privacy policy
1. Introduction
TNA Australia PTY LTD. and its affiliates (hereafter “TNA”, “we” and/or “TNA Group”) is a global leader in food processing and packaging solutions.
At TNA Group, we understand that your privacy is important to you and that you care about how information relating to you (“Personal Data”) is used. TNA Group is committed to ensuring the privacy and security of the Personal Data it processes from customers, vendors, employees, and other individuals, and to protect their rights in accordance with our obligations under applicable Privacy and Data Protection laws across the globe.
This privacy notice aims to give you information about how TNA collects and process your Personal Data, tell you about your privacy rights and how to exercise them. For information about our cookie policy and the cookies we place on computers please look at our cookie statement available on our website(s).
2. Protection of your Personal Data
Personal Data is any information that can be used to identify an individual. Customers, suppliers, employees, business associates and other individuals are entitled to expect TNA to treat their personal information with due care. At TNA Group, we implement the relevant privacy legislation throughout. It does not matter whether you contact us while living in Europe, Asia, Australia, the Americas, Africa or Antarctica, we apply these privacy rights to everybody.
TNA’s privacy notice 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.
3. Personal Data that we collect
We may collect Personal Data directly from you or from other sources. The Personal Data we collect directly from you may include data such as identifiers, contact details, professional or employment-related data, financial account data, commercial data, visual data, and internet activity data, as well as any other data you choose to provide us. We may collect such information, for example, in the following situations:
| Situation | Categories of Personal Data |
| If you express an interest in obtaining additional information about our Products; communicate with us via a phone call, e-mail address; visit our offices; use our contact for or similar features; register to receive communications, newsletters; sign up for an event or webinar; participate in a survey (e.g., customer satisfaction); use our Services; or otherwise communicate with us. | Contact information, such as your name, job title, company name, address, phone number, email address, other information voluntarily chosen to share with us. |
| If you attend an event | Attendee contact details which may include name, title, company name, address, country, phone number and email address, image and video. |
| If you visit our Website or interact with us via social media | Information about your device and your usage of our Websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data using cookies, web beacons, or similar technologies, any information you choose to share with us. |
| If you use our Services/ customer portals | Name, business contact details like e-mail and business address, job title, company name, phone number, financial company bank account, transaction information, e-mails that might contain personal information, information about the company you work for, position and any other information voluntarily chosen to share with us. |
| If you are a supplier or service provider to TNA (or work for a supplier or service provider) | Contact information, payment and billing information. |
| If you apply through our career portal, LinkedIn accounts or you apply for a vacancy through our email address. | Name, contact details, professional background, and all the job-related information that you voluntarily choose to provide to us. |
Although you are able to visit and use TNA’s website anonymously, if you wish to get further information through the website, then you may need to provide personal information to TNA (e.g. in our contact forms).
When you deal with TNA’s website 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.
If you provide us Personal Data relating to other individuals (e.g., individuals working for a client, an affiliate or a service provider), you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Notice. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information below.
Personal Data we collect from other sources
From the Products / from our Customers / Vendors: We receive and store your data, or your company provided directly to us, to satisfy customer contract obligations. For example, when setting up new customers for our Products, we collect Personal Data, such as name and e-mail address, to provide our clients with the Products and related services. The types of information we may collect directly from our customers and their users include names, usernames, email addresses, postal addresses, phone numbers, job titles, transactional information, as well as other contact or other information they choose to provide us or upload to our systems in connection with the products and related services. Other personal information we process may vary depending on the requirements specified in customer contracts. In those cases, we assume that those entities have the authority to do so and that you have obtained appropriate consent where necessary.
4. Purposes and legal basis for processing your Personal Data:
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 collect and process your Personal Data for the following purposes and relying on the following legal basis:
| Purpose | Description | Legal Basis |
| Providing and improving our Websites (including our social media pages) | We process your Personal Data to operate and administer our Websites and to provide you with the content you access and request. We process your Personal Data to analyze overall trends and help us improve the user experience on our websites. | Our legitimate interest in providing relevant online content and well-functioning Websites to our customers and prospective customers regarding our service offering and related information |
| Displaying personalized interactions, advertisements, and content | We process your Personal Data to conduct market research, advertise to you, provide personalized information about us on and off our Websites and to provide other personalized content and interactions with you based upon your activities and interests. | Our legitimate interest in providing best-in-class Services to our customers, including advertising our Services or, where necessary, to the extent you have provided your prior consent |
| Registering visitors to our premises | We process your Personal Data in our registration form for security reasons | Our legitimate interest in protecting our offices, staff, visitors and our confidential information against unauthorized access |
| Managing event and webinar registrations | We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you | (i) Your consent when providing us the information; (ii) Our legitimate interest in providing Services requested by individuals or companies |
| Sending communications, | We process your Personal Data to send you marketing information, product recommendations and other non-transactional communications | Your consent to receive direct marketing from us. |
| Recording phone calls, webinars. | We process your Personal Data, including recording phone calls (in accordance with applicable laws) for quality assurance, and administration purposes | Consent or our legitimate interest in maintaining the high quality of our phone calls with customers |
| Handling contacts and user support requests, | We process your Personal Data, if you request user support, or if you contact us by other means including but not limited to via phone | Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you. |
| Providing, developing and optimizing the performance of the Services | We process your Personal Data to develop, optimize, provision, and improve the performance of the Services and to satisfy our obligations under the applicable terms of use | Our legitimate interest to provide and administer our Services in line with customer expectations Where applicable, compliance with legal obligations incumbent on us. |
| Managing our customer and user accounts | We process your Personal Data (including Usage Data) to manage customer and user accounts generally, such as billing, customer correspondence, customer relationship management, and maintaining your user account in our portal. | Our legitimate interest in the management of customer and user accounts or Performance of a contract depending on the situation. |
| Managing usage compliance | We process your Personal Data (including Usage Data) to assess and manage usage compliance with the applicable terms of use of our Services | Our legitimate interest in managing the provision of our Services to customers |
| Maintaining our security | We process your Personal Data (including your Usage Data) for the purposes of maintaining TNA’s own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect TNA or its Services | Our legitimate interest in promoting the safety and security of TNA generally and to protect our rights and the rights of others |
| Managing job applications | We process your Personal Data (including your Usage Data) for in relation to the position you apply for. The purpose of talent acquisition, including assessing capabilities, reference checks. | Performance of a contract or our Legitimate interest to hire qualified employees and for our administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business. |
| Undertaking financial reporting, managing payments, Preparing internal reports, and business modelling | We process your Personal Data (including your Usage Data) for the purposes of financial reporting, modelling purposes (e.g., forecasting), and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you. | Performance of a contract or Our legitimate interest in meeting our obligations associated with the reporting of our finances, management of our business operations, and necessary for the performance of a contract. |
| Aggregating data | We process your Personal Data (including your Usage and Cookie Data) for the purposes of aggregating this information to ensure that it is no longer identifying you. | Our legitimate interest in minimizing the amount of Personal Data processed as part of the noted processing activity |
| Other information that you provide to us | Customer management, job applications, and others | Consent or legitimate interest. |
| Complying with legal obligations | We process your Personal Data (including Usage Data) when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights | Legal obligation incumbent on TNA, like a law enforcement or national security request, to establish, exercise or defend legal claims, or our legitimate interest in protecting against misuse or abuse of our Websites or Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes. |
5. Principles
TNA only uses Personal Data on the basis of legal processing grounds. For example:
- TNA may use your Personal Data for the performance of a contract between you and TNA.
- TNA may process certain Personal Data 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.
- If Personal Data is processed on the basis of permission, this will be requested separately at the moment the data is given to TNA.
- TNA may process Personal Data on the basis of legitimate interest.
6. Disclosure of Personal Data to third parties:
TNA may share Personal Data with service providers or other third parties that carry out functions or services in our behalf or that assist or enable our operations. These service providers may include hosting, email and collaboration service providers website analytics companies, freelancers, product feedback or help desk/customer support and CRM service providers head-hunters, the website in which you submitted your employment application (if applicable), travel agencies and travel service providers, payrolling vendor, scheduling programs and IT processing systems. In this context, Personal Data 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. Please note that these service providers will only access your Personal Data on an “if needed” basis as a part of their partnerships with us. Where necessary and in accordance with the local regulations, agreements that guarantee the correct and safe processing and confidentiality of your personal information will be implemented.
7. Provision to other Group members and data transfer outside the territory
Personal Data may be transferred across borders to other members of the Group or to third parties for the purposes described above (see section 4). This may also mean that Personal Data 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.
8. Security
TNA takes appropriate precautions including organizational, technical, and physical security measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use. Furthermore, all TNA employees have a duty of confidentiality and are only allowed to process personal information as required for their work.
Although TNA has implemented appropriate technical and security measures to protect Personal Data, a data breach can never be completely ruled out since TNA may rely on the use of different security systems including the system you are using to communicate with us. You are solely responsible for the information you exchange with us through any of our channels as well as protecting your password, limiting access to your devices, maintaining up-to-date and patched version of software and operating systems, and signing out of our Website after your sessions.
9. Retention and Storage
TNA will not process your Personal Data for longer than is necessary for the purposes stated in this Privacy Notice. This means that your personal information will be kept for as long as it is needed to achieve the purposes for which is processed. Certain data must be kept longer, because TNA has to comply with legal obligations, such as the retention obligation for tax purposes.
After the applicable retention periods expire, your personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
The majority of the Personal Data that we collect is held on our servers located in Australia. This may vary depending on the location of our affiliates. In any case, TNA seeks to store data in accordance with the different local regulations and implement the appropriate safeguards.
10. 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 Data 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 Data is used.
- Rectification or erasure of Personal 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 not be subject to a decision based solely on automated processing and profiling, which produces legal effects 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]
Your Personal Data will be processed when responding to these rights requests or any complaint that you may have regarding the processing of your personal data. We may request your additional documentation to verify your identity before fulfilling your request. The appropriate course of action for confirming someone’s identity may vary depending on the situation. We will only collect the bare minimum of personal data required to verify an individual’s identification and this will be informed to you in due course.
We will respond to your request or complaint as soon as possible and you will receive an answer no later than 30 days from receipt of your request. The response time may vary according to your location and applicable regulations. If we are unable to comply with your request due to an exception or limitation, we will explain this in writing. If we need more time, we will inform you of the reason and extension period in writing.
Should you have concerns about your privacy rights or should you feel unsatisfied with our treatment, collection, or use of your Personal Data, we remind you that you have a right to lodge a complaint with your local supervisory authority.
11. Changes to the privacy notice
TNA may amend this privacy notice at any time with the latest revision made on January 2024. New versions are always published on the website. TNA recommends that you periodically review this notice to ensure that you are kept informed of any changes.
12. How to contact us
If you have any questions about how we use your personal information, please contact us. 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 |
If you are located in Europe, our Data Protection Representative can also be contacted through the email address mentioned above.