Who are we
This policy applies to all entities in the Tritium group (identified in more detail in the Scope section below.)
WHAT INFORMATION WE COLLECT AND WHY
Our Products and Services
Tritium provides electric vehicle fast (rapid) chargers and other products (‘products’) and associated services, such as support and maintenance and remote monitoring of product performance (‘services’), to Clients.
As part of supplying and maintaining these products and services, we collect Personal Information.
We collect Personal Information about our Clients (‘Client Information’), which includes both prospective and current clients, in the following circumstances:
Marketing Leads: Our sales team collects information about potential clients in a variety of ways including via social media and attendance at trade fairs and events. This may include name, email address and phone number and other relevant available information.
Contact information: If you wish to become a client, or if you are acting on behalf of a prospective client or prospective client of Tritium, we require the name, business address, email address and telephone number of relevant contacts.
Enquiries, blogs and on-line interaction: If you send us an enquiry through our website or via one of our social media websites, we may collect your name, phone number and email address. We may also collect your responses to our correspondence and to any promotions running on the website.
Credit information: Sometimes we provide credit to Clients. To do that, we may collect and hold credit information and credit eligibility information about those Clients. We may combine credit reporting information from a credit reporting body with our own information about your credit worthiness, and we may use that combined information to determine whether to offer credit to you.
We do not collect any Sensitive Information as part of providing our products or services and we ask that you and our Clients not provide us with Sensitive Information.
We also collect information about suppliers of goods or services to Tritium, including name, position, business and email addresses; and telephone numbers. This information will be treated as Client Information
We collect and retain information about Employees and the way in which they discharge their duties for us which includes:
- Employment applications: We keep copies of resumes, covering letters and applicants contact information, preferences and responses to application questions. We retain this information regardless of whether an applicant was offered a position at Tritium;
- Employment records: We keep copies of contracts and conditions of employment, including records relating to previous employment checks, character checks, security clearances, and references/referee reports;
- Job information: We create and retain records relevant to the the discharge of your duties as part of employee files including attendance and overtime records, leave applications and approvals; performance appraisals and promotion details and records relating to personal development and training. This may also include records relating to discipline matters, complaints and grievances and investigations;
- Payroll information: We collect and retain records to help us pay employees including banking details, tax file numbers declarations and superannuation details.
- Health information: We may also retain medical records and records of accidents, incidents and injuries, along with records relating to compensation and rehabilitation.
Employee Information is mostly collected directly from Employees in application and other forms they complete. It may also be collected:
- By phone or in written correspondence, including email,
- Through interviews, meetings or assessment
- From third -parties, for example, people providing reference checks.
We collect information about the performance of products we provide to Clients which information includes telemetry, component settings, and details about the way the product interacts with particular vehicles.
This information is used for diagnostics and support, for improving the quality of our products and services and in our research and development activities.
WHAT WE USE PERSONAL INFORMATION FOR
We collect and use the Personal Information to provide our Clients with products and services and in particular:
- to market our products and to enable selected third-party partners to market products and services;
- to provide our products and services in accordance with orders and manage, administer, and control their quality;
- to assist with your enquiries or complaints;
- to do research and analysis related to our products, and to develop and improve them;
- to protect our rights and property and to comply with our legal obligations; and
- any other purpose required or permitted by law.
We use Employee Information for purposes related to recruitment or employment of Employees including:
- maintaining accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
- employee performance and related processes, including disciplinary and grievance processes, to ensure acceptable conduct within the workplace, and for succession planning and workforce management purposes;
- ensuring effective general human resources and business administration;
- providing references on request for current or former employees;
- responding to and defend against legal claims.
MARKETING AND OPTING OUT
We may use and disclose your Personal Information (other than Employee Information) for marketing purposes, including to:
- identify your behaviours, habits and preferences; and
- enable different members of the Tritium Group and selected third party partners to send you product and service information directly.
If you are an individual in the EU, we will obtain your consent to use of your Personal information for marketing.
You can object to or withdraw your consent from future marketing communications from us at any time by:
- using the ‘unsubscribe’ link in any email communication; or
- contacting us by email at [email protected].
You may withdraw your consent to receiving third party marketing material at any time. Please follow the instructions in the advertising material or on our website, or email: [email protected]
LEGAL BASIS FOR PROCESSING (FOR EU DATA SUBJECTS)
If you are an individual in the EU, we collect and process information about you only where we have a legal basis for doing so under relevant EU law. The legal basis depends on the products and services you use and how you use them. This means we collect and use your information only where:
- we need it to provide you products pursuant to Client contracts, including to maintain products, provide customer support and features and to protect the safety and security of the products;
- it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote products and to protect our legal rights and interests;
- you give us consent to do so for a specific purpose, such as marketing; or
- we need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the products.
We collect Employee Information based on our legitimate interest in recruiting and managing Employees.
COOKIES, ADWORDS AND TRACKING TECHNOLOGIES
For more information about cookies, including further details as to what they are and how to refuse them please see our Cookies Policy.
For more general information about cookies, please visit: http://www.aboutcookies.org/.
GOOGLE ADWORDS SETTINGS
To help manage our website and marketing, we may use Google products such as AdWords, Google Analytics, and DoubleClick-branded services. For information about using Google Ads Settings to manage the Google ads you see, and opting out of Google Ads Personalisation, please visit: HTTPS://WWW.GOOGLE.COM/POLICIES/TECHNOLOGIES/ADS/
Links to third party websites
Our website may contain links to third-party websites and social media features (for example, Facebook and Twitter buttons and widgets). Social media features are either hosted by a third party or hosted directly on our website. We have no control over those third-party websites, and we are not responsible or liable for their content or the privacy practices applying to them.
For information about those companies’ privacy practices and how they may use your Personal Information, please visit the company websites.
ACCESS AND CORRECTION
QUALITY OF INFORMATION
We will take reasonable steps to ensure the Personal Information we hold about you is accurate, up-to-date and complete. Where relevant, we recommend that you update your own details via access to our on-line customer portal.
Please let us know if there is a change to any of the Personal Information you have given to us.
ACCESS TO PERSONAL INFORMATION
You can request access to the Personal Information Tritium holds about you at any time.
This Personal Information will usually be available within 30 days of your request (subject to allowable exemptions). We will let you know if additional time is required.
RECTIFYING CLIENT INFORMATION
You have a right to ask us to correct any inaccurate Personal Information we hold about you. We will take reasonable steps to correct your Personal Information to ensure it is accurate, up-to-date, complete, relevant and not misleading.
OTHER INDIVIDUAL RIGHTS
If you are an individual in the EU, you may be able to exercise additional rights including:
- to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
- to restrict the processing of personal data where the accuracy of the information is contested, or the processing is unlawful (but the data subject does not want the data to be erased), or where we no longer need the personal data, but the data subject requires the data to establish, exercise or defend a legal claim;
- to restrict the processing of personal data temporarily where the data subject does not think it is accurate (and we are verifying whether it is accurate), or where the data subject has objected to the processing (and we are considering whether the legitimate grounds override the data subject’s interests); and
- to object to decision making based on automated profiling.
You can exercise any of these rights by contacting us using the contact details provided below. We may require evidence of your identity when processing your request.
DATA SHARING AND INTERNATIONAL TRANSFERS
We may share your Personal Information with the following recipients:
- our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
- with third party social networks, advertising networks and websites, which usually act as separate controllers, so that we can market and advertise on third party platforms and websites;
- our third party partners who may contact you regarding their products or services;
- in individual cases, with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Any Personal Information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and/or used by others who visit these forums, depending on your account settings.
We may also disclose your Personal Information:
- to regulators and law enforcement agencies and other relevant government authorities and agencies, where legally required; and
- as otherwise required by law (e.g. in connection with subpoenas, search warrants, court orders or other legal processes).
Sharing within the Tritium Group
Companies in the Tritium Group may share or grant access to Personal Information with other companies in the group (i.e. subsidiary or affiliate companies). This is on a need-to-know basis, and where necessary to fulfil a request you have submitted via our websites, or for customer support, marketing, technical operations and account management purposes.
CROSS BORDER DISCLOSURES
Tritium may disclose Personal Information to a member of the Tritium Group or partners in other locations around the world, as necessary to provide the products. The countries to which we may transfer Personal Information include countries within Europe, the United States and Australia.
International transfers within the Tritium Group: As part of our global operations, we may transfer information to other countries where we operate and allow access to that information from countries in which members of the Tritium Group have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our Clients and users are based. When we share information about you in this way, we may make use of standard contractual data protection clauses, which have been approved by the European Commission or other contractual safeguards to protect that information.
SECURITY MEASURES BY TRITIUM
Tritium will implement and maintain appropriate technical and organisational security measures to protect against Personal Information Breaches and to preserve the security and confidentiality of Personal Information processed by Tritium. Tritium may update or modify the security measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Personal Information processed by Tritium.
NOTIFICATION OF DATA BREACH
In accordance with its obligations under Data Protection Laws, Tritium will inform the competent regulatory authority and the affected data subjects in the event of a Personal Information Data Breach affecting Individual Information.
Tritium will use reasonable endeavours to mitigate the adverse effects of any Personal Information Data Breach.
CONTACTS, ENQUIRIES AND COMPLAINTS
If you have a question or concern about how we have handled your Personal Information, or wish to exercise one of your rights, please let us know by contacting us using any of the details below.
||The Privacy Officer Tritium Pty Ltd
23 Archimedes Place,
Murarrie, QLD 4172,
Telephone: +61 2 8019 0200
email: [email protected]
We will aim to respond to all requests, complaints and other contracts within a reasonable time, usually 30 days. Tritium takes all privacy complaints seriously and our Privacy Officer aims to efficiently resolve any issue arising from a complaint.
Our Privacy Officer is our Data Protection Officer (DPO) for the purposes of the GDPR and will primarily deal with any communications with EU data protection authorities.
COMPLAINT TO THE DATA PROTECTION AUTHORITY
If you have any concerns or complaints about how we are collecting or processing your Personal Information, you can complain to your local data protection authority.
If you are in Australia, you may contact the Office of the Australian Information Commissioner: HTTPS://OAIC.GOV.AU/ (however, you must have first contacted us and given us an opportunity to resolve the issue).
If you are in the EU, please follow this link to locate the data protection authority most relevant to you: HTTP://EC.EUROPA.EU/JUSTICE/DATA-PROTECTION/ARTICLE-29/STRUCTURE/DATA-PROTECTION-AUTHORITIES/INDEX_EN.HTM.
If you are in the US and are unsatisfied with how we resolve your complaint, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us to we will endeavour to provide additional information about who to contact to do this.
- Tritium Holdings Pty Ltd ABN 55 145 324 910;
- Tritium Pty Ltd ABN 75 095 500 280;
- Tritium America Corporation (a Delaware Company) EIN 36-4851036;
- Tritium Technologies LLC (a Delaware Company) EIN 30-095 5575;
- Tritium Europe B.V. Trade Register No. 68864906;
- Tritium Technologies B.V. Trade Register No. 68870795; and
- All subsidiary and affiliate companies (collectively “Tritium”, “we”, “us”, “our” and “Tritium Group”).
In this policy:
EU includes all EU member states and the members of the European Economic Area (Iceland, Lichtenstein and Norway).
Client includes all users of any of our services, any prospective clients, suppliers and other third parties who we may deal with, individuals who may contact us by phone or email and other visitors to our website.
Data Protection Law means the Privacy Act 1988 (Cth) and, if the context so requires, the GDPR or relevant US privacy laws.
Employee includes prospective employees, past and present employees, part time and casual workers, contractors and volunteers.
GDPR means Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation).
Personal Information has the same meaning as defined in the Data Protection Law.
Personal Information Data Breach has the same meaning as ‘eligible data breach’ in the Data Protection Law.
Sensitive Data has the meaning given to it in the Data Protection Law.
Sub-processor means any third party entity engaged by Tritium to processes Personal Information.
Website means our website WWW.TRITIUM.COM.AU and our other websites.
ACCESS TO POLICY
If you have any queries about Tritium’s privacy practices, please contact our Privacy Officer by emailing [email protected] or telephoning +61 7 3147 8500.
Policy last updated: August 2018