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Privacy Statement

ICON Asia-Pacific Limited trading as ICON
ABN 42 662 357 804

Privacy Policy

1 About this policy
This section explains how to read this policy and describes its purpose.  

1.1 Interpretation of this document and general overview
Defining specific terms:

  • “ICON” means ICON Asia-Pacific Limited. 
  • “Privacy information” includes personal information and sensitive information.
  • “Personal information” includes information that is capable of identifying an individual such as name, address and date of birth.
  • “Sensitive information” includes information relating to health or religion, racial or ethnic origin. 
  • “We”, “us” and “our” refer to ICON.
  • “APPs” refer to the Australian Privacy Principles in the Privacy Act 1988 (Cth).
In respect of the collection, use and disclosure of Privacy Information, ICON is subject to the Australian Privacy Principles as laid out in the Privacy Act. All personal information received on behalf of ICON is at all times respected, including the protection and security of all personal records.

1.2 Purpose of this policy
The ICON Privacy Policy explains how our organisation protects your privacy information. Our Privacy Policy lays down the principles by which we collect, store, use and disclose any privacy information you provide to us or we collect from other sources.

Our Privacy Policy also informs members, members, prospective members, stakeholders and anyone else whose privacy information is protected in dealing with ICON, about how they can access their privacy information, correct privacy information held by us, lodge complaints or make any related enquiry.

2 Type of information we collect and hold

2.1 ICON collects information about people, mainly about members and prospective members, which falls into two categories of privacy information under the Privacy Act - personal information and sensitive information. 

We need this information to deliver necessary and effective services to all our members and to understand and forecast our business. 

2.2 For members of, or prospective members of, ICON collects:  

  • name, address, telephone number, email address, job title;
  • gender; 
  • Place of employment;
  • banking details, credit card details; (this information is not stored)
2.3 We may also collect information about you from your access to our website for statistical purposes.  This information is usually anonymous and we do not use it to identify individuals.  However, due to the nature of internet protocols, such information might contain details that identify you, such as your IP address, internet service provider, the web page directing you and your activity on our website. 

3 How we collect your information 
We may collect privacy information from people through our marketing, business development, operational, human resources, research or other activities. 

We have a general policy to collect privacy information directly from you, unless it is unreasonable or impracticable to do so. 

We collect data from our website using various technologies, including “cookies”.  Put simply, a “cookie” is a text file that our website sends to your browser which is stored on your computer as an anonymous tag identifying your computer (but not you) to us.  You can set your browser to disable cookies.  However, some parts of our website may not function properly (or at all) if cookies are disabled.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through ICON public message boards, this information may be collected and used by others. 

Note: ICON does not read any of your private online communications.

We will need your written consent to collect sensitive information about you.

3.1 Members and prospective members 
We may collect information from you in;

  • an agreement you enter with us; 
  • an order form, application or other form you complete and submit to us;
  • a telephone or in-person inquiry or discussion about our, services and accounts;
  • mail correspondence, emails or other electronic means (including by accessing our website and use of the "contact us" form);
  • third parties or your representatives; and
  • publicly available sources of information.

3.2 Prospective employees 

We collect privacy information from:

  • the individual; 
  • referees proposed by the individual; 
  • from previous employers; 
  • police service or crim track upon the individual’s provision of consent and identification information required to complete such a check.

4 Purpose for which we collect and deal with your information

As a general principle, we only use privacy information for the primary purpose for which we collect the information or a secondary purpose related to the primary purpose for which you would reasonably expect us to use the collected information.  

We will make you aware of the purpose for which we collect your information by notifying you about all the relevant matters of that collection.   

We will not use your information for an unrelated secondary purpose unless we obtain your written consent or an exception applies.   

4.1 Members and prospective members 

We collect, hold and use privacy information for the primary purpose of providing our services in accordance with the terms of our agreement with you, or for a secondary related purpose, such as recording your bank details for us to process accounts. 

We also collect and use privacy information for some secondary purposes, only with your written consent. All the secondary purposes for which we use your information are notified to you. 

The following are examples of the purposes for which we collect, hold, use, and deal with your privacy information:

  • to advise you of developments or changes to our services;
  • to market, advertise or otherwise promote our services;
  • to seek your participation (on a voluntary basis) in advertising campaigns, events, launches, customer testimonials and focus groups;
  • to keep a record of your privacy information, as updated from time to time. 
  • to use basic personal information, such as gender, for modelling and forecasting our business. 
  • to lawfully liaise with the individual’s nominated representative eg. a Personal Assistant 
  • to improve our services through quality improvement activities such as audits, surveys and other quality improvement activities.
  • to obtain professional advice. 
  • to comply with our obligations under any applicable laws.

4.2 Third parties

We may disclose your personal information to third parties, such as credit reporting agencies, banks, professional advisers, courts, tribunals, regulatory authorities, other companies and individuals for the purpose of:

  • complying with our obligations owed to you under any contract between us and you, or as required by law;
  • enabling those third parties to perform services on our behalf, such as delivering packages, addressing warranty claims, sending correspondence, providing updated ASIC and/or property searches and processing payments; and
  • recovering debts where you fail to pay for products and/or services provided by us.
They will have access to your personal information required to perform these services, but we will not authorise them to use your information for any other purpose.

We also disclose your information to our business partners, such as auditors, financial services or insurance companies, for them to offer products and services to you.

In addition, we may provide statistics (with personal identifiers removed) about our customers, readers, sales, traffic patterns and related site functions to reputable third parties primarily for the purpose of assisting us to improve our service offering.

You have the right to tell us that you do not wish us to send information to you other than for the primary purpose for which we collect your personal information.  We will always attempt to ensure our disclosure of personal information to other organisations is carried out in a manner which does not personally identify individuals.

5 Direct marketing 
5.1 Collecting information indirectly about an individual for marketing to that individual 
If ICON plans to engage in direct marketing using or disclosing information collected:

  • indirectly about that individual, or 
  • from the individual and the individual would not reasonably expect us to use or disclose the information for marketing purposes, 

ICON must first obtain consent, unless an exception applies. 

Please note that we will also comply with other laws that are relevant to marketing, including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Competition and Consumer Act 2010 (Cth).

All subsequent direct marketing you receive will include an easy opt-out procedure if at any time you wish us to cease sending you information.  

5.2 Collecting information directly about an individual for marketing to that individual  
If we collect information about you and you would reasonably expect us to use or disclose the information for the purpose of marketing, we will use an opt-out procedure in all our marketing communications. This means you will be able to easily unsubscribe from all future marketing communications.

6 The consequences of not providing us with privacy information 
Depending on the category of information, your withholding of personal information from us might mean we are unable to perform some essential functions related to our products and/or services, including one or all of the purposes listed above in clause 4. 

7 Cross border transfer or disclosure of information  
In the event we engage in cross border transfer of information, such as routing or storing information on cloud servers located overseas or transferring information to an office of our company overseas, we will ensure that adequate security mechanisms are in place to protect your information.  For example, we will enter into a contract with the cloud service provider that ensures the information is for the limited purpose of storing and managing the personal information. 

Wherever reasonably practicable, we will first seek your consent to such cross-border disclosure.  Please note that where you consent to such cross-border disclosure, we will be exempt from the requirements of the Act in relation to such disclosed information.  Where it is not reasonably practicable for us to obtain your consent we will otherwise comply with the requirements of the Act.

ICON has active committees overseas, including in Singapore and Hong Kong, China. Whenever information is sent by ICON to committee members located in Singapore, Hong Kong, China or elsewhere overseas the information is received by them in their capacity as ICON committee members, and this Privacy Policy and the Australian Privacy Principles apply to the disclosure of information to them in that capacity.

8 Maintaining the integrity, currency and safety of your privacy information 
This section explains how ICON holds your privacy information, how you can access your privacy information, update your privacy information, complain about an alleged breach of the APPs or make any related enquiry.

8.1 Maintaining currency of your information  

ICON relies on accurate and reliable information to deliver necessary and effective services.  If we are satisfied that any of the information we have about you is inaccurate, out-of-date, irrelevant, incomplete or misleading, or you request we correct any information, we will take reasonable steps to ensure the information held by us is accurate, up-to-date, complete, relevant and not misleading.

The practical measures by which ICON avoids having an incorrect record of an individual’s information include asking you to complete the appropriate forms and requesting that you periodically update this information in writing. 

If we disclose your privacy information that is later corrected, we will, or else you may ask us to, notify the entity that received the incorrect information about that correction.

Should we refuse to correct the information, we will explain the reasons for refusal. We will also show you the complaint procedure if you wish to lodge a formal complaint about our refusal.

8.2 Safety of your information

ll privacy information is securely stored using appropriate physical and/or electronic security technology, settings and applications, and by ensuring staff dealing with privacy information is trained in our privacy policies and procedures. 

These policies are designed to protect privacy information from unauthorised access, modification or disclosure; and from misuse, interference and loss. 

9 Accessing your information or lodging a complaint 

9.1 Accessing and correcting information 

You are entitled at any time, upon request, to access your privacy information held by us. We will respond within a reasonable time after the request is made and give access to the information in the manner requested by you, unless it is impracticable to do so. We are entitled to charge you a reasonable administrative fee for giving you access to the information requested.  

Should you be refused access to your information, we will explain the reasons for refusal - any exceptions under the Privacy Act or other legal basis relied upon as the basis for such refusal – and, if you wish to lodge a formal complaint about our refusal, we will explain the complaint procedure. 

9.2 Lodging a complaint

Should you wish to complain about a potential breach of this Privacy Policy or the Australian Privacy Principles please contact our Privacy Officer. 

The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.  

9.3 Contact details  
Privacy Officer
PO Box 525
Email: info@iconapac.com
Phone: +852 2516 7008

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