;
• our client's personnel and contractors, where coordination on a project requires it;
• our professional advisers, such as accountants, lawyers and insurers; and
• government agencies, regulators or law enforcement bodies, where required or authorised by law.

We take reasonable steps to ensure that third parties who receive personal information from us handle it securely and only for the purpose for which it was provided. We do not sell, rent or trade personal information.

8. Overseas disclosure

Some of our service providers, including Google, which provides our website hosting, and email (Google Workspace), operate data centres and support functions outside Australia. As a result, personal information may be stored or processed overseas, including in the United States and other countries where those providers operate.

Where we use overseas service providers, we take reasonable steps to ensure they handle personal information in a manner consistent with the APPs, including by selecting reputable providers with appropriate security and privacy commitments.

9. Storage and security

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include:

• encrypting data in transit between your browser and our website and database;
• restricting access to personal information to personnel who need it for their role;
• using reputable cloud providers with industry-standard physical and technical security; and
• using strong authentication on the accounts we use to access personal information.

No method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee the absolute security of personal information.

10. Retention and disposal

We keep personal information only for as long as it is needed for the purposes described in this policy, or as required by law. For example, project and financial records are retained for the periods required by taxation and other laws, and enquiries that do not proceed to a project are reviewed periodically and deleted when no longer needed.

When personal information is no longer required, we take reasonable steps to securely destroy or de-identify it.

11. Anonymity and pseudonymity

You may deal with us anonymously or using a pseudonym where it is lawful and practicable, for example when making a general enquiry. However, we will usually need your name and contact details to respond to an enquiry, assess a site or provide our services.

12. Access and correction

You may request access to the personal information we hold about you, and ask us to correct it if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact us using the details in section 16.

We will respond within a reasonable period, generally within 30 days. We may need to verify your identity before acting on a request. We do not charge for making a request, but may charge a reasonable fee for the cost of providing access in some circumstances. If we decline a request, we will explain why in writing, except where it would be unreasonable to do so, and tell you how to complain.

13. Data breaches

If we become aware of a data breach involving personal information we hold, we will act promptly to contain and assess it. Where a breach is likely to result in serious harm to the individuals affected, we will notify those individuals and, where required, the Office of the Australian Information Commissioner (OAIC).

14. Complaints

If you have a concern about how we have handled your personal information, please contact us in writing using the details in section 16. We will acknowledge your complaint, investigate it and respond within a reasonable period, generally within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner:

• Website: www.oaic.gov.au
• Telephone: 1300 363 992

15. Changes to this policy

We may update this policy from time to time to reflect changes in our practices, our services or the law. The current version will always be available on this page, with its effective date shown at the top.

16. Contact us

For privacy questions, requests or complaints, please contact: