CXO Security Pty Ltd Privacy Policy

We take your privacy seriously

This policy outlines CXO Security’s ongoing obligations regarding management of your personal information. Personal information is information or an opinion about an identified individual, or an individual who is directly or indirectly identifiable from that information or opinion, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

1. 1. Collecting Personal Information

   We collect your personal information so that we can carry out our usual business activities related to the development and commercialisation of CXO Security’s services. The personal information we collect from you is your business contact information including your name, job title, employer name, work email address and work telephone number.
   Your personal information is normally collected directly from you as follows:

   • via our website if you complete an online form to register for an event, to register to receive informational content or to request information on our products and services; or
   • in person in the sale and provision of our products or services, or if we meet at an industry or other event.

   We may also collect your personal information from a third party, such as a public website or a supplier of lead generation services.

   If you register on our website to receive our restricted materials, we may ask you questions about your business. Such questions are designed to help us to tailor information to your needs and provide you with useful information about cyber security.
   You may unsubscribe from our mailing lists at any time by using the ‘unsubscribe’ option located at the end of each email.

   The consequences of not providing your personal information could be varied, depending on your relationship with CXO Security. For example, if you wish to register for a CXO Security seminar, without your personal information, CXO Security will not be able to register your attendance at the seminar. If you do not want to provide CXO Security with your personal information, you can contact CXO Security’s Privacy Officer to discuss the specific consequences of not doing so

2. 2. Use of Personal Information

   Our use or processing of your personal information may be on the basis of your consent or on the basis that the use or processing is necessary for CXO Security’s legitimate business interests, depending on our relationship with you.

   If you have opted in to receiving marketing communications from us, our processing of your personal information for marketing purposes is based on that consent. Alternatively, your consent may be inferred when that is a lawful basis for our use of your personal information for marketing communications.

   For other purposes, the basis of our using or processing your personal information is that it is necessary for CXO Security’s legitimate business interests. These legitimate interests may be any or all of the following, depending on our relationship with you:

   • to undertake or manage our business relationship with your employer as a potential customer, customer, supplier or business partner;
   • to comply with a legal action or law enforcement directive, or to protect CXO Security’s legal rights and/or property; and
   • internal purposes such as accounting, planning, record keeping and reporting.
3. 3. Disclosure of Personal Information

   CXO Security does not disclose your personal information to third parties without your consent other than in the following circumstances:

   • to those we contract directly to provide services to us, including the provision of a Customer Relationship Management solution, a business contact database and, on occasion, a lead generation service provider;
   • to those we contract directly to provide payroll services to us (employees only);
   • if legal action or a law enforcement directive requires that we must do so; or
   • it is deemed necessary by us to protect CXO Security’s legal rights and/or property.
4. 4. Statistical Information and Cookies

   We collect statistical information about visits to our website via log files and services such as Google Analytics and Hubspot, which track pages visited, geography and the browsers used. We also leave a cookie on your computer so that, when you return to our website, you do not need to re-enter your information to download resources available through our website. If you do not want us to leave a cookie on your computer, please disable cookies before you submit your personal information through our website.

5. 5. Your Rights

   You have certain rights in relation to our collection, use, disclosure and storage of your personal information. These rights include those listed below.

   1. Privacy Notice
      When we collect your personal information from you or from a third party, we are required to provide you with certain information as required by applicable law (‘Privacy Notice’). We will provide the Privacy Notice free of charge and within the timeframes imposed by applicable law.
   2. Access
      You have the right to access the personal information we hold about you and to information regarding our use, disclosure and storage of your personal information. We will provide the information and/or access in the manner requested by you if it is reasonable and practical to do so.
   3. Quality and Rectification
      We are required to take reasonable steps to make sure that your personal information is accurate, complete and up-to-date. You have the right to require us to rectify any inaccurate personal information we hold about you and to have any incomplete personal information completed.
      To ensure we maintain complete and accurate information about you, please take the time to advise us at the earliest opportunity of any changes to your personal information so that our records can be updated.

   Local law in other countries may provide you with legal rights in addition to or in substitute of those listed above in which case CXO Security will comply with those laws.
   If you wish to submit a request to us to access or rectify your personal information, please contact our Privacy Officer.

   We will respond to your request (unless a statutory exception or limitation applies) within the time required by applicable law. We will not charge you for responding to your request unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administration fee or refuse the request.

6. 6. Security

   In processing your personal information, CXO Security employs appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing of your personal information. In doing so, your personal information is processed in a manner that reasonably protects it from misuse, loss and from unauthorised access, modification or disclosure. Whilst these efforts are made, factors beyond our control could result in unauthorised access to or disclosure of data.

7. 7. Duration

   When your personal information is no longer needed for the purposes identified above, we will take steps to destroy or permanently de-identify your personal information. However, some personal information may be stored in documents that we are required to keep by law for the minimum periods imposed by law.

8. 8. How to Complain

   If you are dissatisfied with our handling of your personal information, including any breach of applicable privacy and data protection laws, please lodge a complaint in writing with the Privacy Officer. We will respond to your complaint within 30 days.

   Alternatively (or if you do not receive a satisfactory response from us), you may be entitled to refer the matter to your local privacy or data protection authority for assistance, such as the Office of the Australian Information Commissioner.

9. 9. Changes to this Privacy Policy

   Changes may be made to this policy from time to time. Notification of substantial changes to this policy will be handled by posting an announcement on the CXO Security website.

10. 10. Privacy Officer

    If you have any questions about this policy, wish to lodge a complaint or submit a request to access or rectify your personal information (or to exercise any of your other rights under applicable law) please contact the Privacy Officer at [email protected]