Privacy Policy

Privacy Policy

TTG GROUP PRIVACY POLICY

TTG is an Australian company.  We have staff and customers in Europe.

TTG operates in accordance with the Australian Privacy Act 1988 and are moving to ensure we comply with the EU GDPR requirements.

The GDPR is a good thing and TTG take protection of the data we hold, both to conduct our business and, to support customers who use our software and services, very seriously.

This policy sets out what TTG does and the type of personal information we collect, hold and manage and, how we treat that information.

TTG do not sell your personal information to any third party for any purpose and do not disclose or share your personal information unless required to do such, as may be lawfully required, in connection with your employment.

Our primary business is in the development and sales of products and services to the railway industry, that our customers use to support their real time train operations and, which are used by customers and TTG staff.

As part of those services, our software platforms contain personal information on users of our software such as, names, ID’s, email addresses etc.

This information is not shared but is available to our customers via our database and reporting services, for use by our customers to generate reports on operational performance.

Our Privacy Policy will be updated from time to time and will be available on our website.

This Privacy Policy applies to the following TTG companies.

  • TTG Transportation Technology Pty Ltd
  • TTG Technology (Europe) Limited

‘Personal Information’ is defined as meaning information recorded in a material form (whether true or not), relating to an individual whose identity is apparent or can be directly or indirectly ascertained from the information.

Should a particular privacy law define personal information in a different way, then this Privacy Policy shall use that definition.

‘Sensitive Information’ is defined as meaning information about an individual, race or ethnic origin, political views, pollical association, religious or other beliefs, membership or trade association or union, sexual preference, sexual orientation, criminal record, health information or other genetic information.

If a local privacy law defines sensitive information in a different or broader way, then that definition will apply to this Policy.

PERSONAL INFORMATION WE MAY COLLECT

We may collect and hold the following types of personal information.

  1. Names, date of birth, relationship to other individuals i.e. next of kin, emergency contacts.
  2. Address, phone number, email address and other addresses and contact details, Skype, LinkedIn and the lie, used in communications or on business cards.
  3. Other personal data such as voice recording, videos and photo images.
  4. Customer contacts from enquiries about TTG Products and Services.
  5. Customer contact details used to carry out conducting TTG’s business and support services.
  6. Names and ID’s of customer personnel who use our products.
  7. Information in respect to employment contracts or other employment activities or enquiries.
  8. As a general rule, TTG do not hold sensitive, personal information unless it may be required for purposes of managing individual employment contracts.
  9. Payment records including bank account details, or other financial institution account details, superannuation funds and income protection insurance records.

THE WAY WE COLLECT PERSONAL INFORMATION

We collect personal information in a number of ways

  1. Through communications with you, via letters, emails, phone calls, voice mail, website and social media.
  2. Via indirect communications.
  3. By using our software where personal information is stored on our system loaded by people authorised to do that, either staff or customer’s staff.
  4. In the ordinary course of our business.
  5. Hard copy files.
  6. Database associated with our software, either installed on our premises, customers premises or third-party hosting services such as Azure.
  7. Unsolicited personal information.

THE PURPOSES FOR WHICH WE COLLECT & HOLD PERSONAL INFORMATION

We collect and hold personal information for the following purpose.

  1. Pursuing our business activities and functions.
  2. Allowing our customers to use our software in accordance with customers agreements.
  3. Allow us to provide technical support to our products.
  4. Managing your employment with us.
  5. Training and HR purposes.
  6. Our administration purposes and obligations.
  7. Performing certain functions via our website.
  8. Customise database and mailouts.
  9. Complying with our legal obligations including relevant privacy legislation.
  10. We do not provide personal information to third parties unless we have your agreement to do so or, we are required by law to do so.

STORAGE AND DISCLOSURE OF PERSONAL INFORMATION (INCLUDING OVERSEAS TRANSFERS)

  1. We take appropriate measures to secure personal data and protect it from loss or unauthorised disclosure or damage. All Personal Information provided to us will be held for so long as you are employed by TTG or, we are reasonably required to deliver services to our customers or, as otherwise required for regulatory or other legal purposes and will be stored on secure servers.
  2. In accordance with this Privacy Policy, we may send Personal Information to third parties, including those located outside of the territory in which the individual’s Personal Information is gathered for processing by staff who work for us or for one of our suppliers, including staff engaged in, among other things, the fulfilment of service delivery, the processing of payment details and the provision of support services. Transfers of Personal Information to overseas jurisdictions will take place in the following circumstances:
  • where we have a group company assisting us with our business activities and functions;
  • where we have a supplier assisting us with providing assistance with our business activities and functions;
  • where our website, or any hosting service we use to support our software or software as a service, is hosted by us or a third party, and the hosting facilities and/or the back-up/disaster recovery sites are located overseas;
  • where a third-party application is being used in connection with our interactions with you, e.g. when we use email or Skype, the third-party providers of the relevant application have their applications hosted overseas;
  1. The countries in which we know that Personal Information may be processed and/or transferred to include:
  • Europe;
  • United Kingdom;
  • New Zealand; and
  • Australia
  1. We will only transfer Personal Information outside of the country of collection in accordance with applicable law.  Wherever Personal Information is transferred outside of the country of collection, we will take all steps reasonably necessary in accordance with applicable law to ensure that such Personal Information is treated securely and in accordance with this Privacy Policy.
  2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or any part of our services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
  • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our site; any transmission is at your own risk. Once We have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
  1. Use of Social Media

Our website may use social media such as YouTube.  The nature of social media is that these applications actively enable exchange and disclosure of any information, whether personal or otherwise, that is included within those applications.  All information, including any Personal Information that you may enter into those applications may be used, stored, handled and disclosed in any way that is consistent with the privacy policies of the relevant applications, if any.  We accept no responsibility or liability for any Personal Information that you decide to publish on any social media outlet.

  1. Cookies, Metadata and Site Data Activity
  • A cookie is a small piece of computer code which remains on your computer and contains information which helps us identify your browser.
  • When you visit our website and applications and tools on it, the cookie records the authentication to allow your user id to login (if required).  We use the information gathered by cookies to identify your web browser so that when you log in on the next occasion your use of the website and other applications and tools on it is easier and faster because the website has remembered your details.
  • If you do not want us to use cookies then you can easily stop them, or be notified when they are being used, by adopting the appropriate settings on your browser.  If you do not allow cookies to be used some or all of the website or other applications or tools on it might not be accessible to you.
  • Sometimes information that you upload is provided with associated metadata.  If you do not want us to use the metadata you must remove it by erasure from the underlying document/materials properties before uploading it onto the website and other applications and tools.
  • We may collect data that is associated with your visit, including the pages you visit, the activities you undertake on our website.  We may also collect information relating to the computer, mobile phone or other devices including the device type, browser, location, IP address and search words used.  We may collect, use, disclose and store such information in any of the ways set out in this Privacy Policy.
  1. How to Access and Seek Correction of Your Personal Information or Complain
  • Under applicable privacy legislation, we must ensure that your Personal Information is accurate and up to date. Therefore, please advise us of any changes to your information.
  • If you want to find out what Personal Information we hold on you, or you believe any of your Personal Information that is held by us is inaccurate, out of date, incomplete, irrelevant or misleading or it is not necessary for us to continue to hold it, or you wish for us to delete or port your Personal Information to a third-party  provider, you can contact us, and we will either provide you with access to the Personal Information (in so far as we are legally able and required to do so by applicable law,) or we will delete it or correct it, as applicable, within a reasonable period as determined under applicable law. You can contact us by:
    • email at the following email address enquiries@ttgtt.com.au or enquiries@ttgeurope.com; or
    • using the Contact Us web form on our website.
  • If you wish to complain about a breach of any applicable privacy laws or codes, or this Privacy Policy, you should contact us by:
    • email at the following email address enquiries@ttgtt.com.au or enquiries@ttgeurope.com; or
  • using the Contact Us web form on our website.
    • If you make any such complaint, we may be obliged to report that complaint to the relevant local regulator within the timeframes set out in the relevant local legislation. We may also be obliged to self-report a breach of your privacy to the relevant local regulator within the timeframes set out in the relevant local legislation.
    • We will aim to respond to any complaint within 10 business days of the date of receipt.  We will attempt to resolve your complaint to your satisfaction.  If you are not satisfied with how we deal with your complaint you may contact the relevant regulatory authority in your country.

This Policy has been endorsed by the TTG Group.

_______________________________________________

DALE COLEMAN
MANAGING DIRECTOR

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