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; 
   • 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.leesenvironmentla.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 that may apply to you; and 
   • collection notices and privacy statements which may be provided to you at the time your personal information is collected. 
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?
   How do we collect personal 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); 
   • 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; or 
   • apply for a position with us (including for work experience). 

   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 type of information that we collect will 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; 
   • 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 online, 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; 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 and trade references (if you are applying for a trade account) 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 improve our services and your experience with us; 
   • 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 and maintain information technology systems; 
   • 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); 
   • 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?
   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. 

   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.

9. DO WE USE OR SHARE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
   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. 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.

10. Important information regarding opting out
    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). 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. 

    For cookies which use your personal information for direct marketing (such as targeted advertising) you can only opt-out by adjusting your device setting and online privacy settings (for advertising on certain websites and social media channels). 

    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).

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
    You may visit our websites without identifying yourself. If you identify yourself (for example, by making an enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy. 

    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. 

    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.

13. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?
    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). 

    We will only keep your personal information for as long as is necessary for the purposes set out in this Privacy Policy or as required to comply with any applicable legal obligations. When we no longer require your personal information (subject to and in accordance with any applicable laws), we will take steps to delete, destroy or de-identify that information.

14. HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
    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?
    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). 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