Introduction
This Privacy Policy sets out how we collect, use, store, disclose and protect your Personal Information. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously.
In this Privacy Policy we, us or our means Privasec (Privasec Pty Ltd, ABN # 44603476768 and Privasec Pte Ltd).
What Personal Information do we collect?
Personal Information includes information or an opinion (whether true or not) about an individual that is identified or reasonably identifiable.
The type of Personal Information we collect may include contact information (e.g. name, email address, postal address, company information, and other profile information), login details, comments, preferences, feedback, user data (see ‘What types of cookies do we use?’ section below) and any other Personal Information that may be required to facilitate your dealings with us.
We do not currently collect financial information, such as your payment method for any services. Where relevant, that information (including a valid credit card number, type, expiration date or other financial information) is collected and stored by our third party payment processing company, Stripe. Use and storage of that information is governed by Stripe’s applicable terms of service and Privacy Policy, available at https://stripe.com/us/legal.
How do we treat Personal Information that is also Sensitive Information?
Sensitive Information includes information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We will collect sensitive information only where relevant and with your consent (e.g. if you register for an event, we may ask you for information about your health, any disabilities or special dietary needs, or we may collect such information if we need it to provide you with our professional advice).
Why do we collect Personal Information?
We collect Personal Information for purposes connected with our activities and operations, including:
- to enable you to access and use our website (Site), associated applications and associated social media platforms;
- to contact and communicate with you;
- for internal record keeping and administrative purposes;
- for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
- to run competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
- to meet our legal obligations and resolve any disputes that we may have;
- to consider your employment application; and
- to understand and meet the needs and requests of individuals.
How do we collect Personal Information?
We collect Personal Information from you in a number of ways – including directly from you and when you provide it to us or our agents, contractors or distributors – by way of emails, forms filled out by individuals (including via online forms), feedback, inquiries, support requests, surveys, competitions, online user-generated content, phone conversations (which may be recorded for quality control purposes in accordance with applicable laws), market research, video conferencing, face-to-face meetings and interviews. We may also collect Personal Information if you inquire about or apply for employment with us, provide services to us, use our Site, or otherwise engage with Privasec.
How might Privasec use and disclose your Personal Information?
Privasec may use and disclose your Personal Information for the purposes described in this Privacy Policy, or for related purposes which would reasonably be expected by you, or for purposes to which you have consented, and in circumstances otherwise required or authorised by law.
We may disclose your Personal Information to:
- Our employees, contractors and/or related entities;
- Our existing or potential agents or business partners;
- Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- Third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia. including in New Zealand, Malaysia and Singapore.
- Third parties to collect and process data. This may include parties that store data outside of Australia including in New Zealand and Singapore.
- Credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- Sponsors or promoters of any competition we run;
- Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
Third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
Do we use your Personal Information for direct marketing?
We and our carefully selected business partners may send you direct marketing communications and information about our services. You may opt out of receiving marketing materials from us by contacting us using the details set out below for the Data Protection and Privacy Officer or, if it is an email, by using opt-out facilities such as an unsubscribe link.
Sending information overseas
We may share your information with among companies affiliated directly with Privasec Pty Ltd, including Privasec Pte Ltd. This may involve sending your personal information to these offices overseas.
We may also disclose your information to:
- our service providers, agents and contractors from time to time that provide services to us and/or help us to provide and market our services to you;
- specific third parties authorised by you to receive information held by us; and
- other persons, including government agencies, regulatory bodies and law enforcement agencies; or as otherwise required or authorised by law.
Some of these vendors or other parties may receive or store your information in overseas locations. For example, we may disclose your email address or other contact information to providers of electronic execution services, which may store the information in an overseas jurisdiction.
Our service providers are located around the world. The countries in which recipients are likely to be located include Australia, New Zealand, Malaysia, and Singapore.
How do we store your information, and how do we keep it secure?
We are committed to ensuring that the Personal Information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
However, we cannot guarantee the security of your Personal Information. If you do use the internet to send us any information, including your email address, please be aware that it will be at your own risk.
Your rights and options we provide for controlling your Personal Information
Choice and consent: Please read this Privacy Policy carefully. By providing Personal Information to us, you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us. You do not have to provide Personal Information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.
Privasec does not intentionally collect personal information from children. Individuals over 16 years old can consent to the processing of personal information; anyone younger than 16 requires the consent of their parent or guardian.
Access: You may request details of the Personal Information that we hold about you. We may charge you a small fee for this service. If so, we will inform you of the fee before processing your request. In certain circumstances (for example, including those set out in Australia’s Privacy Act 1988 (Cth)), we may refuse to provide you with Personal Information that we hold about you.
Erasure: You have the right to request that Privasec erase your personal data, under certain conditions.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Information from third parties: If we receive Personal Information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Information to us.
Restrict processing: You have the right to restrict processing of your personal information, under certain conditions. If we receive Personal Information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Information to us.
Object to processing: You have the right to object to Privasec’s processing of your personal data, under certain conditions.
Data portability: You have the right to request that Privasec transfer the data we have collected to another organisation, or directly to you, under certain conditions.
How long do we retain your Personal Information?
We retain Personal Information about you for as long as necessary to provide you our services, or until we receive a request to delete it. In some cases, we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable laws. Afterwards, we occasionally retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.
What types of cookies do we use?
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our Site, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
Below we’ve provided a quick summary of the main cookie types we and our service providers use on our service.
- Essential Cookies: Essential cookies are required to provide you with features or services you have requested. For example, certain cookies enable you to log into secure areas of our services. Disabling these cookies will make certain features and services unavailable.
- Functional Cookies: Functional cookies are used to record your choices and settings regarding our services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
- Performance/Analytics Cookies: Performance cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site. Performance/analytics cookies also help us measure the performance of our advertising campaigns to help us improve our campaigns and the Service’s content for those who engage with our advertising.
- Advertisement Cookies: Retargeting/ advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
- Analytics Data: We collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our services. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analysing and improving our services.
- Aggregate Information: We collect statistical information about how users use our services (“Aggregate Information”). Some of this information is derived from Personal Information. While Aggregate Information is not Personal Information, it may be tied back to you, your account or your web browser.
If you have a request, please get in touch with our Data Protection and Privacy Officer through the contact details provided below. We will respond to any request we receive within 30 days.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our Site features might not function as a result.
Privacy policies of other websites
The Privasec Site also contains links to other websites. Our Privacy Policy applies only to our Site, so if you click on a link to another website, you should read their Privacy Policy before using their website.
How to make a complaint
If you think we have breached Australia’s Privacy Act or other relevant local legislation, 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 below. Please include your name, email address and/or telephone number and clearly describe your complaint.
Any complaint will be investigated by the firm’s Directors and the outcome of that investigation communicated to you (please allow at least 30 days for us to do so).
If you are not satisfied with the outcome of any internal investigation that we conduct, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at [email protected] or on 1300 363 992. More information is available on the OAIC’s website at https://www.oaic.gov.au/.
How to contact us
If you have any questions about Privasec’s Privacy Policy, the information we hold on you, or you would like to exercise one of your information protection rights, please do not hesitate to contact us.
Contact: Data Protection & Privacy Officer
Email: [email protected]
Phone: +61 1800 996 001
Addresses:
- L6, 276 Flinders Street, Melbourne, 3000, VIC, Australia (for global matters)
- 138 Robinson Road, Oxley Tower #10-01, Singapore 068906 (for South East Asia-related matters)
Updates to this Policy
We may update this Policy from time to time by publishing it on our Site. We recommend you check our Site regularly to ensure you are aware of our current terms. Materials and information on this Site (Content) are subject to change without notice. We do not undertake to keep our Site up-to-date and we are not liable if any Content is inaccurate or out-of-date.
This Privacy Policy was last updated on 13 October 2021.