Privacy Policy

The Middleton Trust Pty Ltd (‘Mark Middo’) is committed to ensuring your privacy through compliance with the Privacy Act 1988 (Cth) (Privacy Act), EU General Data Protection Regulations and the Australian Privacy Principles (APPs). This privacy policy details how Mark Middo collects, uses, stores and deals with personal information.

What personal information do we collect, use and disclose?

Mark Middo, in the course of conducting its business collects a range of personal information including, amongst other things, names, email addresses, mailing and residential addresses, business and home phone numbers.

Mark Middo only collects personal information that is reasonably necessary for one or more Mark Middo’s functions or activities.

Mark Middo only collects sensitive information if it is reasonably necessary for Mark Middo’s functions or activities or an exception applies under the Privacy Act and the individual to whom the information relates has given their express consent to the collection.

No automated decisions are made with the data collected.

How does Mark Middo collect the information?

Collection of personal information by Mark Middo is only done by lawful and fair means.

Mark Middo collects personal information about an individual directly from that individual wherever it is reasonable and practicable to do so. This may be through contact forms, letters, emails, websites, receipts, telephone conversations, consultations and attendance at events.

Mark Middo will always take reasonable steps to ensure individuals are aware of (amongst other things) the fact and circumstances of collection, the purpose of collection and information about Mark Middo’s privacy policy.

What does Mark Middo use personal information for?

Mark Middo will only use or disclose personal information for the Primary Purpose including things such as managing our relationships, performing administrative functions, informing customers and others about our products and services by direct marketing methods, market research, building and maintaining business relationships, implementing our communication model and complying with legal requirements.

Personal information is not transferred internationally.

Where Mark Middo uses personal information other than for the Primary Purpose, Mark Middo does so in accordance with the Privacy Act and APP 6.

Direct Marketing

Mark Middo engages in direct marketing of its products and services from time to time.

Mark Middo only uses personal information for direct marketing in circumstances where Mark Middo has collected the information directly from the individual and that individual reasonably expects to receive direct marketing material from Mark Middo (for example, where an individual has signed up to receive direct marketing material from Mark Middo.

Mark Middo offers all individuals the opportunity to unsubscribe from receiving direct marketing communications. It is not mandatory to have your personal information recorded by Mark Middo to get access to our ‘free’ content, however this helps us keep you up to date on latest initiatives and news.

Access to and accuracy of personal information

Mark Middo takes all reasonable steps to ensure that the personal information it collects, uses and/or discloses is accurate, complete, up to date and relevant.

You have the right to ensure that your personal information which is held by Mark Middo is accurate. To make a request to access and/or correct your personal information, please contact Mark Middo’s Privacy Officer using the contact details provided below.

While Mark Middo will always endeavor to give access to personal information free of charge, Mark Middo reserves the right to charge individuals for access to personal information to cover costs associated with:

  • Searching for, locating and retrieving personal information and deciding which information to provide to the individual;
  • Using an intermediary; and
  • Reproducing and sending the information.
  • Security of personal information

Mark Middo takes all reasonable steps to ensure that information held by Mark Middo is safe and secure, and that it is protected from misuse, loss, unauthorized access, modification and disclosure. No data is sold or shared with other companies for marketing purposes.

Mark Middo stores and secures all personal information via a third party data storage providers, these include: InfusionSoft, WP Engine Web Hosting, Stripe & Merchant Warrior. The data is held with these companies in US and Australia, all being PCI Compliant, which is the highest level of data security standard across the globe. Mark Middo will make all reasonable endeavours to ensure the storage provider is compliant with the APP’s.

Destruction and de-identification of personal information

Mark Middo will take reasonable steps to de-identify or destroy personal information when it is no longer needed by Mark Middo except where the information forms part of a Commonwealth record or Mark Middo is required by law or a court/tribunal order, to retain the information.

Anonymity and pseudonymity

Individuals have the option of dealing anonymously or by pseudonym with Mark Middo unless it is impracticable to do so or Mark Middo is required by law or a court or tribunal order to deal with identified individuals.

Length of data collection

Mark Middo stores data until the user opts out or specifically requests to be removed from our database. Once removed all records of the information is removed from our database. If you wish to opt out please get in contact with our Privacy Officer (details at the bottom of the page).

Cookies

Mark Middo uses Cookies through third party providers including Facebook, HotJar and Google. This is so we can improve our experience of our website visitors and provide relevant re-marketing campaigns on promotions that we may be running to visitors.

To opt out of remarketing we recommend clearing browser history and cookies regularly and researching the way to opt out of being tracked through Google and Facebook permanently through their relevant sections of their websites.

Changes to privacy policy

Mark Middo reserves the right to amend this privacy policy from time to time. Changes will be posted on the RBT website.

Complaints

If you believe there has been a breach of the APPs or an APP Code, please contact Mark Middo’s Privacy Officer using the details provided at the bottom of this page.

Mark Middo takes privacy complaints very seriously. If you make a complaint, Mark Middo will respond within 5 working days to let you know who is responsible for managing your complaint. Mark Middo will try to resolve your complaint within 10 working days. When this is not possible, Mark Middo will contact you within that time to let you know how long we will take to resolve your complaint.

Mark Middo will investigate your complaint and where necessary, consult with third parties about your complaint. Mark Middo will make a decision about your complaint and write to you to explain our decision.

Individuals can also complain directly to the Office of the Australian Privacy Commissioner. Details about how to file a complaint can be found at www.oaic.gov.au or by calling 1300 363 992.

Contact Mark Middo

All queries and complaints should be directed to Mark Middo’s Privacy Officer.

Address: 924/401 Docklands Drive Docklands, VIC 3008 Australia

Telephone: 1300 554 065

Email: info@markmiddo.com

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