Privacy Policy

Introduction

Holocron Cyber is a cyber security managed service provider and cyber security consultancy agent. As a part of our services, we collect information about and may process data from businesses to support the delivery of our cyber security related services. We understand that you care about how your personal information is used and shared and we take your privacy seriously. For this reason, we collect and use personal data only as it might be needed for us to deliver our products and services.

We can collect and process your data with your consent. In many circumstances, if we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. It is important to be aware, that by using or accessing our products and services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you consent to us collecting, using and sharing your information as stated below.

Applicability of the Privacy Policy

This Privacy Policy applies to the Holocron Cyber website, and the services that we provide to our customers. This Privacy Policy includes examples of the types of personal information we collect and the kinds of companies with whom we share such information.

This Privacy Policy does not apply to any third-party applications or software that integrates with the services that we provide, or any other third-party products, services or businesses.

In addition, any separate agreements or contracts with Holocron Cyber customers will govern the delivery, access and use of the products and services provided by Holocron Cyber as per the signed agreement or contract.

What Kind of Personal Data do we Collect?

To deliver our services effectively to customers, Holocron Cyber is required to collect information about our customers and their business that may include personal information:

  • Your Name

  • Job Title & Position in your organisation

  • Phone Number

  • Email Address

  • Location

  • IP Address

  • Affiliations, dealings and transactions with us

 

Holocron Cyber will only utilise this information to communicate with you for operational matters applicable to the products and services you have purchased.

If you apply to work with us, we also collect information about your education, experience, character and background checks including eligibility to work, vocational suitability, identity, reference, directorship, and criminal record checks.

In addition, if you join us, we collect information about your employment or engagement including information about your performance, conduct, use of our IT resources and payroll matters. We collect some of this personal information under laws including the Corporations Act, Fair Work Act, Superannuation Guarantee (Administration) Act, and Income Tax Assessment Act.

Why we collect and handle personal information

Holocron Cyber collect personal information to enable us to:

  • Establish, manage, and maintain our business relationships.

  • Respond to enquiries and requests from individuals and businesses. For example, when customers ask us to respond to tenders, requests for proposals or information, or for reports to be emailed, faxed or posted.

  • Recruit and consider potential employees or applications for employment with us.

  • Consider a potential contractor’s engagement with us.

  • Open and administer our client accounts during sales and the delivery cycle.

  • Manage marketing and sales initiatives such as our publications, information about our service offerings, events and other business programs. For example, when customers ask to be on an email or mailing list so that we can send them information about our activities and our publications, e.g. cyber security alerts.

  • Develop, provide, and improve our services and solution.

  • Inform about our services and solutions.

  • Obtain feedback on our services and solutions.

  • Conduct administrative and business functions.

  • Update our records and keep contact details up to date.

  • Enable you to subscribe to newsletters and mailing lists.

  • Process and respond to privacy questions, concerns and complaints.

  • Fulfil legal and contractual obligations.

  • Undertake any other purpose related to or ancillary to any of the above.

 

If you do not provide us with all or part of your personal information, we may not be able to carry out the purposes which are set out above, including the provision of services to you.

How we collect personal information

We endeavour to collect personal information directly from the individual or their authorised representative, in ways including:

  • From the individual directly when they provide details to us. This could be when an individual contact us by telephone or electronic communications, or when an individual provides us a business card.

  • When we conduct our administrative and business functions.

  • When the individual purchases our solutions and services.

  • When we purchase products and services.

  • When the individual creates an account with us.

  • When we process orders and payment transactions.

  • Where we respond to inquiries and requests.

  • When obtaining feedback about our solutions and services.

  • When registering for our events, workshops and seminars.

 

Sometimes we collect personal information from a third party, such as our customers or partners, or other third-party companies such as data providers, credit reporting bodies, law enforcement agencies, recruitment companies or publicly available sources.

How we Share Information

Holocron Cyber only use and disclose personal information for the purposes for which it was given to us, or for purposes that are directly related to one of our functions or activities.  For example:

  • When customers ask to be on an email or mailing list so that we can send them information about its activities and publications, e.g. cyber security alerts.

  • When customers ask us to respond to Tender, Request for Proposal, Request for Information or reports to be emailed, faxed or posted with contact information.

  • If you are a contact person for one of our customers or suppliers, personal information about you may be used by us in our dealings with the customer or supplier you represent.

 

We may exchange your personal information with third parties including your organisation, our advisers and representatives, government authorities, our related entities, and our advisors and contractors.

If you apply to work with us, we may exchange your personal information with educational institutions, recruiters, background checking services, professional and trade associations, law enforcement agencies, referees and your current and previous employers. In addition, if you join us, we may exchange your personal information with your representatives, other employers seeking a reference about you and providers of payroll, superannuation, banking, surveillance and training services.

Disclosures Required by Law

Holocron Cyber will disclose required information in response to subpoenas, court orders, or legal process, from law enforcement agencies or state and federal regulators.

In the event that we sell or otherwise transfer substantially all of our assets related to any website that we own or operate and any product or service that we offer, Holocron Cyber will be required to disclose certain information. In that event, we will require such third party to honour our current Privacy Policy, until the third party provides you with notice of changes to our Privacy Policy and permits you to exercise any rights you may have under applicable law to limit disclosures of information about you.

Overseas Recipients

We may disclose personal information to our related bodies corporate, third party suppliers and service providers located overseas. Some of our employees are located overseas. Except where specific individual consent has been obtained, we take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

We may disclose your personal information to entities located overseas, including the following:

  • Our related bodies corporate located in Australia, United States of America and the United Kingdom

  • Our data hosting and other IT service providers, located globally

  • Our clients and their related entities located in foreign countries, to the extent that we are acting on their behalf or at their direction in using, storing, or collecting your personal information.

Data Quality

We take steps to ensure that the personal information we collect is accurate, up to date and complete. These steps include maintaining and updating personal information when individuals advise us that their personal information has changed, and at other times as necessary. Any changes, relevant omissions or inaccuracies in their personal information will be updated as soon as practicable.

Privacy, cookies and our Website

This section applies in addition to the other parts of this Privacy Policy where you access our Website, which is the website under the domain name “www.holocroncyber.au”.

As you navigate our Website, certain information may be collected passively, including your Internet protocol address, browser type, domain names, times, and operating system. We may also use session and persistent cookies and navigational data (such as URLs) to gather information regarding the date and time of your visit and the information and services for which you searched and which you viewed. We do not intentionally gather personal information about visitors who are minors.

Our Website may use ‘cookies’ from time to time, as do many other websites. A cookie is a piece of information that helps our system to identify and interact more effectively with your browser. The cookie allows us to maintain the continuity of your browsing session and remember your details and preferences when you return. You can configure your web browser application to reject cookies however some parts of our Website may not function fully as a result. Our Website may use Google services such as Google Analytics from time to time. For more about how Google collects and processes data, and your privacy choices with Google, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/

What can you do if you don't want cookies to be set or want them to be removed?

If you decide that you do not wish for cookies to be allowed, you have the option to change your browser settings and manage cookies accordingly. In some browsers, it is possible to change your privacy settings and manage your cookies on a site-by-site basis. This means that you have the option to deny the placement of cookies from all sites except those you indicate explicitly.

The below links are examples of popular browser manufacturers that provide help pages to assist in managing cookies when using their browser. This list is not an exclusive list of browsers, so please refer to any documentation that your browser manufacture provides if it is not listed below.

  • Google Chrome

  • Internet Explorer

  • Mozilla Firefox

  • Safari (Desktop)

  • Safari (Mobile)

It is important to be aware, that if you do choose to limit the ability of websites and applications to set cookies, you may decrease your overall user experience. It may also stop you from saving customized settings, like login information.

Your Personal Data Rights

Individuals located in certain countries, including the European Union, have certain statutory rights in relation to their personal data that is stored by Holocron Cyber. Subject to any exemptions provided by law, individuals within the European Union may have the following rights:

  1. The right to access – The right to request copies of your personal information from us.

  2. Right to correct – The right to have your personal information rectified if it is inaccurate or incomplete.

  3. Right to erase – The right to request that we delete or remove your personal information where technically feasible.

  4. Right to restrict our use of your information – The right to ‘block’ us from using your personal information or limit the way in which we can use it.

  5. Right to data portability – The right to request that we move, copy or transfer your personal information.

  6. Right to object – The right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling to inform our market research.

Exercising an individual’s rights on personal data

To exercise any of these rights Holocron Cyber mentioned above, including if you wish to get access to the personal information we hold about you, or request that we change that personal information, we will allow access or make the changes unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make the changes.

Data Security & Retention

Data Security

We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We implement a range of measures to protect the security of personal information, including – depending on the circumstances – electronic access controls, premises security and network firewalls. Even though we have taken significant steps to ensure that your personal information is not intercepted, accessed, used, or disclosed by unauthorised persons, you should know that we cannot fully eliminate security risks associated with personal information.

Data Retention

Holocron Cyber will retain personal data only for as long as necessary to provide the services that have been requested and thereafter for a variety of legitimate legal or business purposes. These reasons may vary according to required retention period or ongoing business needs. These business purposes may be if Holocron Cyber is:

  • Required by law, contract or similar obligations applicable to our business operations;

  • Preserving, resolving, defending or enforcing our legal/contractual rights; or

  • Required to allow maintenance of adequate and accurate business records.

Policy Changes

Holocron Cyber may change this policy as required to account for any new business practices or to reflect any changes in law or best practice to in relation to data protection. The date of the most recent revision will appear on this page.

If we make significant changes, we will make that clear on the Holocron Cyber website or other Holocron Cyber services, or by some other means of contact such as email, so that you are able to review the changes. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.

Contact Us

If you have any questions, concerns or complaints about our privacy policy please send contacts us through one of the following methods:

Phone:  1300 650 263
Email:  [email protected]

We will respond to all requests, inquiries or concerns within thirty (30) days.

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