Privacy Policy Statement

1. Introduction

We are the TNA Australia Group of companies (Group), which is known as tna Solutions (tna). This privacy notice is to let you know how we promise to look after your personal information. This notice explains how we do this and tells you about your privacy rights and how the law protects you. For information about our cookie policy and the cookies we place on computers please look at our cookie statement.

tna is a world leader in packaging and processing solutions for food manufacturers. Our head office is located at:

    • 24 Carter Street, Sydney Olympic Park
    • Sydney, NSW 2127
    • Australia

We operate globally with offices throughout Asia Pacific, the Middle East, Africa, Russia, Europe and the Americas. You can find out more about us at www.tnasolutions.com.

If you have any questions or want more details about how we use your personal information, please let us know. See the ‘how to contact us’ section below for the different ways you can get in touch with us.

2. Protection of your personal information

Personal information is information or an opinion that can be used to identify an individual. Customers, suppliers and business associates are entitled to expect tna to treat their personal information with due care. tna has developed a privacy policy that is in line with the (European) General Data Protection Regulation (GDPR) as well as with the Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APPs)(together the relevant privacy legislation). tna’s privacy policy is implemented through agreements, rules of conduct and (security) measures. We take appropriate steps to ensure that personal information that we collect, use or disclose is accurate, up to date, complete and relevant.

At tna we implement the relevant privacy legislation throughout the Group. It does not matter whether you contact us while living in Europe, Asia Pacific, Australia, the Americas, the Middle East, Russia or Africa, we apply these privacy rights to everybody.

Information concerning the Privacy Act and the APPs can be obtained from the Office of the Australian Information Commissioner.

Information concerning the GDPR can be obtained from the office of each national privacy authority of European Member States. For your convenience we have listed several of these.

3. Personal Information

tna processes the following personal information:

    1. IP Address
    2. Website behavior
    3. Information entered in our forms
    4. Contact history
    5. Name
    6. Address information
    7. Email address
    8. Telephone numbers
    9. Account information
    10. The company you work for, and your position
    11. Other information that you provide to us

4. Purposes

Generally, tna will only collect personal information when it is provided voluntarily by an individual such as when you fill in a form to subscribe to our newsletters or send a request to tna for information about our products or services. We will only collect sensitive information with your consent or if we are required to under relevant privacy legislation. We will only collect personal information about an individual directly from the individual unless it is unreasonable or impracticable to do so. If we collect personal information about an individual from another person without the individual’s knowledge or from publicly available sources, we will take reasonable steps to notify the individual that we have collected the information and the circumstances of its collection.

tna processes this personal information for various purposes, such as:

    1. Performance of contracts with tna’s suppliers and customers
    2. Good and efficient service provision and business operations
    3. Performing administrative acts
    4. Customer relationship management
    5. Improving service to its customers
    6. Billing
    7. Collecting funds and taking collection measures
    8. Marketing
    9. Fulfilling legal obligations
    10. Litigation

Although you are able to visit and use tna’s website anonymously, if you wish to take advantage of some of the services that are offered through the website then you may need to provide personal information to us (e.g. in our contact forms).

When you deal with tna you also have the option of using a pseudonym unless tna is required, or authorized, under relevant privacy legislation or a court or tribunal order to only deal with individuals who have identified themselves or it is impracticable for tna to deal with individuals who have not identified themselves or who have used a pseudonym.

5. Principles

tna only uses personal information on the basis of legal processing grounds. For example:

    1. tna may use your personal information for the performance of a contract between you and tna.
    2. tna may process certain personal information in order to comply with a legal obligation. For example, tna is subject to a number of statutory obligations in its business operations, such as verifying the identity of individuals in the context of money laundering and terrorist financing laws.
    3. If personal information is processed on the basis of permission, this will be requested separately at the moment the data is given to tna.
    4. tna may process personal information on the basis of legitimate interest.

6. Overview of personal information collected

Personal information

Purpose

Legal basis

Storage duration

1. IP Address

Marketing

Consent

For as long as there is a business relation with tna.

2. Website behavior

Improving service

Legitimate interest

3. Data entered in our forms

Improving service, marketing

Consent, Legitimate interest

4. Contact history

Administrative acts

Performance of a contract

5. Name

Administrative acts

Performance of a contract, legal obligation

6. Address data

Maintaining contact

Performance of a contract, legal obligation

7. Email address

Maintaining contact

Performance of a contract

8. Telephone number/s

Maintaining contact

Performance of a contract

9. Account data

Performance of contracts

Performance of a contract

10. The company you work for, and your position

Customer relationship management

Legitimate interest.

11. Other information that you provide to us

Customer relationship management

Consent, Legitimate interest


7. Provision to third parties

tna may exchange personal information as part of its services. tna may use third parties for these purposes, such as the IT suppliers of our website and systems, organizations for archive management, specialized advisors and other service providers, logistics or original equipment manufacturers. In this context, personal information will be provided to these third parties who may only process personal information for these purposes and not for their own purposes. tna only makes use of third party services if they comply with relevant privacy legislation.

Personal information may also be provided to third parties if tna is required to comply with a legal obligation. This may be the case, for example, with inspections by tax or customs administrations or other government watchdog agencies. If third parties must or may have access to your personal information, a processing agreement will be concluded, where necessary, in which agreements will be laid down that guarantee the correct and safe processing and confidentiality of your personal information. This happens in the European Economic Area (EEA) and Australia as well as outside the EEA and Australia.

8. Provision to other Group members and data transfer outside the EEA

Personal information may be transferred across borders to other members of the Group or to third parties for the purposes described in Chapter 4. This may also mean that personal information may be transferred to countries or regions without legislation protecting personal information equivalent to that enjoyed by visitors to tna’s website in their country of origin. In such cases, tna will take appropriate measures in each case, so that in a situation in which such a transfer of data takes place, such a transfer of data will always take place in a way that provides an “adequate level of protection”. This is done by making processing agreements with the third parties involved.

9. How tna secures your data

tna believes it is important that your personal information is protected against loss or unauthorized access. tna has therefore taken appropriate security measures at a level that is necessary in view of the nature and volume of the personal information that is processed. Furthermore, all tna employees have a duty of confidentiality and are only allowed to process personal information as required for their work.

tna employs the following security measures:

    • user based access control;
    • multiple factor device authentication;
    • industry leading data and privacy protection services;
    • user authentication;
    • virus and threat detection;
    • live and pre-delivery scanning of documents;
    • public credential leak monitoring.

10. Data breach

Despite all technical and organizational security measures, a data breach can never be completely ruled out. Accordingly, tna has set up a dedicated email address that allows individuals to report incidents that may involve a data breach.

You can e-mail our Privacy Officer to report a data breach at: [email protected]
As required by relevant privacy legislation, any data breach that could have serious consequences for individuals will be reported to the relevant Privacy Authority and, if required, to the individuals whose personal information is involved in the data breach.

11. How long tna stores your data

tna will not process your personal information for longer than is necessary for the purposes stated in this privacy statement. This means that your personal information will be kept for as long as it is needed to achieve the purposes in question. Certain data must be kept longer, because tna has to comply with legal retention obligations, such as the retention obligation for tax purposes. For a complete list refer to chapter 6 above.

12. Your rights

At tna , all of your rights as a data subject under relevant privacy legislation are honored by tna. These rights are explained below.

    • Information
      You have the right to be informed of the existence and purpose of processing before your personal information is processed by tna.
    • Access
      If you think that tna is processing your personal information you may request confirmation from us in which case we will notify you whether or not tna is processing your personal information and inform you about the purpose(s) for which your personal information is used.
    • Rectification or erasure of data
      If it appears that personal information that tna processes is not (completely) correct, you can request rectification. You can also ask tna to delete your data In which case tna will implement the request unless there are compelling reasons, such as legal obstacles, for not doing so. tna will inform you whether or not a rectification or data erasure has been made.
    • Restriction and objections
      You always have the right, due to your specific situation, to object to the processing of your personal information and to request tna to restrict or discontinue the processing. If there are no compelling obstacles, such as legal obstacles, tna will comply with your request and notify you of our decision.
    • Right to object to Automated decision making
      At tna personal information is not subject to automated decision making.
    • Right to Data Portability
      You have the right to obtain and reuse your personal information for your own purposes across different services.

If you wish to exercise your rights, you may submit a written request to us (at the contact details below) or by email to our Privacy Officer at: [email protected]

tna will respond to your request as soon as possible and you will receive an answer no later than 30 days from receipt of your request.

To identify you with regards to exercising your rights we may need a copy of your identification card, passport or driver’s license which has the following information blocked out by you.

    • State issued ID number
    • Your signature
    • Any photograph of you
    • Document number
    • Any machine-readable code

We also ask that you write the date of sending + the name of tna on the card, passport, or driver’s license. The ID card or passport will then look like this):

13. Questions – complaints

If you have a question or complaint about the processing of your personal information by tna, please contact us. We will respond to your question or complaint as soon as possible, but at the latest within 30 days of receipt.

14. National Data Protection Authority

You also have the right to lodge a complaint with your national privacy regulator in the country you live in.

15. Changes to the privacy policy

tna may amend this privacy statement at any time with the latest revision made on the 1st June 2020. New versions are always published on the website. tna recommends that you periodically review this statement to ensure that you are kept informed of any changes.

16. How to contact us

If you have any questions about how we use your personal information, please let us know. We’ve provided a few different ways for you to do this, so please pick the one you would prefer to use:

Email:

[email protected]

Telephone:

+61-2-9714-2300

Address:

24 Carter Street
Sydney Olympic Park
N.S.W. 2127
Australia