The last update to this document was 20 December 2021.

Introduction

Navia Pty Ltd ACN 105 752 921 (Navia, we, us, our) and its related entities are committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business.

Please take a moment to read our Privacy Policy as it explains how we manage personal information, including our obligations and your rights in respect of our dealings with your personal information.

We may, in connection with particular goods or services we offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those other disclosures, the other disclosures will apply. Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices.

This Privacy Policy (other than section 10) explains how we manage personal information about individuals other than our employees. Section 10 explains the position of employees.

Key definitions

In this document:

• “APPs” means the Australia Privacy Principles set out in the Privacy Act;
• “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
• “Privacy Act” means the Privacy Act 1988 (Cth); and
• “sensitive information” has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.

 

1. How we collect your personal information

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.

Some of the common ways in which we may receive personal information directly from you include:

• when you make an inquiry or order in relation to our goods or services, including through your use of our website located at naviafreight.com (the Website);
• when you access and use our online platform Navia Hub at naviahub.com (the Platform);
• when you engage us to provide goods or services;
• when you subscribe to any newsletters, updates or alerts or otherwise complete and submit any forms to us;
• when you apply for a role with us;
• from correspondence (whether in writing or electronically) or when you contact us via telephone, the Platform, our social media pages or other means;
• when you upload content to or interact (in an identifiable manner) with our Website, our Platform or our social media pages;
• when you use any mobile applications provided by our organisation;
• when you participate in our customer satisfaction and market research surveys;
• if you attend any of our premises, we may record certain contact details and health information (such as details of your COVID-19 vaccination status) so that we can comply with applicable laws, and we may also record your image and/or voice if we have surveillance systems operating at those premises; and
• as otherwise required to manage our business.

Where it is reasonably practical to do so, we will collect personal information that we need about you directly from you.  However, in certain cases we may collect personal information from publically available sources and third parties, such as suppliers, recruitment agencies, your employers, contractors, our clients, business partners, referees, government bodies (e.g. police checks, if required), academic and professional bodies (e.g. to validate details and currency of qualifications).

We provide freight forwarding and logistics services to assist our clients with managing the shipping and transport of their cargo, their inventory and their supply chains.  Our clients may provide us with shipping information (such as pickup and delivery addresses) and other documents that contain personal information about their customers for this purpose.  If you are a customer of a business that uses our services, we may receive certain personal information about you in this context.

If we collect personal information about you from one of our clients or another third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

2. Types of personal information we collect

The types of personal information we collect about you will depend on the circumstances in which the information is collected. Typically, the types of personal information we may collect can include (but is not limited to) name, address, email address and phone numbers.

If we enter into contracts with you, request or receive goods or services from us or have any other commercial dealings with us, we may also collect your signature, date of birth, credit card and /or banking details, and billing information.

In the course of providing our freight forwarding and logistics services for our clients, we also receive and handle shipping information, insurance claim information and other documents that contain personal information.

If you are an individual contractor to us or apply for a role with us, we may also collect information relevant to your engagement with us including qualifications, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).

If you attend a premises we operate or manage, we may:

• collect certain contact details that you provide to us (which may be via digital check-in apps), including the date and time of attendance, including so that we can comply with applicable laws (such as public health directives). If we collect such information to comply with a particular law, we will only use and disclose it in accordance with applicable laws; and
• record your image and/or voice through the use of Closed-Circuit Television (CCTV) systems footage of you via our CCTV devices, for the purposes of managing security of the premises and health and safety of occupants and the public generally.

If you call us via telephone, we may monitor and in some cases record such telephone conversations for staff training, quality assurance and record-keeping purposes.

If we have or in the future make available any mobile applications for you to download and use, we may:

• record details of your device details and operating systems; and
• if you have provided us with permission to access your device location when using our app, we may collect information about your geographical location.

If you access our Website, Platform or mobile apps, we may utilise cookies to collect additional information about your use of our Website, Platform and apps.

If when you are on our Website, our Platform or our apps and you have provided us with permission to access your device location, we may collect information about your geographical location.

If we communicate with you by email, we may use technology to identify you so that it will be in position to know when you have opened the email or clicked on a link in the email.

We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. The main types of sensitive information we may collect include:

• certain health information (such as information about your COVID-19 vaccination status) where it is necessary for us to manage our workplace health and safety program and/or comply with government directions and public health orders;
• details of injuries (i.e. health information) that may occur on our premises;
• details of disabilities or allergies (i.e. health information) you notify us of for a particular purpose (e.g. so that we can accommodate any special requirements when you attend our premises); and
• details of your membership of professional associations and affiliations with relevant industry bodies or organisations and/or other types of sensitive information, where this is relevant to our business dealings or employment relationship with you (including as part of our recruitment process when you apply for a job vacancy with us).

If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.

In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.

Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services and/or certain functionality of our Website or the Platform.

3. Our purposes for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it.

Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.

We may use or disclose your personal information:

• for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
• for other purposes to which you have consented; and
• as otherwise authorised or required by law.

In general we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.

Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:

• to provide you with our goods and services (including freight forwarding services, customs consultancy services, logistics services and e-commerce services);
• to provide you with updates and information relating to your cargo including dispatch and tracking information;
• to provide you with access to and use of the Platform;
• to receive goods or services from you;
• to consider you for a job (whether as an employee or contractor) or other relationships with us;
• to provide you with tax invoices for our goods and services;
• to operate, monitor, develop and improve our Website, Platform mobile applications and our goods and services;
• to verify your identity;
• to optimise and customise the user experience (including content and advertising) for users of the Websites, mobile applications and services;
• to facilitate communications via our Website, Platform, apps and our social media pages, including communications with us or with other users of those platforms via direct messaging and posting to forums;
• where you have provided us with access to your geographical location via our Website, our Platform or any of our mobile applications, we may send you push notifications and other electronic communications (including SMS) for purposes including to provide updates on your cargo;
• to facilitate your entry and participation in a competition or trade promotion;
• to protect the security and integrity of the Website, the Platform and our other websites, mobile applications and services;
• to develop and improve our Website, the Platform and our goods and services;
• to contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our goods and services;
• to comply with our legal and regulatory obligations;
• to protect the security, health and safety of our premises, facilities, personnel and visitors;
• to address any issues or complaints that we or you have regarding our relationship; and
• to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

4. Who we disclose your personal information to

We may disclose your personal information to third parties in connection with the purposes described in section 3 of this Privacy Policy.  This may include disclosing your personal information to the following types of third parties:

• the suppliers, contractors and partners that we work with to deliver our integrated freight forwarding and third party logistics services (including carriers, transportation providers, warehousing providers, customs brokers and others);
• relevant government authorities in Australia and other countries (including local customs and border protection);
• organisations that provide us with technical and support services or who manage some of our business functions;
• our related entities (who may use and disclose the information in the same manner we can);
• our accountants, insurers, lawyers, auditors and other professional advisers;
• any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees); and
• in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors.

We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.

If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

If you post information to certain public parts of our Website, Platform or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.

5. Protection of personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.  We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

6. Direct marketing

Like most businesses, marketing is important to our continued success.  We therefore like to stay in touch with customers and let them know about new offers and opportunities.  We may provide you with information about products, services and promotions either from us, or from third parties which may be of interest to you, where:

• you have consented to us doing so; or
• it is otherwise permitted by law.

You may opt out at any time if you no longer wish to receive direct marketing messages from us.  You can make this request by contacting our Privacy Officer.

7. Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time.  We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website.  This information will help to better adapt the Website to suit personal requirements.  While cookies allow a computer to be identified, they do not permit any reference to a specific individual.  For information on cookie settings of your internet browser, please refer to your browser’s manual.

We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Website and other internet activity.  We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Website.

Please see our cookies policy (available at Navia Freight Cookie Policy (windows.net)) for further details of the types of information collected and how you can control what information is collected.

8. Accessing and correcting your personal information

You may contact our Privacy Officer (see section 12) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time.  On the rare occasions when we refuse access (which we will only do in accordance with applicable laws), we will provide you with a written notice stating our reasons for refusing access.  We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so.  If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

9. Overseas transfers of personal information

We are an international business that is headquartered in Australia with branches in New Zealand, the United States, Malaysia and Hungary.

We provide international freight services for our clients, and this requires us to work with various transportation partners and government authorities in the origin and destination countries (as well as intermediate locations) in order to manage the shipping and delivery of the cargo.  We may provide information to these partners and authorities (including personal information) where it is necessary for the shipping process.

In the ordinary course of operating our business we may also share your personal information within the Navia group of companies, which may involve transferring your data to locations outside of Australia.  Our external third party service providers may be located, or have servers, in a number of different countries, so your personal information may be transferred, processed and stored outside of Australia.

The countries in which such Navia group companies and third party service providers are located may depend on the circumstances and the purpose of the transfer.  Such overseas recipients provide billing, payment, IT and other administrative services to us (including offshore data hosting and processing, data analytics, help desk and data-entry).

Countries to which we commonly send personal information (in the ordinary course of business) include Singapore and the Philippines, where certain members of our in-house IT support and development team (working under direction from our Australian headquarters) are based.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures.  For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

We may also disclose your personal information to overseas recipient without your consent where permitted by the Privacy Act (and, in such circumstances, we will comply with the applicable requirements of the Privacy Act in doing so).

10. Employees

We collect information in relation to employees as part of their application and during the course of their employment, either from them or in some cases from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications).  Such information may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).

Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship.  We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.

11. Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy or how we handle your personal information, including if you believe we have breached the APPs, please contact our Privacy Officer (see section 12).

When contacting us please provide as much detail as possible in relation to your question, concern or complaint.

We take all complaints seriously, and will respond to your complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218, Sydney  NSW  2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

12. Contact details of Privacy Officer

The contact details for our Privacy Officer are as follows:

Postal address: 54 Concorde Drive, Keilor Park, VIC 3034

Telephone: +61 3 9331 5715

Email: brendanb@naviafreight.com

13. Links

Our Website may contain links to other websites operated by third parties.  We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.  Third party websites are responsible for informing you about their own privacy practices and procedures.

14. Changes

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Website.