Cleanway Group is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws (see below for further information about the Cleanway Group). 

We take protecting your privacy very seriously and we want to be open and transparent with you about how we handle your personal information. This Privacy Policy describes the ways in which we collect, hold, store, use and share your personal information. If you have any questions about our Privacy Policy, or about the ways we handle your personal information, please contact us using the details set out below.

1. ABOUT CLEANWAY GROUP
   Cleanway Group is a leader in chemical and hazardous waste management in Australia. Cleanway Group includes Cleanway Group Pty Ltd (ACN 645 125 766) and its Australian subsidiaries and affiliates (Cleanway Group). We are committed to providing our customers with tailored and cost effective end to end disposal solutions. We offer a range of services, including waste disposal, secure product destruction, emergency spill response, waste management and waste audit services.
2. WHEN DOES THIS PRIVACY POLICY APPLY AND WHAT IS IT?
   This document sets out how we manage your personal information and is referred to as our Privacy Policy. It is divided into a number of sections and in addition to explaining how we manage personal information it also provides answers to commonly asked questions. This Privacy Policy applies to all Australian Cleanway Group websites, subsidiaries, affiliates and businesses, unless that website subsidiary, affiliate or business has adopted a separate privacy policy.
   
   In this Privacy Policy, “we“, “us” and “our” refers to Cleanway Group and “you” and “your” refers to any individual about whom we collect personal information. Our Privacy Policy explains how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online). For example, this can include information we may collect: 
   • when a potential customer makes an enquiry regarding our services; 
   • when a customer acquires our services; 
   • when a customer creates a trade account with us or completes an application to obtain commercial credit from us; 
   • when a trade referee provides us with a trade reference about a customer;
   • when you interact with us (including when you visit one of our premises in person, when you visit our website(s) (https://www.cleanway.com.au/, www.evoro.com.au, https://www.leesenvironmental.com.au), or contact and communicate with us via our social media channels (such as via Facebook or LinkedIn), phone or online). 

   Other terms and conditions may also apply to you, such as: 

   • any of our terms and conditions, which may include our trading terms and conditions and our credit application terms and conditions; 
   • collection notices, consents and privacy statements which may be provided to you at the time your personal information is collected; and

   credit related collection notices and consents, including our Credit Reporting Policy and Statement of Notifiable Matters] (our Credit Policy) which applies in connection with our collection and handling of Credit Related Personal Information (as defined in Section 4 below and in our Credit Policy) when an individual applies to us for commercial credit, and to other individuals we deal with in connection to the provision of commercial credit (such as directors and individual guarantors).

3. WHAT IS PERSONAL INFORMATION?
   Personal information is defined in the Privacy Act as ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable:
   • whether the information or opinion is true or not; or 
   • whether the information or opinion is recorded in a material form or not’.In this Privacy Policy, whenever we use the term “personal information”, we are referring to this legal definition. This is a very broad definition, however some simple examples of personal information include your name and date of birth. Personal information does not include aggregated or de-identified data.
4. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE COLLECT THIS INFORMATION? 

   Normally we collect your personal information from you directly, however on occasion, we may also collect personal information about you from other people and organisations. In summary, we may collect your personal information when you: 

   • create a trade account with us; 
   • enquire about or acquire our services (via phone, in person or electronically); 
   • are an individual and make an application for commercial credit, or provide a guarantee in connection with a commercial credit application;
   • interact with us in person (such as when you visit one of our offices), via phone or online (including through our website or our social media channels), such as when you contact us to make an enquiry, book a waste audit, give us feedback or make a complaint;  
   • apply for a position with us (including for work experience); or
   • otherwise do business with us or interact with the Cleanway Group. 

   We may also: 

   • receive information from a third party (such as your employer) if a workplace incident occurs and you are involved with or witness the incident; 
   • receive personal information from another member of Cleanway Group; and 
   • collect personal information from third parties (such as through acquisition of third party mailing lists and from organisations with whom we have an affiliation), to improve the personalisation of our offerings for you. 

   What information do we collect?

    The types of information that we collect will vary depending on your interactions with the Cleanway Group but typically include: 

   • your name and e-mail address (and other contact details such as your phone number), when you apply for a trade account, enquire about or acquire our services or book a waste audit, if you apply for a position with us, if you make an environmental nuisance complaint or pollution incident allegation or when you otherwise interact or contact us online, over the phone or in person; 
   • your credit information, credit eligibility information and credit reporting information (as each of those terms are defined in the Privacy Act, and together, Credit Related Personal Information), that we may collect from individuals in connection with an application for commercial credit; 
   • information relating to your work history, education and qualifications, your suitability for a role and working eligibility rights and details about your referees, if you apply for a position with us (including if you apply for work experience with us); 
   • information regarding your location, if you work with us; 
   • Video footage when driving our vehicles, if you work with us; 
   • CCTV on our physical sites 
   • details of your interactions with us, for example information you provide us when you make an enquiry or complaint online, over the phone or in person; 
   • voice recording, time, date, number and name of individuals on the call, where we monitor and record our call with you, when we call you or you call us (we will let you know if we are going to record call information); 
   • publicly available information, such as on online forums, websites, and social media channels (for example, information that relates to a complaint); 
   • any information we are required by law to collect; 
   • online and digital services information (including behavioural information), such as your IP address and details about your device, where you use our online services (such as cleanway.com.au or our social media channels), via use of online behavioural technologies, such as “cookies” – in some cases this may be personal information and other times we cannot identify you (see Section 12) ; and 
   • any additional personal information you provide to us, or authorise us to collect, as part of your interaction with Cleanway Group. 

   In some cases you may provide us with personal information which relates to another person, for example:

   •  a person involved with or a witness to a workplace incident;
   • trade references (if you are applying for a trade account); 
   • guarantor information (which may apply if you are applying for commercial credit); or 
   • a job referee (if you are applying for a job with us). 

   If you do so, you agree that you have received permission from these individuals for us to collect, use, and share, their personal information in accordance with this Privacy Policy. You should also let them know about our Privacy Policy (including the information in this Privacy Policy).

5. CAN YOU DEAL WITH US WITHOUT PROVIDING YOUR NAME OR OTHER PERSONAL INFORMATION?
   Most of the time, you will have the option of not providing your name, or using a fake name, when you deal with us (where it is lawful and practicable). This includes for example, when you make a general enquiry. In some circumstances however, we may need your real name as it may not be practicable for us to deal with you anonymously or pseudonymously on an ongoing basis. For example, this includes when you choose to acquire our services. This means that if we do not collect your personal information, we may not be able to provide you with the services you have asked for.
6. WHY DO WE COLLECT, STORE AND USE YOUR PERSONAL INFORMATION?
   We collect personal information that is necessary to provide you with our services, and to carry out our business. We may use your personal information for purposes which are incidental to the sale and promotion of our goods and services, or for other purposes which are within your reasonable expectation or permitted by law. 
   The purpose for which we usually collect, store, and use your personal information depends on how you interact with us, but may include: 
   
   • to provide you with our services you have acquired or otherwise inquired about (for example, a waste audit) and otherwise manage our relationship with you (for example, as a trade account holder; 
   • to administer, manage and communicate with you about existing services we are providing to you; 
   • to assess an application for commercial credit;
   • to improve our services and your experience with us; 
   • to test, train, improve, maintain and develop our products, services and technology systems (some of which may be powered by, or integrate, Artificial Intelligence Tools (AI Tools)); 
   • to communicate with you and provide you with special offers and promotions; 
   • to assess your suitability for a position with us, and, if you successfully join us, to manage your working relationship with us; 
   • for administration and management purposes (such as if you are a contractor); 
   • if you interact with us on a commercial basis (such as if you are a service provider, contractor or supplier to us), or you otherwise interact with us on a commercial basis; 
   • to manage fees and administer billing (including administration of third-party payment arrangements) and debt recovery; 
   • to manage, monitor, plan and evaluate our services, and test, train, maintain and improve our information technology systems, including by using AI Tools; 
   • to conduct safety and quality assurance and improvement activities, including quality control of our services and communications with you, and to test the effectiveness and customer satisfaction of our services; 
   • to train staff and to investigate any incidents that may occur (both in relation to cyber security, as well as any health and safety incidents that occur) and handle and respond to any complaints (including any environmental nuisance complaint or pollution incident allegation); 
   • to create deidentified or aggregate data sets (which is no longer personal information). We do this by deidentifying or aggregating your information such as combining your information with information we have about our other customers and with data we obtain from other sources. We use this deidentified or aggregate data to assist with our business decisions, such as to understand customer behaviour, improve our offerings and develop new services; and 
   • for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale.
7. WHY DO WE SHARE YOUR PERSONAL INFORMATION AND WHY?
   We may share your information with third parties: 
   • for the reasons for which we collect, store and use that information (see above); 
   • for other purposes explained at the time we collect your personal information; or 
   • where we are otherwise allowed or required to do so under law.

   Some of the third parties we may share your information with include the following:
   

   • other members of Cleanway Group (for example, if a Cleanway Group member is providing another member with backend IT support and other corporate services to Cleanway Group; 
   • our partners, suppliers and entities we do business with (who assist us with providing our services), such as manufacturers, suppliers and distributors; 
   • our service providers and advisors (who assist us with providing, promoting and managing our services). These may include our IT service providers and third party storage providers, marketing and communications providers, data analysis organisations, and professional advisors and consultants (e.g. legal, insurance and financial advisors); 
   • our credit reporting bodies, credit providers and debt collectors in connection with an application for commercial credit and for the purposes set out our Credit Policy;
   • third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us); and 
   • government and law enforcement agencies (including regulatory bodies) to comply with our legislative or regulator obligations (such as to assist with police investigations).
8. DO WE SHARE YOUR PERSONAL INFORMATION OVERSEAS?
   There are other circumstances where we may share your personal information to an overseas recipient. For example, where you have provided your consent, or we are otherwise permitted to do so under the Privacy Act or other relevant laws.We generally only collect personal information in Australia. However we may share some personal information with our external service providers located overseas where applicable. We only ever share your personal information outside Australia where we are permitted to do so under the Privacy Act. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with the requirements of the Privacy Act.
9. DO WE USE OR SHARE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
   Where you provide personal information to a Cleanway Group member, we may share this personal information to another entity in the Cleanway Group so that they can undertake direct marketing as set out in this Section 9.We may communicate with you (and send these electronic messages and tailored advertising) through various channels, such as via regular mail, email, SMS push notifications or social media. We will only send these communications in accordance with applicable privacy and marketing laws, and only where you have not opted out from receiving such communications from us.When you provide your personal information to a Cleanway Group member, we may use that personal information to send you direct marketing communications to keep you informed about products and services offered by Cleanway Group and carefully selected partners which we think might be of interest to you based on your interactions with us.
10. Important information regarding opting out
    You can also contact us using our contact details set out below to tell us you would like to stop receiving direct marketing communications from us. Importantly, regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if we are required by law to provide you with information, or in relation to the services we are providing you with (for example, in relation to sending you an invoice in relation to services we have provided you with).You are always in control of the direct marketing communications which you receive and can opt-out at any time. Generally you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as email or SMS message).  To disable cookies and other third party tracking technologies, please follow the instructions set out in Section 12 below.

HOW DO WE INTERACT WITH YOU VIA THE INTERNET? 

11. Third party links and sites
    When you use our websites or receive communications from us, links to websites which belong to other third parties may be included (and are provided for your convenience). You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, any third party websites.
12. Website use and cookies
    We may collect statistical information when you access and use our websites, by utilising features and technologies of your internet browser and built into our website infrastructure, including cookies and tracking pixels. We use these tracking technologies for a variety of purposes, including to:
    • collect data about our website traffic;
    • analyse how our websites are being used, 
    • improve our websites; and 
    • provide more user friendly and customised websites and online services. 

    These features and technologies do not specifically identify you unless you otherwise provide personal information to us that enables identification. As such, information collected through these tracking technologies may be personal information.

    We also use third-party service providers that may collect data related to your use of our online services through a suite of tracking technologies, such as third-party cookies, tracking pixels and web beacons, for analytic and/or marketing purposes.

    Cookies

    Our websites also use cookies (and we share personal information we collect between members of Cleanway Group). A ‘cookie’ is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, “click-through” information, IP address, pages you have accessed on our websites and on third-party websites. Depending on the circumstances, this may or may not be personal information. 

    At a high level, cookies can be used for a variety of reasons, such as to personalise your browsing experience (for example, by remembering your preferences and recognising you as a repeat visitor to our websites), and to track statistics about the usage of our website. This allows us to better understand our users and improve the layout and functionality of our websites. 

    Below are the main types of cookies we may use a combination of:

    Type of Cookie	How we use this Cookie
    Session Cookies	Session cookies are used to track your movements from page to page. These cookies are usually erased when you close your web browser.
    Persistent Cookies	Persistent cookies are stored on your device between browser sessions for a pre-defined amount of time. These cookies allow the site to remember your information or settings across the site. These cookies also enable targeted advertising.
    Functional Cookies	Functional cookies remember information such as usernames or language settings and may allow the site to display important alerts. These cookies are not considered necessary, and can be blocked by the user, although this may impact how the site functions.
    First party Cookies	First-party cookies are small data files stored on your device by our website. These cookies help improve your experience by remembering your preferences, enabling essential website functions, and providing insights into how you interact with our site. They are set and managed directly by the website you are browsing, ensuring a personalised browsing experience
    Necessary Cookies	Necessary cookies are either session or persistent cookies, and are used to perform functions such as storing data and remembering you between pages. Similar to session cookies, these cookies are necessary for a number of functional features on our website.
    Tracking and Social Cookies	Tracking and social cookies are either session or persistent cookies, but are not essential to the function of our website. These cookies help improve your experience by providing content relevant to you.

    Opting out of Cookies: If you do not wish to receive any cookies (other than those that are strictly necessary) you can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our websites.

    For example, depending on which browser your device uses, you may be able to disable certain third-party cookies. Please note that if you disable certain cookies, you may be unable to access certain pages or content on our Websites.

    To change your web browser preferences, please visit the relevant preferences or settings page on your browser and amend the privacy settings in relation to cookies and site data. It may be necessary for you to opt out separately from each device and browser that you use to access online content.

    Tracking pixels

    A tracking pixel is a piece of code that a business or third-party provider can place on its website or in email to collect information about a users’ activity, including the site pages they visit time spent on each page, IP address, and/or form inputs (as relevant). When users visit pages with pixels, the pixel “loads” and sends the information it is designed to collect back to the server of e.g. in the case of third-party pixels this would be to the third-party service provider.

    Below are the main types of tracking pixels we may use a combination of:

    Type of Pixel	How we may use these Pixels
    Retargeting Pixels	These are coded to monitor specific actions you make, such as which pages you visit, how much time you spend on each page, or how far you scrolled down a page. These help us understand our users’ behaviour on our Websites.
    Conversion Pixels	These are designed to track completed actions. When an action is completed it sends a signal back to the server. This data helps us understand how effective a particular webpage is at encouraging specific actions.
    Analytical Pixels	These pixels collect a wide range of data, including page views, time spent on the site and visitor demographics
    Email Tracking Pixels	We may use these in email campaigns to track actions like email opens, link clicks and forwards. When you  open an email, the pixel sends a signal back to the server, providing data that can help in understanding the effectiveness of email marketing strategies.
    Affiliate Pixels	Affiliate pixels are used to track sales or leads generate through affiliate marketing. When a visitor clicks on an affiliate link and completes a specific action, the pixel fires, allowing the affiliate to earn a commission for the sale.

    Opting out of Tracking Pixels: In addition to opting out of cookies via your browser as described above, you can opt out of the following third-party analytical tools we may use using the instructions in the table below:

    Provider	Description
    Meta Platforms Inc	If you use Facebook, Instagram, Threads or any other platforms or networks owned or used by Meta, you can generally adjust your ‘ad preferences’ in the account settings of the respective platform that you access and see ads in.
    Alphabet Inc	If you use YouTube, Google or any other platforms owned by Alphabet, you can manage how tracking technologies are used by checking your browser or account settings and adjusting your ‘privacy & safety’ and ‘search personalisation’ settings.
    Other websites	If you see our ads on any other third party website or platform and you consider the ad is not general in nature (e.g., that is has been personalised for you), you may be able to adjust your account settings on that website to adjust your ad preference and turn off any ad personalisation.

    These third party providers may update their policies and settings from time to time, so we encourage you to review their terms and policies for more information on their data collection practices and options available to you for managing your privacy. Please note that how these third parties handle and use your data is governed by their own privacy policies, not ours.

13. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?
    
    1. We are committed to protecting your personal information, and ensuring that we securely store any personal information we collect (and in accordance with applicable privacy laws). We may hold your personal information in hard copy (paper) or electronic form. 

    We take all reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.

    We store personal information in paper-based files in secure storage (generally at our offices). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). 

    We store electronic records in secure databases, using trusted third party storage providers. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores). Using technical methods, we also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems. 

    Our websites use encryption or other technologies to ensure that your personal information is securely transmitted via the internet (including to protect any payments you make). We encourage you to exercise care when sending your personal information via the internet (for example, when communicating with us online, we ask that you do not include your full account or card details). 

14. HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
    
    1. You are entitled to request access to any of your personal information that we have. To make such a request, please contact us using the details set out below. 

    We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and informing us of any change in your personal details (for example, if your email address changes). 

    If you consider any personal information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are also entitled to request correction of the information (again, please contact us). After receiving a request from you, we will take reasonable steps to correct your information. 

    We may decline your request to access or correct your information in certain circumstances in accordance with the applicable privacy laws. If we do refuse your request, we will provide you with a reason for our decision. In addition, if we refuse your request for correction, we will include a statement about your request with the personal information we store.

15. HOW CAN YOU MAKE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?
    
    1. If you have any questions or concerns please contact us using the details set out below. 

    Please also contact us in writing if you have a complaint about privacy. If you make a complaint about privacy, the following will occur: 

    • Step 1: We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. 
    • Step 2: If your complaint requires more detailed consideration or investigation: 
      • we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly; and 
      • we may ask you to provide further information about your complaint and the outcome you are seeking. 
    • Step 3: We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved. 
    • Step 4: In most cases, we will respond to your complaint within 30 business days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know. 

    
    If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator). 

    The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992, or you can fill out this form to make a complaint about our handling of your personal information. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

     

16. HOW ARE CHANGES MADE TO THIS PRIVACY POLICY?
    We may make changes to this Privacy Policy, with or without notice to you. However, where we make a material change to the Privacy Policy, we will provide notice to you (including by updating our websites, and, where appropriate, notifying you directly).
    You can access this Privacy Policy on our website and you can also contact us to request that we make this available to you in another appropriate form (for example, in hard copy). We recommend you visit this Privacy Policy regularly to keep you up to date with any changes we make.
17. CONTACT US
    You can contact us using the details below:

    CLEANWAY GROUP
    Phone	03 9369 4545
    Email	hi@evoro.com.au
    Postal address	9-11 Maria Street, Laverton North, VIC, 3026