Privacy Policy
Effective: 28 April 2026 · ToneCooling Australia Pty Ltd · ABN 96 653 174 040
This Privacy Policy explains how ToneCooling Australia Pty Ltd ("ToneCooling Australia", "we", "us") collects, uses, discloses, stores, and protects your personal information in accordance with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs).
1. Who we are
ToneCooling Australia Pty Ltd is the Australian customer engineering support and supply entity within the ToneCooling group. Our registered office is Suite 69, 139 Cardigan Street, Carlton VIC 3053, Australia. We can be contacted at info@tonecooling.com.au or +61 420 936 669.
2. What personal information we collect (APP 3)
We collect personal information that is necessary for our business functions and activities. This includes:
- Identity information: name, job title, employer organisation
- Contact information: business email, business phone, business address
- Engineering enquiry information: design specifications, TDP maps, drawings (under NDA where applicable)
- Commercial information: ABN, GST registration status, payment terms preferences, banking details for invoicing
- Website usage information: IP address, browser, device, pages visited, referrer URL (via standard server logs and analytics)
We do not knowingly collect sensitive information (as defined in the Privacy Act) unless you provide it to us as part of an engineering enquiry that requires such information.
3. How we collect personal information (APP 3 & 5)
We collect personal information directly from you when you:
- Submit an RFQ via our website contact form, by email, or by phone
- Sign an NDA or commercial agreement with us
- Subscribe to engineering reference content or download a design guide
- Visit our website (passive collection via standard server logs and analytics)
- Communicate with us by phone, email, video conference, or in person
4. Why we collect personal information (APP 6)
We use personal information for the following primary purposes:
- Responding to engineering enquiries and providing quotes
- Coordinating engineering review sessions and project execution between the Carlton VIC team and the Huizhou design and engineering team
- Issuing commercial documentation (quotations, invoices, ChAFTA Certificate of Origin, customs documentation)
- Maintaining customer engineering support relationships
- Complying with our legal and regulatory obligations (Australian Consumer Law, Modern Slavery Act 2018, ATO requirements)
- Improving our website and engineering reference content
5. Disclosure of personal information (APP 6 & 8)
We may disclose your personal information to:
- Our parent group's manufacturing partner facility in Huizhou, Guangdong, China — for engineering review, manufacturing execution, and quality validation. This is a cross-border disclosure (APP 8); we take reasonable steps to ensure the recipient handles your information consistent with the APPs.
- Our service providers — IT hosting, email, accounting, freight forwarders, customs brokers, banks — under written confidentiality obligations
- Government agencies — ATO, Australian Border Force, Australian Sanctions Office, AICIS — as required by law
- Professional advisers — lawyers, accountants — where necessary for our legitimate business interests
We do not sell your personal information to third parties.
6. Cross-border disclosure (APP 8)
Engineering review by the Huizhou design and engineering team requires cross-border disclosure of certain personal information (e.g., design specifications, TDP maps, drawings) to our parent group's facility in Huizhou, Guangdong, China. We take reasonable steps to ensure the overseas recipient handles your information consistent with the APPs, including written confidentiality obligations and IATF 16949-aligned data-handling controls.
7. Security of personal information (APP 11)
We hold personal information in secure electronic and physical systems with access restricted to authorised personnel. We use industry-standard encryption for data in transit (TLS 1.2+) and access controls for data at rest. NDA-protected design IP is segregated and access-restricted to the engineering team handling your specific programme.
8. Data retention
We retain personal information for as long as is necessary for our business functions and to comply with our legal obligations:
- Quotation and RFQ records: 7 years (Australian Taxation Office record-keeping requirements)
- Commercial agreement and invoicing records: 7 years (ATO record-keeping)
- NDA-protected design IP: as specified in the NDA, typically 5 years post-termination
- Marketing list and subscription records: until you unsubscribe or 3 years of inactivity
9. Your rights (APP 12 & 13)
You have the right to:
- Access your personal information held by us (APP 12). We will provide access within 30 days unless an exception applies.
- Correct your personal information if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading (APP 13).
- Request deletion of your personal information where we are no longer required to hold it under our retention schedule.
- Withdraw consent for marketing communications at any time.
To exercise any of these rights, contact us at info@tonecooling.com.au.
10. Privacy concerns and complaints
If you have a privacy concern or complaint, please contact us first at info@tonecooling.com.au. We will respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
- Web: oaic.gov.au
- Phone: 1300 363 992
- Post: GPO Box 5288, Sydney NSW 2001
11. Cookies and analytics
Our website uses essential cookies for site functionality and may use analytics cookies (e.g., Google Analytics) to understand site usage. We do not use marketing or advertising cookies that track you across other sites without your consent. You can control cookies via your browser settings.
12. Changes to this policy
We may update this Privacy Policy from time to time. The "Effective" date at the top of this page reflects the most recent update. Material changes will be notified on our website and, where appropriate, by email to active customers.
Compliance baseline. This Privacy Policy is structured around the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs). Lawyer review pending before final publication. For complex queries, contact the Office of the Australian Information Commissioner.
