PRIVACY STATEMENT

Privacy Statement

Privacy Policy

Introduction

LVX Global Holdings Ltd ACN 638 155 842 and its related bodies corporate (we, us or our) are subject to the Australian Privacy Principles (the APPs) and the European General Data Protection Regulation (GDPR). 

The APPs apply to the collection and use of Personal Information as set out in the Privacy Act 1988 (Cth) (the Act) (as amended from time to time). 

The GDPR applies to the processing of personal data.

For the purpose of this Policy:

1. Personal Information means information, including financial information, or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is in a material form or not (and includes personal data as defined in the GDPR).
2. Sensitive Information means information or an opinion (that is also Personal Information) about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual practices, criminal record or health information.

We recognise the importance of protecting your Personal Information. We will take reasonable steps to ensure all Personal Information held by us is secure and all Personal Information collected, used or disclosed by us is accurate, complete and up to date. 

In Australia, our handling of Personal Information is regulated by the Act and the Credit Reporting Privacy Code (as amended from time to time) (the Code).

This Policy is published on our website and may be updated from time to time at our discretion. By continuing to use our website, or otherwise continuing to deal with us, you accept this Policy as it applies from time to time.

Types of Personal Information

Depending on the particular circumstances, we may collect and hold a range of different Personal Information about you.

This may include, but is not limited to:

1. your name;
2. contact details (including address, email address and telephone number);
3. information about your computer or device and about your visits to and use of our website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation);

We use Google to analyse the use of our website. Google generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at http://www.google.com/privacypolicy.html. 

Data collection

We provide general information about our company on our website. You can obtain extensive information about our products and services online. In addition to our newsletter, which you can either receive by e-mail or download, you have the option of downloading our publications or requesting copies of them by e-mailing us at Info@icititech.com or by using contact form which can be located by following this link: www.icititech.com/ contact-us/  

We acknowledge that there is no obligation for you to provide us with Personal Information except as required by law. However, if you choose not to provide us with certain necessary details, we may not be able to provide you with our full range of services or employment.

We collect Personal Information in a number of ways, including but not limited to:

1. directly from you when you enter the information into input masks or send it direcly to us via application documents or otherwise;
2. when you browse our website;
3. if you apply for employment with us, from any third parties that you nominate as your referees (and you consent to use obtaining Personal Information about you from third party sources such as social sites). 

We base the processing of Personal Information on our website on Art. 6, para. 1 (b) of the GDPR. However, certain exceptions do apply. These exceptions are set out below. 

Automatic data and information collection 

We use technologies which collect users' data and create usage profiles using non-identifiable personas. Data collection does not take place for the purpose of personally identifying our website visitors without prior consent. You may object to future collection and storage of your data at any time.

Purpose of data storage and storage period 

The purpose for which we use and disclose Personal Information will depend on the circumstances in which it is collected. Generally, to the extent permited by law, we may use or disclose Personal Information:

1. for the purposes for which it was collected;
2. for a related secondary purpose, if the use or disclosure could be reasonably expected;
3. for other purposes to which you have consented; and
4. as otherwise authorised or required by law (for example, to comply with work, health and safety, industrial relations and taxation laws).

We may use your Personal Information for the purposes not limited to, but including, technical administration of our website, for customer and application management, considering an individual for employment, providing you with products and/or services and for marketing purposes.

The Personal Information you provide for the free newsletter subscription will only be used for the purpose of sending the newsletter. The subscription can be cancelled at any time via the provided link in the newsletter. 

In the event that you submit an application with us, your Personal Information will only be used for the application process and then once the application process is over, will only be stored with us for approximately three months (unless otherwise required to be stored by law). Your Personal Information will be deleted/destroyed by secure means.

The storage takes place at LVX Global Germany, Australia, USA and Korea taking into consideration the data protection requirements.

In the event we collect Sensitive Information about you, you consent to us collecting, using and disclosing the Sensitive Information for the purpose for which it was disclosed and as permitted by law.

Disclosure of personal data to third parties

If we are required to provide your Personal Information to third parties, this will be done without your separate consent, but in compliance with legal requirements. 

It is not likely that we will disclose Personal Information that we collect and hold about you to any overseas third party recipients (as defined in the Act) with the exception of the external service providers outlined above. If we transfer your information to overseas third parties, we will ensure that reasonable steps are taken to ensure that the overseas recipient does not breach the APPs or the GDPR in relation to the information and that the overseas recipient is in a jurisdiction that has an adequate level of protection for your data before we provide them with it. 

We may be required to disclose your Personal Information to governmental authorities if required under laws or guidelines imposing obligations on entities relating to COVID-19 contact tracing (and your information may be used or stored by the relevant governmental authority for that purpose).

Social Media Plugins

On our website, we use social media plugins with links to our social media, such as LinkedIn, Instagram, Facebook, Twitter and YouTube. The data protection information listed below applies to this:

1. By clicking on the respective link, you activate the plugin and it remains active until you delete the cookies or deactivate the active plugin. 
2. A connection to the server of the social network is established and a transfer to your browser and an integration into the website takes place.
3. This starts the data collection by the social network regardless of whether you are active on that network. We explicitly point out that we have no influence on this data collection and therefore this collection does not fall within our responsibility but is rather to be taken from the statement on the treatment of data of the respective provider. If you are logged in with a user account on one of the social channels, the visit to our website can be assigned to you.  If you do not wish this, you must first log out of the social network.

Data protection measures

All Personal Information collected by us will be retained as part of our business records, which will be securely monitored and maintained.

Through continuous technological adjustments to our website and appropriate security measures, we try to protect your Personal Information from unauthorised external access, against any kind of misuse, loss or destruction. 

While we take reasonable technical and organisational precautions to ensure the security of your Personal Information on our systems (and without limiting anything set out in our General Terms & Conditions):

1. data transmission over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet; and
2. without limiting the above (and except to the extent we are in breach of the law), we do not take responsibility for any unauthorised access to your Personal Information or loss of or corruption of data caused by any computer virus or Trojan horse or via any system from an internet service provider linking your computer system to ours.

We note that LVX employees have been bound by the special confidentiality requirements in relation to dealing with your Personal Information.

Rights of information, correction, deletion and objection 

Based on the GDPR (Articles 15-21), you have the right to access, correct, delete and object to the storage of your Personal Information. Upon your request, we will provide you with machine readable access to your Personal Information (subject to certain exceptions contained under the relevant laws).  

To request access to your Personal Information, or to update or correct your Personal Information, please send a written request by email to info@icititech.com or by mail to the following addresses:

1. if you are located in the European Union, LVX Global Tannenwaldallee 2, 61384 Bad Hamburg, Germany; or 
2. if you are located in Australia, LVX Global, Level 3 Bice Building, Lot Fourteen, North Tce, Adelaide, Australia, 5000. 

You may also request that your Personal Information be updated or rectified if it is no longer up-to-date or incorrect. 

You may request deletion of your Personal Information if there is no other legal basis for the original purpose for which the data was collected.

You may object to processing of your Personal Information that we have collected on the basis of legitimate interests, unless we can prove compelling reasons for the processing.

Contact us

If you are concerned that the way in which we collect, hold, use or disclose your Personal Information may be in breach of the GDPR, APPs/and or the Code, please send written details of your complaint 

by email to info@icititech.com or by mail to the following addresses:

1. if you are located in the European Union, LVX Global Tannenwaldallee 2, 61384 Bad Hamburg, Germany;or 
2. if you are located in Australia, LVX Global, Level 3 Bice Building, Lot Fourteen, North Tce, Adelaide, Australia, 5000. 

In relation to Australian complaints, we will conduct internal discussions and evaluate whether we believe that such collection, holding, use or disclosure of your Personal Information was in breach of the APPs and/or the Code. We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex issues or requires extensive investigation, it may not be possible to respond within this timeframe. If the conclusion of our investigation is that our collection, holding, use or disclosure of your Personal Information was in breach of the APPs and/or the Code, we will take steps to remedy the breach as soon as reasonably practicable. If after dealing with us you are still not satisfied, you are entitled to make a complaint to the Office of the Australian Information Commissioner or the Financial Ombudsman Service.