1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data.

TXM Lean Solutions collects and holds personal information from clients, customers, employees, contractors and other individuals. We collect and hold this information when it is necessary for business purposes.

The personal information TXM Lean Solutions collects and holds relates to the contact details and organisational roles of our clients, suppliers and other business contacts. Generally, this information includes names, addresses, telephone numbers, e-mail addresses and job titles.

TXM has an E-store on its website which enables purchase of TXM products. This transaction when done over the telephone requires TXM to obtain credit card information. Upon completion of the transaction the credit card details are shredded.

We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face to face meetings, email messages, telephone conversations or by third parties. If you contact us, we may keep a record of that contact.

Our email address is admin@txm.com

Our postal address is 211/134 Cambridge Street, Collingwood, Vic 3066, Australia.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Australian Office of the Information Commissioner (www.oaic.gov.au) or the UK Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)

If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us at admin@txm.com and we will try to resolve those concerns.

If you wish to have your personal information deleted, please let us know in writing at TXM Lean Solutions, 211/134 Cambridge Street, Collingwood, Vic 3066, Australia and we will take reasonable steps to delete it (unless we need to keep it for legal or auditing purposes.)

 

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

 

2. HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at admin@txm.com

 

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at admin@txm.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

 

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b) Necessary to comply with a legal obligation

 

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests to develop our products/services and grow our business

 

 

Marketing communications 

You will receive marketing communications from us if you have:

  • requested information from us or purchased goods or services from us; or
  • if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
  • in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at admin@txm.com at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

3. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities based in the Australia, Europe and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.
  • To keep clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars and other events we are holding
  • To maintain contact with clients
  • For purposes related to the employment of our personnel and providing internal services to our staff
  • For recruitment purposes

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

4. INTERNATIONAL TRANSFERS

TXM Lean Solutions has offices in China, United Kingdom, France and America. As part of TXM Lean Solutions business operations exchanges of information may occur, including personal information, between TXM’s international office sites. As a result, we may transfer personal information outside Australia to countries whose privacy laws do not provide the same level of protection as Australia’s. TXM Lean Solutions may also use overseas facilities or contractors to process or back-up our information or to provide certain services to us. As a result, we or another TXM Lean Solutions international office may transfer your personal information to our overseas facilities or contractors for these purposes.

However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.

 

Privacy on our Websites and Applications

This policy also applies to any personal information we collect via our websites, including txm.com and applications including mobile applications. In addition to personal information you provide to us directly (such as where you make a request or complete a registration form), TXM lean Solutions may also collect personal information from you via its applications and websites.

Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.

Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page. Alternatively you can opt out of a third party vendor’s use of cookies by visiting the Network Advertising Initiative.
We use Cookies for the purposes of conducting re-marketing Campaigns. Google’s Display Network use the DoubleClick Cookie. You can opt out of DoubleClick cookies by visiting the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.

In order to properly manage our websites and applications, we may log certain statistics about the users of the facilities, for example the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites and applications present the best possible navigational experience for users.

As TXM Lean Solutions wants your user experience to be as informative and resourceful as possible, we provide a number of links to websites and embedded content operated by third parties that may also set cookies. TXM lean Solutions is not responsible for the privacy practices or policies of those sites. We encourage you to review each website’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non TXM Lean Solutions website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.

If you are located in the European Economic Area, you need to be aware that we share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at admin@txm.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

5. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have the right under data protection laws to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at admin@txm.com

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.