The privacy of your personal information is important to us at HAL Communications Corp. and each of its controlled entities.

HAL Communications Corp. is bound by the Federal Trade Commission Act (15 U.S.C. §§41-58) (FTC Act), the Australian Privacy Act 1988 and subsequent amendments and EU General Data Protection Regulation (GDPR) regarding the manner in which we handle your personal information, and we will strictly comply with all relevant legislative requirements.

This Privacy Policy sets out our information handling procedures and the rights and obligations that both you and we have in relation to your personal information. In the event of any inconsistency, the legislative requirements will override the provisions of this document.

What kinds of personal information do we collect?
The kinds of personal information that we collect and hold include:
• your contact information, including name, company, position title, postal and residential addresses, country, telephone number, and email addresses;
• details of the make and model of any product you purchase from us;
• data relating to your activity on our websites via tracking technologies such as but not limited to cookies and google analytics;
• details of any survey responses you provide;
• bank account and tax file details; and
• for job applicants or staff, employment history, educational qualifications, reference checks, payroll information and medical information (where relevant).

Who do we collect information from?
Our Website is intended for people over the age of 13 years. No one under the age of 13 may provide any information to the Website. We do not knowingly collect personal information from people under 13. If we learn we have collected or received personal information from a person under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 13, please contact our Privacy Officer.

How do we collect personal information?
We will only collect personal information where it is reasonably necessary to do so for the conduct of our business. Any collection of personal information by us will be fair and lawful and will not be intrusive.

We will collect personal information about you in the following ways:
• if you provide your information by telephone, post, email or facsimile, or in person (such as at industry events and Trade Shows);
• if you contact us via email or submit your information through one of our websites;
• if you purchase products from us, or require us to provide services to you.

If it is reasonable and practical to do so, we will collect personal information about you only from you. In the course of operating our business, however, we may collect personal information from third parties such as suppliers, advertisers, mailing lists, recruitment agencies, contractors and business partners. If we collect personal information about you from a third party we will, contact you to gain acceptance to use it and correct and update the information.

How do we hold personal information?
We will hold personal information as either physical records, records on our servers, and in some cases, records on third party servers, which may be located overseas.

We take active steps to hold all hard copy and electronic records of personal information in a secure manner to ensure that they are protected from misuse, interference and loss, and unauthorised access, modification or disclosure.

We have procedures in place to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

Purposes for which we collect, hold, use and disclose personal information.
In general, members of HAL Communications Corp. will collect, hold, use and disclose personal information for the purposes of providing or offering goods and services to you.

By providing us with your personal information, you consent to us using and disclosing your personal information for the following purposes:
• providing you with news and information about our products and services;
• sending you marketing and promotional material that we believe you may be interested in;
• personalising your experience with our products and services;
• for job applicants, assessing your eligibility for employment within HAL Communications Corp.; and
• disclosing that information to third parties (such as our agents and dealers and government departments) to undertake the above purposes on our behalf.

You may opt out of receiving marketing and promotional material from HAL Communications Corp. at any time by contacting our Privacy Officer.

Most of our website does not require any form of registration, allowing you to visit our site without telling us who you are. However, some services may require you to provide us with personal data. In these situations, if you choose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of the site and for us to respond to your query or provide a quote.

There may be circumstances in which we are authorised or required by law to use or disclose your personal information. We may also use or disclose personal information about you to avoid, lessen or prevent a serious emergency or crime. If we use or disclose personal information about you in those circumstances we will make a written record of such use or disclosure. We may disclose personal information between our related bodies corporate or to third parties such as our suppliers, organisations that provide us with marketing, technical and support services, or our professional advisors, where permitted by the Privacy Act.

You can visit our website without providing your personal information. The HAL Communications Corp. website uses Google Analytics and Cookies in order to improve our service, user experience and analyse how the website is used. Aside from the approximate location, the information collect by Google Analytics is anonymous traffic data including browsers information, device information and language.

How long will we keep your personal information?
We only retain the Personal Data collected from a user for as long as the User’s account is active or otherwise for a limited period of time as long as we need tit to fulfil the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements as follows:
• billing information is retained for a period of 7 years as of their provision in accordance with the Australian accounting and taxation law.
• information on legal transactions between customers and HAL Communications Corp. is retained for a period of 10 years.

How can you access your personal information?
You have a right to request access to your personal information and to request its correction if it is out of date or incorrect. You may request access or correction at any time by sending a written request to our Privacy Officer.

You do not need to provide a reason for your request for access to your personal information. We may charge a small fee for providing access to your personal information if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form.

We will not charge you to correct your personal information that we hold in our records. We will respond to all requests for access to or correction of personal information within a reasonable time.

Please note there may be circumstances in which we are not able to provide you with access to your information, such as where the requested access will have an unreasonable impact upon the privacy of others or where we are required by law to withhold the information.

If we are unable to provide you with access to your information, or make the amendments which you have requested, we will provide you with reasons for this decision.

Cross Border Disclosures of Information
We may disclose your personal information to overseas recipients in the following circumstances:
• to any members of HAL Communications Corp. that are located overseas (with our offices currently operating in Australia, the United Kingdom and the United States of America;
• to our vendors and/or service providers who provide dealer or agent services to customers for us;
• any courts, tribunals and regulatory authorities that are based overseas, where disclosure is required by law. We will take reasonable measures to ensure that such disclosure is in compliance with the requirements of the Australian Privacy Act 1988 or EU General Data Protection Regulation (GDPR). As at the date of this Privacy Policy, HAL Communications Corp. is not likely to disclose personal information to other overseas recipients.

By providing your personal information to us, you consent to us disclosing your personal information to the above overseas recipients and agree that OAIC Guidelines APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able seek redress under the Act. If you do not want us to disclose your information to overseas recipients, please let us know.

Complaint procedures
If you believe that we may have breached the Federal Trade Commission Act (15 U.S.C. §§41-58) (FTC Act), Australian Privacy Act 1988 or EU General Data Protection Regulation (GDPR), or failed to comply with this policy, you may direct your complaint to our Privacy Officer.

We take all complaints seriously, and will respond to your complaint within a reasonable period.

Where practicable, we are required to provide the option for you to deal with us anonymously or under a pseudonym. This option will not be available where we are required or authorised by law to deal with individuals who have identified themselves, or if we need to verify your identity in order to provide products or services to you. This document reflects our Privacy Policy as at 1 June 2018. We may amend our Privacy Policy at any time by posting an updated Privacy Policy on our website. The date of this Privacy Policy will inform you as to whether there have been updates since your last visit to our website.

Privacy Officer
Our Privacy Officer can be contacted as follows:

Privacy Officer
HAL Communications Corp.
3111 Village Office Place
Champaign, Illinois 61822
United States of America
Telephone: +1 217 367 7373