Privacy Policy

ANL Online Privacy Policy


General


In this document the term “ANL” means ANL Container Line Pty Ltd and ANL Singapore Pte Ltd all of their respective related bodies corporate.


This online Privacy Policy is provided to make you aware of how ANL collects, uses and manages information of visitors to its website and other electronic platforms.


ANL considers that the personal privacy of users of its electronic platforms is an important issue and it is committed to maintaining the security of personal information provided to ANL by the users of any ANL website or other media platform (including but not limited to Facebook, YouTube, Instagram and Twitter) which are collectively referred to here as “Platforms”. This Privacy Policy forms part of the terms of use of ANL Platforms and describes how ANL treats personal information that it receives through your use of ANL’s Platforms.



Controller


ANL has appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights in respect of your personal information, please contact ANL using the details set out below.


Email: Privacy@anl.com.au


Mail:


Privacy Officer


ANL Container Line Pty Ltd


GPO Box 2238


Melbourne Victoria 3001


If you believe ANL has incorrectly handled your personal information you can lodge a complaint using the above e-mail or address. ANL will review your complaint and attempt to resolve it as a priority.


ANL acknowledges every complaint we receive in writing and we will provide the relevant ANL contact person and a reference number for your complaint. ANL will also keep you updated on the progress of resolving the complaint.


If you are not satisfied with ANL’s handling of you complaint you are able to refer your complaint to an external review in your country of residence or business activity. In Australia the regulatory body for privacy issues is the Office of the Australian Information Commissioner (“OAIC”).


OAIC Contact Details


Phone: 1300 363 992


Online: ww.oaic.gov.au


Mail:


Office of the Australian Information Commissioner


GPO Box 5218


Sydney NSW 2001



Changes to ANL’s Privacy Policy


It is important that the personal data ANL holds about you is accurate. Please keep us informed if your personal data changes so that ANL can continue to serve you as expected. As regulations change ANL may update this Policy at any time, so please check this page regularly to ensure you are kept up to date. If ANL makes any significant changes to its Privacy Policy that would affect our relationship with you, we will let you know in advance.



Links to Third Parties


ANL Platforms may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. ANL does not control these third party websites and it is not responsible for their privacy statements. When you leave any of ANL’s Platforms you are encouraged to read the privacy notice of every website you visit.


Your interactions with third party platforms on ANL’s Platforms will be governed by the privacy terms of that third party, and ANL is not responsible for such interactions or for additional personal information you may decide to provide to such third parties. You are strongly advised to read any relevant third party's privacy and cookie policies prior to any such interaction.



What information does ANL collect and how is it used


Your personal data means any information from which you can be identified. It does not include data where your identity has been removed (anonymous data) or is not attached.? In going about ANL business we may collect, use, store and transfer various kinds of your personal data. The type of data ANL may collect from you includes the following:


  1. Identity data includes your name or other identifier, title, date of birth and gender.
  2. Contact data includes billing address, shipping address, email address and telephone numbers.
  3. Transaction data includes details about payments and other details of services and products you have purchased from ANL.
  4. Technical data includes your internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform plus the devices you use to access ANL Platforms.
  5. Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (if any given).
  6. Usage data includes information about how you use ANL’s website, products and services.
  7. Marketing and Communications data includes your preferences in receiving marketing from ANL and any third parties (where applicable).

ANL does not collect any special categories of Personal Data about you (which includes details about race or ethnicity, religious or philosophical beliefs, political opinions, etc).


Other than stated in the preceding paragraphs no attempt is made to identify users or their browsing activities except in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect logs, or where ANL believes it is required to collect and/or produce relevant electronic documentation to fulfil its obligations to third parties, including statutory organizations.


ANL endeavours to use and disclose your personal information only in limited circumstances. ANL will do so if it is necessary to protect any copyright or intellectual property in the material in the ANL Platforms, or if it is necessary to enforce the ANL website Terms and Conditions of Use.


ANL reserves the right to use third party advertisers to deliver advertisements to your web browser whilst you are viewing the ANL website. Except as specifically stated in this Privacy Policy ANL will not share your personally identifiable information with a company that is not associated with ANL.



How does ANL collect your Data


There are a number of ways in which data is collected by ANL including, but not limited to,:


  1. Direct communication. You may give ANL your ID, contact, profile and marketing and communications data by filling in forms or by corresponding with ANL by post, phone, e-mail or otherwise. This includes personal data you provide when you:
    a. Purchase ANL services and/or products;
    b. Create an account on any ANL Platforms;
    c. Request ANL marketing or newsletters to be sent to you; or
    d. Give ANL feedback – including complaints.
  2. Automated technologies or interactions. As you interact with ANL’s Platforms ANL may automatically collect technical data about your equipment, browsing actions and patterns. ANL use cookies, server logs and other similar technologies, and we may also receive technical data about you if you visit other websites (such as Facebook) employing ANL’s cookies.
  3. Third parties or publicly available sources. Although ANL does not buy in data, we may receive personal data about you from various third parties and public sources.


The use of Cookies


A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie file can contain information such as a user ID, that a website uses to track the pages visited. ANL may use cookies to maintain session state on the webserver. ANL does not use cookies to track where a user has been or identify them when they return to the ANL website.



How ANL uses Your Personal Data


ANL will only use your personal data when a relevant law permits ANL to do so. The following circumstances are examples of how ANL most commonly uses your data:


  1. Where ANL needs to fulfil the contract we are entering into or has entered into with you.
  2. Where it is necessary for our legitimate interests (if you have purchased a service or product from ANL) and your interests and fundamental rights do not override those interests.
  3. Where you have “opted in” to receive communications from ANL, for example newsletters.
  4. Where ANL needs to comply with a legal or regulatory obligation.

Notwithstanding the above you have the right to withdraw consent to ANL marketing at any time by contacting ANL directly or you can unsubscribe from any e-mail.



Direct Marketing


ANL may collect your information to provide you with notices relating to our services and products.


You can unsubscribe to ANL’s membership database at any time by the following the instructions contained in e-mail notifications.



Change of Purpose


ANL will only use your personal data for the purposes for which ANL collected it - unless we reasonably consider that ANL needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose please contact ANL.


If ANL needs to use your personal data for an unrelated purpose we will notify you and explain the legal basis which allows ANL to do so. ?Please note that ANL may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



Disclosure of your Personal Data


ANL may have to share your personal data with the parties set out below:


  1. Internal Third Parties - as set out in the Glossary at the end of this Policy.
  2. External Third Parties - as set out in the Glossary at the end of this Policy.
  3. Other third parties to whom ANL may choose to sell, transfer, or merge parts of its business or its assets.

ANL requires all third parties to respect the security of your personal data and to treat it in accordance with all applicable laws. ANL does not allow our third party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with ANL’s written instructions.



Data Retention


ANL will only keep your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.


The appropriate retention period for personal data depends on the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which ANL processes your personal data and whether ANL can achieve those purposes through other means, and applicable legal requirements.


By law ANL may have to keep certain basic information about our customers (including contact, identity and transaction data) for six years after they cease being customers for tax or other compliance purposes.


In some circumstances you can ask ANL to delete your data as set out in the below section on “Your Legal Rights”.


In some circumstances ANL may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case ANL may use this information indefinitely without further notice to you.



International Transfers


Generally ANL does not transfer your personal data internationally, and we will not do so unless this is absolutely necessary. Some of our ANL’s external third parties may be based outside the country where the data is collected or sourced including the European Economic Area (“EEA”) and the United States. Whenever ANL transfers your personal data internationally we ensure a similar degree of protection is afforded to it as in the original source country by ensuring at least one of the following safeguards is implemented:


  1. ANL will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Australian Government, Singapore Government, European Commission and/or US Federal Government.
  2. Where ANL uses providers based in the US we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.


Data Security


ANL has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.


In addition, ANL limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Such persons will only process your personal data on our instructions and they are subject to a duty of confidentiality.


ANL has put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where ANL is legally required to do so.


The above provisions noted; however, as far as permissible under law, ANL accepts no responsibility for the unauthorized access of personal information held by ANL.



Your Legal Rights


You should understand the specific legal rights available to you regarding privacy issues in the country in which you are residing; however, most countries’ privacy laws provide some or all of the following rights in respect of privacy of personal data:


  1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data ANL holds about you and to check that ANL is lawfully processing it.
  2. Request correction of the personal data that ANL holds about you. This enables you to have any incomplete or inaccurate data ANL holds about you corrected, although ANL may need to verify the accuracy of the new data you provide to us.
  3. Request erasure of your personal data. This enables you to ask ANL to delete or remove personal data where there is no good reason for ANL continuing to process it. You also have the right to ask ANL to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where ANL may have processed your information unlawfully or where ANL is required to erase your personal data to comply with local laws. Note; however, that ANL may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data. This is where ANL is 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 and freedoms. You also have the right to object where ANL is processing your personal data for direct marketing purposes. In some cases, ANL may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask ANL to suspend the processing of your personal data in the following scenarios:
    a. If you want ANL to establish the data's accuracy;
    b. Where ANL’s use of the data is unlawful but you do not want ANL to erase it;
    c. Where you need ANL to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    d. You have objected to ANL’s use of your data but we need to verify whether ANL has overriding legitimate grounds to use it.
    e. Request the transfer of your personal data to you or to a third party. ANL will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for ANL to use or where ANL used the information to perform a contract with you.
    f. Withdraw consent at any time where ANL is relying on consent to process your personal data. In this regard; however, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent then ANL may not be able to provide certain products or services to you. ANL will advise you if this is the case at the time you withdraw your consent.

Generally ANL will not charge any fee for making an initial request for the above actions and enquiries about your privacy issues generally. In some cases; however, ANL may charge a reasonable fee to cover the costs of compiling the relevant information requested by you – including (but not limited to) administration costs and photocopying costs, etc. If this is the case then ANL will first provide an estimate of any fees to be charged and you will be asked to confirm in writing your agreement to such fees.



Access to ANL’s e-Business


Access to any ANL e-Business website provides ANL’s customers with the ability to conduct e-commerce transactions. Users of ANL’s e-Business websites must register with the ANL membership database.


ANL will collect details in the membership database that are relevant to the use of any ANL e-Business website. ANL will not make membership details available to external parties.



Opting Out


You can ask ANL to stop sending you marketing or newsletter messages at any time by following the “opt out” links on any marketing message sent to you or by contacting ANL at any time. Where you opt out of receiving such messages this will not apply to personal data provided to ANL as a result of a product or service purchased, or other transactions with ANL.



Updating this Privacy Policy


ANL reserves the right to review and update the contents of this Privacy Policy at any time.



Disclaimer


Whilst ANL endeavours to ensure that all information provided on any ANL Platform is accurate and up to date, ANL takes no responsibility for any error or omission relating to any information on its Platforms or in this Privacy Policy.


To the maximum extent permitted by law ANL will not be liable for any cost, loss or damage suffered by you through your use of any ANL Platforms or ANL’s failure to provide access to any such Platforms or information updates.


Your use of all ANL Platforms is governed by the ANL website Terms and Conditions of Use.



Glossary


In this Policy the term “Third Parties” means:


  1. Service providers, including IT service entities whose servers are based within the EU and US, and who provide IT and system administration services.
  2. Professional advisers acting as processors or joint controllers including: lawyers, bankers, auditors and insurers based in the Australia and Singapore who provide consultancy, banking, legal, insurance and accounting services.
  3. Tax authorities, regulators and other authorities acting as processors or joint controllers, generally based in Australia and Singapore who require reporting of processing activities in certain circumstances.
  4. Organisations providing re-marketing services.