Nasa Consulting takes your privacy very seriously.
Your email address and contact details will be stored if you
subscribe to our newsletter, or when you submit an enquiry form,
agreeing that we may contact you.
We will never sell or distribute your contact details to any
third party and your contact details will always be stored in a
secure and encrypted format.
Contents
• Data Collection
• Data Security
• Data Use
• Data Disclosure
• Data Retention and Destruction
• Access by You to Your Personal Data
• Information about Data Handling Practices
• Handling of Enquiries, General Concerns and Complaints
• Enforcement
• Changes to These Privacy Undertakings
• Definitions
Data Collection
Nasa Consulting undertakes to collect your data by means that
are:
• fair;
• legal; and
• transparent.
If you visit Nasa Consulting web-site, your
web-browser automatically discloses, and Nasa Consulting web-server
automatically logs, the following information: the date and time,
the IP address from which you issued the request, the type of
browser and operating system you are using, the URL of any page
that referred you to the page, the URL you requested, and whether
your request was successful. This data may or may not be sufficient
to identify you.
Any additional data that you provide, e.g. in a web-form, may
also be logged. This data may or may not be sufficient to identify
you.
Any additional data that your web-browser automatically provides
may also be logged. This will be the case, for example, if your
browser has previously been requested to store data on your
computer in 'cookies' and submits them each time you request a
web-page within a particular domain (such as debi-online). This
data may or may not be sufficient to identify you.
If you disclose personal data to Nasa ConsultingI in conjunction
with an identifier such as your name or your credit-card details,
Nasa Consulting will collect Your Data. Moreover, any data that
becomes available to Nasa Consulting through any of the means
described in the preceding paragraphs may be able to be associated
with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, Nasa Consulting
undertakes to collect Your Data from you and not from other
parties. This undertaking is qualified as follows:
• where Nasa Consulting reasonably considers that the protection
of its financial interests requires that it gather YourData from
other sources, or from additional sources. This applies in
particular where Nasa Consulting has a lending exposure to you, and
seeks information about your creditworthiness;
• where Nasa Consulting reasonably considers that its capability
to deliver quality services to you will be materially enhanced by
gathering YourData from other sources. This applies in particular
to consumer profile data.
Where Nasa Consulting collects Your Data from sources other than
you, it undertakes:
• to do so only by legal means;
• to do so only with your Consent; and
• to declare to you what sources it uses, and under what
circumstances.
Nasa Consulting undertakes to declare the purpose of collection in
a manner which is clear and meaningful, and to avoid vague, highly
inclusive statements such as 'to support our operations'.
Data Security
Nasa Consulting undertakes to store Your Data in a manner
that ensures security against unauthorised access, alteration or
deletion, at a level commensurate with its sensitivity.
Nasa Consulting undertakes to store Your Data only in
jurisdictions where data protections are at least equivalent to
those required under the OECD Guidelines.
Nasa Consulting undertakes to transmit Your Data in a manner that
ensures security against unauthorised access, alteration or
deletion, at a level commensurate with its sensitivity.
Nasa Consulting undertakes to implement appropriate measures to
ensure security of Your Data against inappropriate behaviour by
Nasa Consulting staff-members and contractors. These include:
• training for staff in relation to privacy;
• access control, to limit access to Your Data to those staff and
contractors who have legitimate reasons to access it;
• particularly in the case of sensitive data, audit trails of
accesses, including the identities of staff and contractors
accessing the data;
• reminders to staff and contractors from time to time about the
importance of data privacy, and the consequences of inappropriate
behaviour;
• declaration of appropriately strong sanctions that are to be
applied in the event of inappropriate behaviour
• clear communication of policies and sanctions; and
• processes to audit, to investigate and to impose
sanctions.
Data Use
Use refers to the application of Your Data by any part of Nasa
Consulting, or any staff-member or contractor of Nasa Consulting in
the course of their work.
Nasa Consulting undertakes to use Your Data only for:
• the purposes for which it was collected;
• such other purposes as are subsequently agreed between Nasa
Consulting and You;
• such additional purposes as may be required by law. In these
circumstances, Nasa Consulting will take any reasonable steps
available to it to communicate to You that the use has occurred,
unless it is precluded from doing so by law; and
• such additional purposes as are authorised by law (in particular
to protect Nasa Consulting interests, e.g. if it believes on
reasonable grounds that You have failed to fulfil your undertakings
to Nasa Consulting or have committed a breach of the criminal
law).
Nasa Consulting undertakes to use YourData only if it has
demonstrable relevance to the particular use to which it is being
put.
Nasa Consulting undertakes to use YourData in such a manner as to
take into account the possibility that it is not of sufficient
quality for the purpose, e.g. because it is inaccurate,
out-of-date, incomplete, or out-of-context.
Data Disclosure
Disclosure refers to making YourData available to any
party other than Nasa Consulting and You. The term disclosure may
include many different conditions of data transfer, including
selling, renting, trading, sharing and giving.
Nasa Consulting undertakes to disclose Your Data only under the
following circumstances:
• in the course of business being conducted between You and Nasa
Consulting, where disclosure is necessary to a contractor, such as
a transport company. Where Your Data is disclosed in this way, Nasa
Consulting undertakes to exercise control over Nasa Consulting
contractors to ensure that their actions are compliant with these
Terms;
• in other circumstances that are directly implied by the purpose
agreed between You and Nasa Consulting at the time of data
collection or subsequently. Where Your Data is disclosed in this
way, Nasa Consulting undertakes to exercise control over Nasa
Consulting contractors to ensure that their actions are compliant
with these Terms;
• with your consent, or at your request;
• where required by law, such as a provision of a statute, or a
court order such as a search warrant or sub poena. In these
circumstances, Nasa Consulting will take any reasonable steps
available to it to communicate to You that the disclosure has
occurred, unless it is precluded from doing so by law;
• where permitted by law (e.g. the reporting of suspected breach
of the criminal law to a law enforcement agency; and in an
emergency, where Nasa Consulting believes on reasonable grounds
that the disclosure of YourData will materially assist in the
protection of the life of health of some person), provided that
Nasa Consulting will apply due diligence to ensure that the
exercise of the permission is justifiable.
In all cases, Nasa Consulting undertakes to disclose only such of
Your Data as is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below, Nasa Consulting
undertakes:
• to retain Your Data only as long as is consistent with its
purpose; and
• to destroy Your Data when its purpose has expired, and to do so
in such a manner that Your Data is not subsequently capable of
being recovered.
This undertaking is qualified as follows:
• Your Data may be retained in Nasa Consulting logs, backups and
audit trails within short-term retention cycles that are devised to
protect the company's operations. In such cases, Your Data will be
destroyed in accordance with those cycles;
• Your Data may be retained beyond the expiry of its purpose if
that is required by law, such as a provision of a statute, or a
court order such as a search warrant or sub poena, or a warning by
a law enforcement agency that delivery of a court order is
imminent. In these circumstances, Nasa Consulting :
o will take any reasonable steps available to it to communicate to
You that Your Data is being retained, unless it is precluded from
doing so by law; and
o will only retain Your Data while that provision is current, and
will then destroy Your Data;
• Your Data may be retained beyond the expiry of its purpose if it
is authorised by law (in particular to protect Nasa Consulting
interests, e.g. if it believes on reasonable grounds that You have
failed to fulfil your undertakings to Nasa Consulting or have
committed a breach of the criminal law). In these circumstances,
Nasa Consulting will only retain Your Data while that situation is
current, and will then destroy Your Data.
Access by You to Your Personal Data
Nasa Consulting undertakes to provide you with access to
Your Data, subject to only such conditions and processes as are
reasonable in the circumstances. In particular, Nasa Consulting
undertakes to enable access:
• conveniently;
• without unreasonable delay; and
• without cost.
Nasa Consulting undertakes to establish and operate identity
authentication protections for access to Your Data that are
appropriate to its sensitivity, but practical. This may involve
some inconvenience; for example, relatively straightforward
procedures may be involved in order to provide you with access
through a channel that you have previously registered with Nasa
Consulting (such as a particular email-address), but may impose
more onerous procedures if you wish to use some other
channel.
In the event that you dispute some aspect of Your Data, Nasa
Consulting undertakes to take reasonable steps in relation to the
amendment, supplementation or deletion of Your Data.
You undertake:
• not to seek access for frivolous purposes, or unreasonably
frequently;
• to accept that deletion of some data may not be consistent with
the provision of particular services by Nasa Consulting to
you.
Information about Data-Handling Practices
Nasa Consulting undertakes to make information available to you
about the manner in which DEBI handles your data:
• in general terms, in a readily accessible manner; and
• in more specific terms, on request.
Where Your Data is disclosed to a contractor, Nasa Consulting
undertakes to make information available to you on request about
the manner in which Nasa Consulting contractors handle your
data.
Nasa Consulting undertakes to ensure that the information provided
is meaningful, and addresses your concerns.
You undertake:
• not to seek such information for frivolous purposes, or
unreasonably frequently; and
• to accept that the disclosure of excessive detail may harm the
security of Your Data and Nasa Consulting business processes, and
may harm Nasa Consulting commercial interests.
Handling of Enquiries, General Concerns and
Complaints
If you have enquiries, general concerns, or complaints
about these Terms, or about Nasa Consulting behaviour in relation
to these Terms, you undertake:
• to communicate them in the first instance:
o to Nasa Consulting only;
o in sufficient detail;
o through a channel made available by Nasa Consulting for that
purpose;
Nasa Consulting undertakes:
• to provide one or more channels for communications to Nasa
Consulting , which are convenient to users;
• to promptly provide acknowledgement of the receipt of
communications, including the provision of a copy of the
communication, the date and time it was registered, and Nasa
Consulting reference-code for the communication;
• to promptly provide a response to the communication, in an
appropriate and meaningful manner.
You further undertake to not pursue Nasa Consulting through any
Regulator or the media:
• until and unless Nasa Consulting has had a reasonable
opportunity to respond to the initial communication; and
• while Nasa Consulting and you remain are conducting a meaningful
dialogue about the matter.
Enforcement
Nasa Consulting declares that its undertakings in these Terms are
intended to create legal obligations, and that those obligations
are intended to be enforceable under appropriate laws in
appropriate jurisdictions. These include laws relating to data
protection, privacy, fair trading, corporations and criminal
laws.
You undertake to seek enforcement only in a jurisdiction that is
relevant to the transactions that have taken place between You and
Nasa Consulting , in particular the jurisdiction in which you live
or in which you performed the relevant acts, and the jurisdiction
in which Nasa Consulting is domiciled or performed the relevant
acts.
If you wish to discover the relevant laws in any particular
jurisdiction, DEBI draws your attention to the following
resources:
• WorldLII Privacy Links
• Compilation of [U.S.] State and Federal Privacy Laws, Privacy
Journal, Providence RI
• Privacy Law Sourcebook 2004, EPIC, Washington DC
• the Australian Privacy Foundation's pages:
o International Instruments Relating to Privacy Law
o Privacy Laws of Countries of the World
o Privacy Laws of the Commonwealth of Australia
o Privacy Laws of the States and Territories of Australia
• Privacy International
Changes to These Privacy Undertakings
Nasa Consulting undertakes:
• not to materially change these Terms in a manner that reduces
the protections for Your Data;
• to take all possible steps to prevent any company that acquires
this company or any of its relevant assets from materially changing
the Terms applicable to Your Data in a manner that reduces the
protections for Your Data;
• where it is considering making changes to these Terms, or
creating more specific Terms relating to specific services, to
consult with appropriate representative and advocacy
organisations;
• where it makes changes to these Terms, to ensure that the
differences between successive versions are readily
accessible;
• to maintain all prior versions of these Terms in such a manner
that they are dated, and readily accessible.
Definitions
Nasa means Nasa Consulting Ltd.
Your Data means data that is capable of being associated with you,
whether or not it includes an explicit identifier such as your name
or customer number. In particular, it encompasses all data that
Nasa Consulting is capable of correlating with you, using such
means as server-logs and cookie-contents.
Your Data does not refer to data that can no longer be associated
with you. This includes aggregated data that does not and cannot
identify the individuals whose data are included in the
aggregation.
Consent means your concurrence with an action to be taken by Nasa
Consulting. Consent may be express or implicit, but in either case
must be informed and freely-given.