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PRIVACY POLICY

Hansen’s Commitment to Privacy

Privacy Policy

The Hansen Technologies Group (“Hansen”) is a global company that develops, implements and supports proprietary customer care and billing solutions for service providers within the energy, pay-tv and telecommunications sectors in 40+ countries. In addition, Hansen is an IT service provider which provides a range of IT services including data centres, private cloud and managed services.

Hansen is fully committed to ensuring the proper management and use of all personal data it collects and handled in compliance with applicable privacy laws, including the Australian Privacy Principles, the EU General Data Protection Regulation (GDPR) and the US Privacy Shield Framework.

This Privacy Policy (“Policy”) applies to all of Hansen’s entities, as set out in the Appendix. It sets out Hansen’s policy on the management of personal data.

1. Open and transparent management of personal data
Hansen is committed to ensuring that it is open and transparent about the way it manages personal data. Set out in this Privacy Policy is the following important information regarding our management of your personal data:

(a) the kinds of personal data that Hansen collects and holds;

(b) how Hansen collects personal data and the purposes for which Hansen collects, holds and uses personal data;

(c) who Hansen discloses personal data to;

(d) how an individual may access personal data about the individual that is held by Hansen and seek the correction of such information; and

(e) how an individual may complain about a privacy issue or alleged breach of privacy and how Hansen will deal with such a complaint.

2. What personal data Hansen collects, from whom and the purpose for the collection?
Hansen will only collect personal data that is necessary for its functions and activities. It will only collect personal data by lawful and fair means and not in an obtrusive way. Hansen collects and holds different categories of information depending on the services being provided. We ensure that our staff are trained in regard to their obligations in handling personal data.

The following types of personal data may be collected:

(a) Information about customers and their employees and customers
When your company becomes a customer, or prospective customer of Hansen, then, in the course of establishing the business relationship, we may collect personal data about certain customer employees such as names and contact details. We may collect this information when you give it to us directly or when you use our products and services or visit our website.

Hansen’s website includes a Contact Us option for all visitors (see https://sitedev.hansencx.com/contact). If you complete and submit this form, you are providing consent for Hansen to use your contact information for the purpose in which it was provided.

All personal data collected by Hansen is solely used for our business functions and activities. It may be used to the extent that it is necessary for us to carry out our business of the supply of our products / solutions and services and to provide you with information in relation to our products/ solutions, services or other information that you may have requested.

Sometimes, as part of a service being provided to a customer, Hansen may also collect and retain, on behalf of that customer, personal data relating to that customer’s customers. In that scenario, Hansen is a data processer, and Hansen and the Customer will have a Data Processing Agreement in place. The personal data of the end customer will be collected directly from Hansen’s customer. An example of this would be when Hansen provides hosting or managed solutions on behalf of a customer or where we provide support or maintenance services for our customers and it is not reasonably practical to use anonymised materials. This personal data is solely held in accordance with our customer’s requirements and instructions so that we can facilitate provision of the services our customers have requested. If you are a current or former customer of one of Hansen’s customers and you wish to access, correct, amend or delete your personal data, please direct your request to the applicable Hansen customer first (ie, to the company which collected your personal data from you), and then, if no satisfactory response is received, please contact: privacyofficer@hansencx.com. Hansen will work with our customer to endeavour to resolve your request.

We will retain such personal data that we process on behalf of our customers only for as long as is needed to provide our services.

(b) Recruitment
In connection with a job application or inquiry, you may provide us with information about yourself, such as a resume. We may use this information throughout Hansen in order to address your inquiry or consider you for employment purposes. Unless you tell us not to do so, we may keep the information for future consideration. If you do apply for a job, you will be provided with an opportunity to consent to your personal data being collected and held, and how to request information about what personal data is being held about you.

(c) Information about Hansen’s Contractors and Suppliers
Hansen may collect personal data directly from our contractors and suppliers. This personal data will include their name and contact details so that we can contact them.

3. Quality of personal data
Hansen will ensure, to the extent reasonably possible, that personal data collected, used or disclosed is accurate, up-to-date, complete and relevant. If Hansen becomes aware that any of the personal data it holds is inaccurate it will take prompt steps to update its records so that those records are correct. Please be aware that in circumstances where Hansen is processing personal data on behalf of a customer of Hansen (as described above) we are unable to correct incorrect personal data, but we will work with our customer in regard to correcting any inaccuracy.

4. Data Security
Hansen takes active measures to ensure the security of personal data it holds from misuse, interference, loss and unauthorised access, modification or disclosure.

All personal data is stored at secure premises and is accessed only by authorised personnel for permitted purposes. Electronic personal data is stored using the highest quality data management tools and IT security systems and controls including passwords and firewalls.

When we no longer require your personal data, it is securely destroyed and disposed of. Our security systems are regularly reviewed and audited so that we can identify any potential security weaknesses and take steps to promptly rectify them.

Hansen complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States. Hansen has certified to the US Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Hansen has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution/American Arbitration Association (“AAA-ICDR”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of AAA-ICDR are provided at no cost to you. For complaints left unresolved by all other available channels, in certain circumstances you may be able to invoke binding arbitration before a Privacy Shield Panel.

5. Direct Marketing
Hansen will only engage in direct marketing practices in accordance with the law. At any time, you can request that it no longer receives any marketing material or information from Hansen.

6. Disclosure and retention of personal data, and transfers to third countries
Some of the information you provide to us may be transferred cross border. These are transfers to a “third country”. In most instances, the transfers will be to an affiliated company within the Hansen Technologies Group (these are listed in the appendix) given the global nature of Hansen’s business.

Wherever transfers of data to third counties occurs (even if it is to another company within the Hansen Technologies Group), Hansen puts in place appropriate contractual protections, which include strict rules regarding both the confidentiality and security of your information. In addition, we undertake data security due diligence on our partners and ensure that that these partners conform to appropriate accreditations.

We will not sell, rent, lease or transfer personal information to third parties other than business partners or agents. We will not disclose such information to business partners without first letting you know and offering you an opportunity to opt-out or otherwise prohibit disclosure to that business partner. We will also provide you the opportunity to let us know if you wish to opt out of all disclosures to business partners. We will only transfer personal information to our agent in order that such agent processes personal data pursuant to our instructions and only after assuring that the agent has privacy policies in effect for such data which are at least as stringent as those contained in this privacy policy.

We may also share your data with professional advisers such as our lawyers and insurers to manage risks and legal claims.

Hansen will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with lawful requests by public authorities, including to meet national security or law enforcement requirements from within or outside your country of residence, for example, Hansen is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting our business security.

Hansen only retains personal data for as long as required by law and needed for our business functions and activities. It is then securely destroyed and disposed of.  In case of onward transfer of personal information to third parties, Hansen is potentially liable.

7. Website browsing
Hansen’s website uses ‘cookies’ to keep track of your user session on our site for statistical purposes and will result in some information being logged including the time of access, your IP address and the pages that have been viewed or accessed. If you reject cookies, you can still use our website, but your ability to use some features may be limited.

Hansen’s website may include relevant hyperlinks to external websites not controlled by Hansen. Whilst all reasonable care has been exercised in selecting and providing any such links, Hansen does not verify the safety or security of the content which may be provided to you.

8. Access and Correction of personal data and Complaints
Subject to verification of your identity, if we hold personal data about you then you may make a request to access, update or correct this personal data at any time.

You may also request that we remove any personal data that we may hold. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Policy.

You may object to us continuing to use or disclose your personal data, where we are relying on a legitimate interest, (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

All requests to access, correct, or remove personal data and any complaint relating to the handling and management of personal data by Hansen or any breach of the applicable privacy laws, should be addressed to:

The Privacy Officer
Hansen Technologies
2 Frederick Street
Doncaster, VIC 3108
Australia

Email: privacyofficer@hansencx.com

There is no fee to make a request for access to your personal data. We will endeavour to respond to written requests for access and correction of personal data within 15 business days after a request is received by us, unless extenuating circumstances exist.

This Policy can be obtained via sitedev.hansencx.com or by contacting Hansen’s Privacy Officer at the address above.

Hansen’s Privacy Officer will commence an investigation into any complaint made by you to Hansen. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Privacy Commission at https://www.oaic.gov.au/ or if the complaint is GDPR-related, to the Information Commissioner’s Office at https://ico.org.uk

Hansen reserves the right to amend this Privacy Statement at any time. This Privacy Statement was last updated in May 2020.

Appendix
List and location of Hansen Technologies group entities.

Australia

Hansen Technologies Ltd
Hansen Corporation Pty Ltd
Hansen Corporation Investments Pty Ltd

New Zealand

Hansen New Zealand Ltd

UK

Hansen Holdings Europe Ltd
Hansen Corporation Europe Ltd
Hansen Billing Solutions Ltd

USA

Hansen Technologies North America, Inc
Hansen ICC, LLC
Hansen Banner, LLC
Hansen Solutions, LLC

Denmark

Hansen Technologies Denmark A/s

Norway

Hansen Technologies Holdings AS
Hansen Technologies Norway AS

Finland

PEP Finland Oy
Hansen Technologies Finland Oy
Hansen Technologies CIS Finland Oy
Enercube OY Finland

Sweden

Hansen Technologies Sweden AB

Netherlands
Enoro BV

Switzerland

Enoro AG

Vietnam

Hansen Technologies Vietnam Limited Liability Company

India

Hansen Customer Support India Private Ltd

Canada

Sigma Systems Canada LP