Privacy Policy

Strottman's Privacy Statement

This document declares the undertakings by Strottman in relation to its handling of Personal information.

Data Collection

Strottman undertakes to collect Personal information by means that are:

fair;
legal; and
transparent.

If you visit Strottman's web-site, your web-browser automatically discloses, and Strottman's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.

Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.

Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (such as Strottman.com). This data may or may not be sufficient to identify you.

If you disclose personal data to Strottman in conjunction with an identifier such as your name or your credit-card details, Strottman will collect Personal information. Moreover, any data that becomes available to Strottman through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Personal information.

Subject to the qualifications immediately below, Strottman undertakes to collect Personal information from you and not from other parties. This undertaking is qualified as follows:

where Strottman reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Personal information from other sources. This applies in particular to consumer profile data.

Strottman undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.

Data Security

Strottman undertakes to store Personal information in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.

Strottman undertakes to store Personal information only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.

Strottman undertakes to transmit Personal information in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.

Strottman undertakes to implement appropriate measures to ensure security of Personal information against inappropriate behavior by Strottman's staff-members and contractors. These include:

training for staff in relation to privacy;
access control, to limit access to Personal information to those staff and contractors who have legitimate reasons to access it;
particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behavior;
declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behavior
clear communication of policies and sanctions; and
processes to audit, to investigate and to impose sanctions.

Data Use

Use refers to the application of Personal information by any part of Strottman, or any staff-member or contractor of Strottman in the course of their work.

Strottman undertakes to use Personal information only for:

the purposes for which it was collected;
such other purposes as are subsequently agreed between Strottman and You;
such additional purposes as may be required by law. In these circumstances, Strottman will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and

Strottman undertakes to use Personal information only if it has demonstrable relevance to the particular use to which it is being put.

Strottman undertakes to use Personal information in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.

Data Disclosure

Disclosure refers to making Personal information available to any party other than Strottman and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.

Strottman undertakes to disclose Personal information only under the following circumstances:

in the course of business being conducted between You and Strottman, where disclosure is necessary to a contractor, such as a transport company. Where Personal information is disclosed in this way, Strottman undertakes to exercise control over Strottman's contractors to ensure that their actions are compliant with these Terms;
in other circumstances that are directly implied by the purpose agreed between You and Strottman at the time of data collection or subsequently. Where Personal information is disclosed in this way, Strottman undertakes to exercise control over Strottman's contractors to ensure that their actions are compliant with these Terms;
with your consent, or at your request;
where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, Strottman will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
where required by a government agency or otherwise required by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Strottman believes on reasonable grounds that the disclosure of Personal information will materially assist in the protection of the life of health of some person), provided that Strottman will apply due diligence to ensure that the exercise of the permission is justifiable.

In all cases, Strottman undertakes to disclose only such of Personal information as is necessary in the particular circumstances.

Data Retention and Destruction

Subject to the qualifications immediately below, Strottman undertakes:

to retain Personal information only as long as is consistent with its purpose; and
to destroy Personal information when its purpose has expired, and to do so in such a manner that Personal information is not subsequently capable of being recovered.

This undertaking is qualified as follows:

Personal information may be retained in Strottman's logs, backups and audit trails within short-term retention cycles that are devised to protect the company's operations. In such cases, Personal information will be destroyed in accordance with those cycles;
Personal information may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Strottman:

will take any reasonable steps available to it to communicate to You that Personal information is being retained, unless it is precluded from doing so by law; and
will only retain Personal information while that provision is current, and will then destroy Personal information;

Personal information may be retained beyond the expiry of its purpose if it is authoriZed by law (in particular to protect Strottman's interests, e.g. if it believes on reasonable grounds that you have failed to fulfill your undertakings to Strottman or have committed a breach of the criminal law). In these circumstances, Strottman will only retain Personal information while that situation is current, and will then destroy Personal information.

Access by You to Your Personal Data

Strottman undertakes to provide you with access to Personal information, subject to only such conditions and processes as are reasonable in the circumstances. In particular, Strottman undertakes to enable access:

conveniently;
without unreasonable delay; and
without cost.

Strottman undertakes to establish and operate identity authentication protections for access to Personal information that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Strottman (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.

In the event that you dispute some aspect of Personal information, Strottman undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Personal information.

You undertake:

not to seek access for frivolous purposes, or unreasonably frequently;
to accept that deletion of some data may not be consistent with the provision of particular services by Strottman to you.

Information about Data-Handling Practices

Strottman undertakes to make information available to you about the manner in which Strottman handles personal information:

in general terms, in a readily accessible manner; and
in more specific terms, on request.

Where personal information is disclosed to a contractor, Strottman undertakes to make information available to you on request about the manner in which Strottman's contractors handle personal information.

Strottman undertakes to ensure that the information provided is meaningful, and addresses your concerns.

You undertake:

not to seek such information for frivolous purposes, or unreasonably frequently; and
to accept that the disclosure of excessive detail may harm the security of Personal information and Strottman's business processes, and may harm Strottman's commercial interests.

Enforcement

Strottman declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.

You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between you and Strottman, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which Strottman is domiciled or performed the relevant acts.

If you wish to discover the relevant laws in any particular jurisdiction, Strottman draws your attention to the following resources:

WorldLII Privacy Links
Compilation of [U.S.] State and Federal Privacy Laws, Privacy Journal, Providence RI
Privacy Law Sourcebook 2004, EPIC, Washington DC
the Australian Privacy Foundation's pages:

Privacy International

Changes to These Privacy Undertakings

Strottman undertakes:

not to materially change these Terms in a manner that reduces protections
to take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Personal information in a manner that reduces the protections for Personal information;
where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.