Governance
Privacy Policy
Upstream is committed to protecting your privacy. Any information collected is handled in accordance with our privacy policy, which outlines how data is gathered, used, and stored. By using our services or submitting information through our site, you agree to our privacy practices.
Upstream Technology’s Commitment to Your Right to Privacy
Upstream Technology Pty Ltd (“Upstream”, “we”, “our” or “us”) respects your privacy and is committed to protecting your personal information. Upstream has created this Privacy Policy in order to demonstrate its firm commitment to the protection of your privacy and to the requirements of the Australian Privacy Act 1988 (Cth) (as amended) (“the Act”) and Australia’s Australian Privacy Principles (“APPs”).
References to “personal information” in this Policy mean information or an opinion that identifies you or from which you are reasonably identifiable whether true or not, or in a material form or not. Personal information we collect may include your name, address, telephone number, payment details, communications with us or our partners, email address and photographs and images that are provided to us as well as information on the products and services you purchase from us.
Upstream complies with the Act and the APPs.
1. How we collect your Personal Information
We may collect personal information about you, including when you purchase our products and services, contact us regarding our products and services, visit our website and provide us with your personal information, register to receive our newsletters or other communications, or otherwise interact with us, including where you are a business contact or otherwise associated with one of our business partners, suppliers or customers. We will collect your personal information directly from you when we can. We may also collect your personal information from third parties.
2. Purposes for Collecting, Holding, Using or Disclosing Personal Information
Upstream collects the personal information it requires and holds, uses or discloses that personal information for the following purposes:-
- Selling, promoting and providing products and services requested by you.
- Responding to communications from you.
- Providing you with information that you request (by post, telephone or email).
- Engaging with you as a business contact in respect of your role with one of our business partners, suppliers or customers.
- Sending you additional information on our products and services which we think may be of interest to you.
- Sending you information on products and services of our select business partners which we think may be of interest to you.
3. Electing Not to Receive Additional Information on Products and Services
If you do not wish to receive additional information on our products and services or on the products and services of our select business partners, you can request that we do not end that additional information to you by contacting us as detailed below.
If you supply us with your personal information via our website, you may utilise a function on that website to “opt out” from receiving that additional information at the time you supply us with your personal information via that website.
When that additional information is sent to you by email, you can utilise a function linked to that email to “opt out” from receiving further additional information.
Upstream will honour and respect any request made by you in any of the ways outlined above to cease receiving that additional information.
4. Provision of Personal Information to Contractors, Related Companies and Business Partners
It is sometimes necessary for us to pass on some of your personal information and your requested delivery information to other organisations which are contracted by us (or our related companies) to assist in providing some products and services. We require these organisations to have compliant privacy procedures in place and to only use your personal information to assist us in providing those products and services and for no other purpose.
Upstream may also, from time to time, select and send you information on the products and services of our business partners which we think may be of interest to you (unless you have already opted out). Each time such information is sent to you, you will have the opportunity to opt out. If at any time you do not wish to receive that information, you should take the opportunity at that time to opt out from receiving or continuing to receive that information.
Except in the circumstances described above, we will not disclose or share any personal information with our business partners unless we request and/or you give us your specific permission to do so. Upstream may, however, develop general reports incorporating some personal information in a de-personalised format for use by our business partners.
When you engage with third-party providers on our site, the collection and use of the personal information may also be governed by the privacy policy provided to you by the third-party provider. It is your own choice whether or not you decide to disclose any personal information to these third-party providers.
5. Cookies
Upstream may collect identifiable information from visits to our websites to help us provide better customer service through the use of various technologies, including “cookies”. A cookie is a piece of data that a website can send to your browser which may then be stored on your computer as a tag that identifies your computer and /or the computer user. Such technologies enable Upstream to measure and analyse, for example, visitor activity on the website, visits to web pages and the domains from which people visit. This information assists Upstream in understanding trends and patterns and helps to serve you better when you return to the website or when a new product or service becomes available. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies. If you turn off cookies, there may be some features and pages of Upstream’s site that will not display properly to you.
6. Consent to Use of Personal Information
Provided Upstream complies with the requirements set out in this Policy, the provision by you of personal information to Upstream amounts to consent to the use of that personal information for the purpose for which it was provided and for any of the purposes set out in this Policy. Other than described above, Upstream will not use, sell or disclose your personal information without your consent.
7. Websites of Third Parties
Where our website contains links to or from other websites (which are not operated by Upstream), we will not be responsible for the privacy practices of the operators of those other websites (“third-party sites”). You should check the privacy practices of those third-party sites. Links to and from our website to any of those third-party sites does not amount to an endorsement by Upstream of any of those other websites or their content.
8. How we Hold Personal Information and the Security of Personal Information
We hold your personal information in a combination of hard copy and electronic files.
Upstream holds all personal information securely. Except for the provision of personal information to contractors and business partners for the purposes referred to in the paragraphs above, access is restricted to Upstream employees who need the personal information for a designated purpose. Additional security measures, including secure locked areas, a high level of commercially available encryption for financial transactions online and secure disposal procedures, have been implemented.
9. Privacy Complaints and Further Information
If you wish to make a complaint about a breach of the APPs or any privacy code which may bind us, have a concern about your privacy or you have any query on how your personal information is collected or used, please contact us using the details below. We will respond to your query or complaint within a reasonable time. If you are dissatisfied with the response that you receive from us, you may make a complaint to the Office of the Australian Information Commissioner (OAIC).
10. Access to and Correction of Personal Information about You
You have a right to access your personal information which Upstream collects and holds about you.
If you wish to see your personal information, change or update your details, please contact us using the details below.
The Privacy Officer
Upstream Technology Pty Ltd
21 Elliot Street, Balmain NSW
Telephone: 1300 877 111
Email: [email protected]
Anti-Slavery Policy Statement
This policy reflects Upstream Technology’s commitment to ensuring to the best of our ability that no modern slavery, as defined in the Modern Slavery Act 2018 (Cth), occurs in any part of our business operations or supply chain. We are committed to acting ethically and with integrity in all business dealings and relationships.
1. Our Commitment
As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.
Our business also expects its service providers, suppliers and contractors to share our commitment to act lawfully and ethically and to work to ensure that modern slavery is not taking place within their organisations or supply chains.
Definitions
The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. We understand that coercion, threats and deception can be explicit or implicit.
The Modern Slavery Act 2018 (Cth) defines modern slavery as including eight types of serious exploitation: trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, the worst forms of child labour, and deceptive recruiting for labour or services.
The ‘worst forms of child labour’ means extreme forms of child labour that involve the serious exploitation of children, including through enslavement or exposure to dangerous work. The ‘worst forms of child labour’ does not mean all child work.
Under Australian law, modern slavery is defined in the Modern Slavery Act 2018 (Cth). In the event of any inconsistency, the definitions in the Act take precedence over this policy.
2. Upstream Technology: Our Products and Services
Upstream Technology Pty Ltd (‘Upstream’) is a 100% Australian-owned and -operated Australian Private Company.
It has two offices in Australia – the headquarters in Sydney and an office in Melbourne.
Upstream operates as a sales & service organisation supplying Australian businesses with multifunction print devices and associated software. The products supported are sourced through tier 1 reputable suppliers such as Fujifilm, Lexmark and HP.
We partner with leading local players across various industries to deliver world-class products and customer service. In doing so, we support local people and jobs in customer support, logistics, professional trades and sales.
3. Risks of Modern Slavery Practices
While we are not directly involved in the majority of the manufacturing process, Upstream understands the risks associated with:
- A lack of transparency in supply chains that makes it difficult to trace the origin of raw materials and components used in its products. This creates opportunities for unscrupulous actors to exploit vulnerable workers through forced labour and human trafficking.
- Subcontracting and informal labour practices that make it challenging to monitor labour conditions and ensure compliance with labour standards.
- Inadequate monitoring that leads to a lack of oversight, enabling modern slavery practices to persist undetected.
- Limited enforcement of labour laws and weak penalties for non-compliance, contributing to the perpetuation of these practices.
- Unethical recruitment practices and debt bondage that make it nearly impossible for workers to escape exploitative conditions, especially in labour-intensive operations.
We have assessed our operations for modern slavery-related risks and established a low-risk profile given our local operations, which are handled by staff directly employed by us.
Currently, our highest risk area is our suppliers’ offshore manufacturing and logistics operations.
4. Risk Mitigation
Upstream’s Code of Ethics defines how it conducts its business in an ethical manner to:
- Offer products and services that deliver the highest standards of safety, performance and innovation; and
- Safeguard the health, dignity and safety of workers.
- Engage with reputable suppliers and contractors and avoid agreements with suppliers of questionable reputation in environment-related issues, working conditions, and/or human rights issues.
- Create stakeholder value based on trust and open communication.
Upstream seeks at all times to adopt legal and ethical behaviours in line with internationally accepted standards and principles concerning the treatment of its employees and workers, particularly the protection of basic rights, non-discrimination, protection of children, prohibition of forced labour, protection of trade union rights, occupational health and safety, working hours and remuneration. Upstream expects its suppliers and partners to adhere to the same standard.
Upstream acknowledges that open communication with the suppliers is a critical component in developing an appropriate plan to avoid a modern slavery situation.
5. Ongoing Commitment
As Upstream evolves its business over time, it commits to reviewing the effectiveness of its Modern Slavery Risk Management and strengthening or introducing new measures as needed.
Upstream also commits to responding promptly to grievances and reporting any such grievances to the Board of Directors.
To promote transparency and mitigate the Modern Slavery risk from suppliers outside Upstream’s direct control, Upstream commits to regularly reviewing its product range and services.
Upstream will clearly communicate its commitment to anti-slavery to its suppliers.
Upstream will subject all new and renewing suppliers to a due diligence process. This helps Upstream to identify areas of non-compliance with its Code of Ethics or potential areas of risk.
Upstream conducts training for all employees on the requirements of the Modern Slavery Act 2018 (Cth).
This statement constitutes Upstream’s Modern Slavery Statement and has been endorsed by the Board of Directors May 20th 2024.