The Australian Privacy Principles
We will treat all personal information in accordance with any and all obligations that are binding upon Us under the Privacy Act 1988 (Cth) (“Privacy Act”) and the “Australian Privacy Principles” set out in the Privacy Act.
What is "personal information"?
“Personal Information” is information about you which:
- can be used to identify, contact or locate you;
- can be combined with other information that is linked to you; or
- is defined as “personal information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about you.
We collect the content, communications and other information you provide when you use Our Platform and/or Services, including when you register on the Platform, create or share content on the Platform and communicate with others. This can include information in or about the content that you provide (e.g. metadata), such as the location of a photo or the date a file was created. Personal information that We collect from you may also include your ‘personal details’ including:
- personal details including name, mailing or street address, email address, telephone number and other contact details, age or date of birth, your employment information;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the Services We have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries;
- credit card information;
- any additional information relating to you that you provide to Us directly through Our Platform or app or indirectly through your use of Our Platform or app or online presence or through other websites or accounts from which you permit us to collect information;
- Geolocation information regarding your business or projects; and
Any other information that you share with Us.
Why do we collect your personal information and how do we use your personal information?
We collect and use your personal information to operate Our Platform and to deliver Our Services. This includes:
- responding to your enquiries and requests, and providing you with Our Services in response to such requests;
- providing, maintaining, protecting, and improving Our Platform, technology, products and services;
- monitoring the effectiveness of our services;
- anything you authorise or consent to Us doing;
- notifying you in regard to changes or developments to Our Platform and Services;
- administering, developing, and improving our Platform and Services;
- marketing our Platform and Services, sending you messages and follow-up reminders;
- responding to any complaints you have made regarding Our Platform or Services;
- data analytics; or
taking any action We are obliged to take in accordance with relevant laws and regulations.
How we may collect your personal information
We only collect personal information that is necessary for Us to operate Our Platform, conduct Our business and deliver Our Services. We will generally collect personal information:
- from you directly when you provide your details to Us. This might be via a face-to-face discussion, email or telephone conversation;
- when you communicate or interact with Us via Our Platform registration form, online chatbot feature via Our Platform, or social media channels;
from third parties where the Privacy Act or other law allows it.
How can you access and correct your personal information?
- Access: You may request details of personal information that We hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth). An administrative fee may be payable for the provision of information. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may refuse to provide you with information that We hold about you, in certain circumstances set out in the Privacy Act. If We refuse to give you access, We will provide you with reasons for Our refusal.
Correction: If you believe that any information We hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact Us by email at email@example.com. We rely in part upon customers advising Us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.
When we may disclose your personal information
For the purposes set out above, the We may disclose your personal information to other members of of our corporate group and third parties outside the Company. Your personal information may be disclosed to these third parties who are contracted to carry out specialised functions, which will only be in relation to Our business operations, functions and activities, and performance of services. We take reasonable steps to ensure that these third parties are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
In addition, We may disclose your personal information to:
- your authorised representatives or legal advisers (when requested by you to do so);
- Our professional advisers, including Our accountants, auditors and lawyers or the professional advisers of members of our corporate group;
- government and regulatory authorities and other organisations, as required or authorised by law;
- organisations who manage Our business strategies, including those involved in a transfer/sale of all or part of Our assets or business (including accounts and trade receivables) and those involved in managing Our business risk and funding functions;
- Our employees, contractors and personnel and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of Our Platforms and/or Our business or in connection with providing Our products and services to you);
- as necessary to detect, prevent, or otherwise address fraud, security or technical issues; and
- the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.
We may process and disclose personal information outside of the country of origin of that personal information. We may also store data, including personal information, in various countries such as Australia, the United States of America, the United Kingdom, countries within the EU, India, the Philippines.
When you provide your personal information to Us, you consent to the disclosure of your information outside of Australia and acknowledge that We are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
The Platform may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. We collect and manage IP addresses as part of the service of providing internet session management and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving this Platform.
This Platform uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this Platform: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this Platform. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information, whether gathered via cookies or from other sources.
You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this Platform.
- remember your preferences for using this Platform;
- show relevant notifications to you (eg, notifications that are relevant only to users who have, or have not, subscribed to newsletters or email or other subscription services); and
- remember details of data that you choose to submit to Us (eg, through online contact forms).
Many of these cookies are removed or cleared when you logout but some may remain so that your preferences are remembered for future sessions.
While do not operate in the EU, we subscribe to the privacy principles set out in the General Data Protection Regulation (“GDPR”) of the European Union (“EU”) and we endeavour to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects both in and outside of the EU that we may obtain.
The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include the following rights:
- you are entitled to request details of the information that we hold about you and how we process it. For EU residents, we will provide this information for no fee;
- you may also have a right to:
- have that information rectified or deleted;
- restrict our processing of that information;
- stop unauthorised transfers of your personal information to a third party;
- in some circumstances, have that information transferred to another organisation;
- lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and
- where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, please be aware that:
- such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other clients subject to appropriate confidentiality protections; and
- even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:
- to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and
in exercising and defending our legal rights and meeting our legal and regulatory obligations.
Storage and processing by third parties
Data that we collect about you may be stored or otherwise processed by third party services with data centres based in various locations internationally, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc and online relationship management tools. We consider that the collection and such processing of this information is necessary to pursue our legitimate interests in a way that might reasonably be expected (eg, to analyse how our clients use Our Services, develop Our Services and grow Our business) and which does not materially impact your rights, freedom or interests.
We require that all third parties that act as “data processors” for Us provide sufficient guarantees and implement appropriate technical and organisational measures to secure your data, only process personal data for specified purposes and have committed themselves to confidentiality.
Duration of retention of your data
We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements. At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning). In some circumstances, you can ask Us to delete your data.
Storage and security of your personal information
We are committed to maintaining the confidentiality of the information that you provide Us and We will take all reasonable precautions to protect your personal information from unauthorised use or alteration. In Our business, personal information may be stored both electronically (on Our computer systems, CRM system and within Our Platform hosting provider) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, protect all of Our electronic information. Likewise, We take all reasonable measures to ensure the security of hard-copy information.
You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.
If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Federal Privacy Commissioner’s website (see www.privacy.gov.au).
Contacting us about privacy and breach
If you would like more information about the way We manage personal information that We hold about you, or are concerned that We may have breached any privacy rules, or would like to update your personal information, please contact Us by email at firstname.lastname@example.org.