Global Privacy Principles
We have adopted a comprehensive approach to privacy, incorporating the National Privacy Principles (NPPs) from the Privacy Act 1988 (Cth) (the Privacy Act) in Australia, as well as compliance with privacy regulations in the United States (including CCPA and HIPAA), the United Kingdom (UK GDPR), the European Union (GDPR), and New Zealand (Privacy Act 2020).
These principles govern the way in which we collect, use, disclose, store, secure, and dispose of your personal information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Federal Privacy Commissioner at www.privacy.gov.au. For information on the privacy regulations in the US, UK, EU, and New Zealand, please refer to the relevant government websites.
What is Personal Information and Why Do We Collect It?
Personal information is information or an opinion that identifies an individual. Examples of personal information we collect include names, addresses, email addresses, and phone numbers.
This personal information is obtained in various ways, including interviews, correspondence, by telephone and email, via our website toaglobal.com, from other publicly available sources, from cookies, and from third parties. We do not guarantee website links or the policy of authorized third parties.
We collect your personal information for the primary purpose of providing our services to you, providing information to our clients, and marketing. We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or by simply clicking on the “Unsubscribe” link at the bottom of an email sent to you from us.
When we collect personal information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive Information
Sensitive information is defined in the Privacy Act and other global regulations to include information or opinions about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained.
- For a secondary purpose that is directly related to the primary purpose.
- With your consent; or where required or authorized by law.
Third Parties
Where reasonable and practicable, we will collect your personal information only from you. However, in some circumstances, we may be provided with information from third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your personal information may be disclosed in a number of circumstances, including the following:
- To third parties, where you consent to the use or disclosure.
- Where required or authorized by law.
- Information via web forms may be used to protect the copyright, trademarks, or legal rights of toaglobal.com, its clients, or third parties.
- Personal information that we store may be processed in or transferred between parties located in countries outside of Australia, including but not limited to New Zealand, the UK, the USA, Canada, the Philippines, and EU countries. These transfers will be done in compliance with the relevant privacy laws applicable in those regions. By providing your personal information, you are consenting to the terms and conditions of this privacy policy, including cross-border data transfers, as outlined above.
If there is a change of control in the business or a transfer, we reserve the right to transfer our user databases, together with all information provided in this privacy policy, to the extent permissible by law. This information may be disclosed to a potential partnership under an agreement to maintain confidentiality.
Third-Party Disclosure
We work with third-party digital app providers who provide functions related to contact management, application development and integration, and web hosting, all of which have their respective privacy policies linked to their pages. We do not share or trade your private information with outside parties.
Here is a list of our third-party providers:
- HubSpot CRM
- GoDaddy
- InMotion
- FileVine
- Social Media Accounts
These third parties provide services to us, which we purchase or subscribe to. They may have access to our contacts but are subject to maintaining the confidentiality of such information and only perform the necessary functions to provide us with their services.
These third-party products or services are not included on our website.
Security of Personal Information
Your personal information is stored in a manner that reasonably protects it from misuse, loss, unauthorized access, modification, or disclosure.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in client files, which will be kept by us for a minimum of 7 years.
Access to Your Personal Information
You may access the personal information we hold about you and request updates and/or corrections, subject to certain exceptions. If you wish to access your personal information, please contact us in writing.
TOA Global will not charge any fee for your access request but may charge an administrative fee for providing a copy of your personal information. To protect your personal information, we may require identification from you before releasing the requested information.
Access Rights to Personally Identifiable Information (PII)
Under various global privacy laws, including GDPR, CCPA, and others, you have the following rights regarding your personally identifiable information (PII):
- Right to Access: You have the right to request a copy of the personal data we hold about you.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
- Right to Erasure: You have the right to request that we erase your personal data, under certain conditions.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
- Right to Data Portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
- Right to Object: You have the right to object to our processing of your personal data, under certain conditions.
- Automated Decision Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our provided contact information.
Method for Data Subjects to Object to Data Processing
If you wish to object to the processing of your personal data, you may do so by:
- Email: Send a detailed request to notifications@toaglobal.com, specifying the nature of your objection and the specific processing activities you wish to object to.
- Postal Mail: Send a written request to our address at i) Level 12, Australia Fair, 36 Marine Parade, Southport, QLD, 4215 Australia; or ii) 3100 West 7th St, Suite 350, Fort Worth TX 76107 USA. Please include your contact information and a description of the processing activities in question.
- Online Form: Please Click here to submit your request online.
We will review your request and respond within one month, in accordance with applicable legal requirements. If your objection is valid, we will cease the processing of your personal data unless there are compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
Maintaining the Quality of Your Personal Information
It is important to us that your personal information is up-to-date. We will take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date. If you find that the information we have is not up-to-date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we continue to provide quality services to you.
Policy Updates
This policy may change from time to time and is available on our website.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our privacy policy, please contact us at any of the following:
- Email: Send a detailed request to notifications@toaglobal.com
- Postal Mail: Send a written request to our address at i) Level 12, Australia Fair, 36 Marine Parade, Southport, QLD, 4215 Australia; or ii) 3100 West 7th St, Suite 350, Fort Worth TX 76107 USA. Please include your contact information and a description or your query.
- Online Form: Please Click here to submit your query online
- Phone:
AUS +61 1300 896 522
USA +1888 585 1740
CND+1403 917 0244
