and our related bodies corporate.
If you are accessing the site from Europe we shall observe the General Data Protection Regulation (GDPR) in processing personal data.
As controller we are responsible for the personal data processed on the website. We have commenced technical and organisational measures to ensure processing of personal data is conducted in accordance with the regulations and implemented necessary data protection policies. Furthermore, we have taken measures to ensure personal data processed on the website is not destroyed, lost, impaired, or has become available for unauthorised persons or entities.
By using the website users accept our processing of any personal data delivered to us by the use of the website. Users may contact us to get information on the data processed about them or to have the data deleted or corrected.
We shall process all personal data received in a confidential manner and may not in any event pass on any such information to a third party. However, we may place such information on third parties’ storage centres in the European Union, hosting services and such. Where needed we have entered necessary data processing agreements with such third parties.
We may not use the data for marketing purposes, including circulation of promotional e-mails, unless accepted by the user.
Collection of personal information
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details.
What personal information do we collect?
We may collect the following types of personal information:
mailing or street address;
telephone number and other contact details;
age or date of birth;
credit card 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 products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
information you provide to us through customer surveys; or
any other personal information that may be required in order to facilitate your dealings with us.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
register on our website or app;
communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
interact with our sites, services, content and advertising; or
invest in our business or enquire as to a potential purchase in our business.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
to enable you to access and use our website, app or platform services;
to operate, protect, improve and optimise our website, app or platform services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
to consider your employment application.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
If you require further information about the legitimate interest legal basis under the GDPR, please see Section 14 ‘Contact’.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our platform or services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
To whom do we disclose your personal information?
our employees and related bodies corporate;
third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
professional advisers, dealers and agents;
payment systems operators (eg merchants receiving card payments);
our existing or potential agents, business partners or partners;
our sponsors or promoters of any competition that we conduct via our services;
anyone to whom our assets or businesses (or any part of them) are transferred;
specific third parties authorised by you to receive information held by us; and/or
other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of personal information outside Australia
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.
We may disclose personal information outside of Australia to Sharp Spring (Customer Relationship Management) and DropBox located in the United States of America.
We provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). These countries include but are not limited to the United States of America (US).
We have hosting facilities in Australia, the EU and the US .The European Commission has made an “adequacy decision” with respect to the data protection laws of Australia. Transfers to the US will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://www.privacyshield.gov/.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Using our website and cookies
We may collect personal information about you when you use and access our website.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we use industry standard encryption to protect all personal information data we hold. However, we cannot guarantee the security of your personal information.
Accessing or correcting your personal information
You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth) and the EU GDPR 2018. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at firstname.lastname@example.org.
You have the following rights under the GDPR:
Right of Access – the right to access the personal information that we hold or process about you;
Right to Rectification – the right to update, correct or amend the personal information that we hold or process about you;
Right to Erasure – the right to request remove personal information that we hold about you
Right to Restrict – the stop processing all or some of your personal data;
Right to Object – the right to object to your personal information being used for direct marketing purposes;
Right to Data Portability – the right to request a copy of your personal data in electronic format;
Right not to be subject to Automated Decision making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
The Privacy Officer
301/66 Mt. Alexander Road, Travancore, Victoria, Australia 3032