You have the right to make a complaint at any time to the relevant national regulatory body. We would, however, appreciate the chance to deal with your concerns please contact the DPO in the first instance.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you during your relationship with us, however we acknowledge that, as most of our transactions are business to business, the personal data we collect will be minimal. We have identified types of data as follows:
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and/or Financial Data by filling in forms or by corresponding with us by post, phone, emails or otherwise. This includes personal data you provide when you engage with ACE.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and/or Systems Data about products and/or services used, your browsing actions and patterns. We collect this personal data by using cookies, server logs or other similar technologies.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you or your employer (or business / organisation on whose behalf you act in any capacity); The vast majority of ACE’s transactions are business to business, as such most of the personal data in our possession will be limited to Identity Data and Contact Data and we will only use this data as necessary for legitimate interests as we perform our contractual obligations.
- 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; and/or
- Where we need to comply with a contractual, legal and/or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing communications. You have the right to withdraw consent to marketing at any time by contacting the DPO.
Purposes based on legitimate interest for which we will use your personal data
We may use your personal data in connections with any of the following (or combination of the following) purposes based on legitimate interest:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a process that we will follow should we use your personal data for marketing purposes and to this extent we will seek consent.
Optimisation of your databases:
When you access our Web sites, we may automatically (i.e. not by registration) collect non-personal data (e.g. type of Internet browser and operating system used, domain name of the Web site from which you came, number of visits, average time spent on the site, pages viewed). We may use this data and share it with our worldwide affiliates to monitor the attractiveness of our Web sites and improve their performance or content.
Systems Data can be used to quality check, understand and develop products and services. In the vast majority of cases, this will be Aggregated Data such as statistical or operational data for any purpose connected to ACE’s obligation to provide products and services. Aggregated Data may be derived from personal data but will be anonymised. Should there be any situation where it is not possible to anonymise we will only use this data as necessary for legitimate interests as we perform our contractual obligations.
“Cookies” – Information stored automatically on your computer:
When you view one of our Web sites, we may store some data on your computer in the form of a “cookie” to automatically recognize your PC next time you visit. Cookies can help us in many ways, for example, by allowing us to tailor a Web site to better match your interests or to store your password to save you having to re-enter it each time. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.
Links to other web sites
ACE Web sites contain links to other Web sites. ACE is not responsible for the privacy practices or the content of other Web sites.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. Disclosures Of Your Personal Data
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. 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. 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.
7. Data Retention
How long will you use my personal data for?
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.
Where by law we have to keep basic information including, but not limited to, Contact, Identity, Financial and Transaction Data for six years after fulfilling the purposes for which we collected it for tax purposes, we will retain for 6 years.
In some circumstances you can ask us to delete your data, by writing to us and asking us to delete the 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.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights include:
- 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.
If you wish to exercise any of the rights set out above, please contact the DPO.
NO FEE USUALLY REQUIRED
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.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
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.
9. Modifications To This Notice
ACE reserves the right to modify this Notice by posting changes to the Website. If you submit additional personal information following the effective date of a modified Notice, your personal information will be handled in accordance with the Notice in effect at that time.
Data Protection Legislation: shall include all applicable privacy and data protection laws of Australia.
Where an issue arises, the following principle shall be adhered to – if both parties (being the ACE entity and the data subject) have their registered seat in the same jurisdiction, the relevant data protection law and regulations for that jurisdiction will be complied with by both parties. OR, if both parties have their registered seat in different jurisdictions the data protection law and regulations shall be in accordance with Australian Law.