Privacy Policy

In this policy, you refers to clients, employees (including potential employees), suppliers, contractors, affiliates and any other individuals with whom we interact on a more informal or ad hoc basis as described in this policy.

By voluntarily supplying us with your personal information you are agreeing to be bound by this policy. While we may update our policy from time to time, the most recent version will always be available on our website. If we change the policy in any material way, we will post a notice on our website along with the updated policy, and we may also contact you using the contact information we hold for you.

If you have any queries, concerns or complaints about how we handle your personal information, please contact our Privacy Officer in the first instance:

Privacy Officer: Nick Johnston
Email: admin@integrawaterservices.com.au
Post: Attention: Privacy Officer, Integra Water Services, PO Box 344, Tatura VIC 3616

Our website contains links to other websites or applications. When you click on a link to another site, you are no longer subject to this policy.

Collection from you

We collect and store information you provide directly to us, whether in person, by email, by phone, via our website or by any other direct means. This includes:

• Contact information — such as your name, address, email address and phone number.
• Personal information — such as your date of birth.
• Financial and payment information — such as your payment details (credit card, bank account, and similar).
• Business details — such as your Australian Business Number, details of the water entitlements you hold, allocation bank account details, and your place of business.

Automatic collection

We use cookies — small text files stored on your device that provide information such as your IP address, server and internet service provider details, and how you interact with our website — and other services that help us understand how you use our online media. This information is not linked to you personally. We use Google Analytics to measure user interaction and improve our products and services. If you opt out of third-party tracking technologies or prevent the use of cookies, some website functionality may be lost or affected.

Device and communications

If you use our services through a mobile device, we receive technical information about your device and its identifiers, and location information that is not associated with you. When you communicate with us, we collect details such as your email address or phone number, and we engage third-party services that tell us how you interact with some of the communications we send. You can choose not to receive communications from us by contacting our Privacy Officer or using the relevant links in email communications.

Through other sources

Where necessary, we may collect your information from publicly available records — for example, records maintained by the Victorian Department of Energy, Environment and Climate Action (or its interstate equivalent), the Victorian Water Register, the Australian Securities and Investments Commission, the Australian Financial Security Authority (PPSR), and land titles offices in each state. We do this only where it is unreasonable or impractical to collect the information directly from you. If you have previously applied for a position with us, we may receive your personal information from third parties such as recruiters or external websites.

Information about someone else, and sensitive information

If you provide us with personal information about another person, you must ensure you are authorised to disclose it and that we may collect, store, use and disclose it for the purposes described in this policy. We do not routinely collect sensitive information as defined in the Privacy Act; if we need to, we will always request your express consent beforehand. You may deal with us anonymously or using a pseudonym, though this may not be practicable when engaging our services, and choosing not to provide your personal information may mean we are unable to provide our services to you.

We only use your information for the purpose for which it was collected (the primary purpose), a related purpose you would reasonably expect, or a purpose for which you have given consent. Our primary purposes are:

• Providing our water broking services, including arranging and facilitating temporary trades and water entitlement sales.
• Providing our water rights consulting services.
• Complying with laws, audit and regulatory requirements, including record-keeping and responding to regulators.
• Identifying authorised representatives and conducting diligence and searches, including verifying identity and authorisations.
• Responding to enquiries and complaints, including customer service and complaint handling.
• Any purpose related to the above and necessary to carry out our functions.

Disclosure to third parties

We may disclose your personal information to third parties who help us provide, manage and administer our services — including providers of digital solutions such as Aquifa, and parties who send marketing information on our behalf (which you may opt out of at any time). We will not sell or license your information, or otherwise disclose it, except where disclosure is required by law — such as to comply with court orders, subpoenas, other legal process, or investigations including by tax authorities. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

We store your personal information as physical files in a secured area and on our electronic database systems and computers, with appropriate backup and security. We take reasonable steps to protect it from misuse, loss and unauthorised or accidental access, modification, disclosure or destruction by:

• Physical, electronic and procedural safeguards in line with industry standards.
• Requiring third-party providers to maintain acceptable security measures.
• Limiting access to the information we collect about you.
• Imposing confidentiality requirements on our employees.
• Only providing access once proper identification has been given.

In the unlikely event of a reportable data breach, we will notify you and any relevant authorities in accordance with our obligations. We keep your personal information only for as long as we require it, or as required by law — where you have engaged our water broking services, we are required to retain certain personal information relating to that engagement for six or more years. When we no longer require it and are not legally required to retain it, we take reasonable steps to destroy or de-identify it. We do not disclose or store personal information overseas.

Under the APPs you may request a copy of the personal information we hold about you. Please make your request in writing; we will ask you to verify your identity and specify what information you wish to access, and if eligible we will grant access within 30 days. We may charge a fee to cover the cost of processing an application (retrieving, reviewing and copying the material), but not for making the request itself.

We endeavour to keep the personal information we hold accurate, complete and up to date. If you believe the information we hold requires correction or is out of date, please contact us using the details above. We aim to process any request within 30 days and will provide written reasons if a request is rejected, along with details for making a complaint about the refusal.

If you are concerned that we have not complied with your legal rights or the applicable privacy laws, contact our Privacy Officer in the first instance, in writing, with a thorough description of your concerns. We will confirm your identity before processing a request relating to information we may hold about you, and we expect our procedures to deal fairly and promptly with your complaint.

If you remain dissatisfied, you can contact the Office of the Australian Information Commissioner:

Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001