1 PURPOSE OF OUR POLICY
- 1.1 Qwilr Pty Ltd ABN 23 168 533 793 (“we”, “us” or “our”) provides the suite of tools, applications and services, known together as “Qwilr”.
- 1.2.1 how we collect, use, share and protect the personal information that comes into our possession in the course of:
- 18.104.22.168 providing the services that we offer; and
- 22.214.171.124 the normal day-to-day operations of our business, and
- 1.2.2 your rights regarding the user, access and correction of your personal information.
- 1.3.1 the Australian Privacy Principles set by the Australian Government for
the handling of Personal Information under the Privacy Act 1988 (Cth) (“Privacy Act”); and
- 1.3.2 the General Data Protection Regulation (“GDPR”), the EU-wide privacy and data protection law, together referred to as “Privacy Standards”.
2 WHO AND WHAT THIS POLICY APPLIES TO
- 2.2 We handle Personal Information for our own business, as well as potentially storing Personal Information in our systems on behalf of our users.
- 2.5 If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.
- 2.6 Our website and services are unavailable to children (persons under the age of 18 years). If an individual is under 18 years of age, they can only use our website and services under the supervision of a parent or guardian.
3 THE INFORMATION WE PROCESS
- 3.1 In the course of business it is necessary for us to process Personal Information. This information allows us to identify who an individual is for the purposes of our business, contact the individual in the ordinary course of business, transact with the individual and otherwise pursue our legitimate interests (where such is not overridden by your interests or fundamental rights or freedoms with respect to that Personal Information).
- 3.2 Without limitation, the following are types of information we may process:
- 3.2.1. Personal Information. We may process personal details such as an individual’s name, location, date of birth, nationality, family details and other Personal Information;
- 3.2.2 Contact Information. We may process information such as an individual’s email address, telephone number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;
- 3.2.3 Financial Information. We may process financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
- 3.2.4 Statistical Information. We may process information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
- 3.2.5 Information an individual sends us or elects to store on Qwilr.
- 3.4 We may also process non-Personal Information about an individual such as information regarding their computer, network and browser and their IP address.
- 3.5 The Privacy Standards do not apply in relation to information that is not Personal Information.
4 HOW INFORMATION IS COLLECTED
- 4.1 Most Personal Information will be collected in association with an individual’s use of Qwilr, an enquiry about Qwilr, or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
- 4.1.1 Registrations/Subscriptions. When an individual registers or subscribes for a service, list, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;
- 4.1.2 Accounts/Memberships. When an individual submits their details to open an account and/or become a member with us;
- 4.1.3 Supply. When an individual supplies us with goods or services;
- 4.1.4 Contact. When an individual contacts us in any way;
4.1.5 Access. When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet, we may:
- 126.96.36.199 collect information using cookies (if relevant – an individual can adjust their browser’s settings to accept or reject cookies) or analytics services;
- 188.8.131.52 supplement the information provided to us by the user with other relevant data sourced from business partners, including company names, phone numbers and social media statistics; and/or
- 184.108.40.206 Pixel Tags. Pixel tags enable us to contact or otherwise engage with users through a variety of media.
- 4.2 We may also collect Personal Information about your contacts, either from you or from your contacts, to enable those contacts to engage with you on Qwilr and to maintain a record of such engagements.
5 HOW INFORMATION IS USED
- 5.1 As a general principle, we will not use any Personal Information other than for the purpose for which it was collected, as determined by the circumstances in which the information was collected and/or submitted.
- 5.3 Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
5.3.1 The provision of goods and services between an individual and us;
5.3.2 Verifying an individual’s identity;
- 5.3.3 Automated decision making, such as using the domain in an email address to infer the individual’s affiliation with a company and to tailor that individual’s experience with Qwilr accordingly;
- 5.3.4 Communicating with an individual about:
- 220.127.116.11 Their relationship with us;
- 18.104.22.168 Our goods and services;
22.214.171.124 Our own marketing and promotions to customers and prospects;
126.96.36.199 Competitions, surveys and questionnaires;
5.3.5 Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or
5.3.6 As required or permitted by any applicable law.
6 WHEN INFORMATION IS DISCLOSED
- 6.1 We may disclose Personal Information to third parties who provide services that enable and enhance our business activities, insofar as such disclosure of information is required. Examples of such services include:
- 6.1.1 Payment processing
- 6.1.2 Providing customer service
- 6.1.3 Sending marketing communications
- 6.1.4 Conducting research and analysis
- 6.1.5 Providing cloud computing infrastructure
- 6.2 We take reasonable steps to ensure the disclosure of Personal Information to any third party, including any entity outside of Australia and the European Union, will not be made until that entity has agreed in writing that its own data processing activities are not inconsistent with the Privacy Standards.
- 6.3 There are certain circumstances in which we will be required to disclose Personal Information, namely:
- 6.3.1 where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
- 6.3.2 as required by any applicable law; or
- 6.3.3 in order to sell our business or assets (in which case we may need to transfer Personal Information to a new owner).
7 RIGHTS TO INFORMATION
- 7.1 Individuals have a number of rights that may be exercised in relation to their Personal Information subject to exceptions and limitations provided for in the Privacy Standards.
- 7.2 Individuals have a right to confirm whether Qwilr is processing their Personal Information and, if so, obtain access to that information as well as information concerning:
- 7.2.1 the purposes of the processing;
- 7.2.2 the categories of relevant data;
- 7.2.3 the recipients or categories of recipients to whom the data have been or will be disclosed;
- 7.2.4 the envisaged period over which the data will be stored or, if not possible, the criteria used to determine this; and
- 7.2.5 the existence of any automated individual profiling, including the logic involved and the significance or envisaged consequences of this.
- 7.3 Individuals have a right to object to certain processing operations on their Personal Information on legitimate grounds, and thus cause us to cease such processing.
- 7.4 Individuals have a right to have inaccurate Personal Information rectified, incomplete Personal Information completed, and otherwise have their Personal Information erased.
- 7.5 Individuals have a right to request and receive their Personal Information in a structured, commonly-used and machine-readable format.
- 7.7 You may receive email communications from us from time to time. If you would like to discontinue receiving this information, use the ‘unsubscribe’ links found in those emails or contact us at email@example.com.
- 7.8 To enquire about or exercise these rights, contact us at firstname.lastname@example.org.
- 7.9 We will endeavour to act on valid requests to exercise these rights within a reasonable timeframe, and in any event within 30 days of our receipt of such requests.
8 THE SAFETY & SECURITY OF PERSONAL INFORMATION
- 8.2 We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
- 8.3 The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
- 8.5 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
- 8.6 We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
9 COMPLAINTS AND DISPUTES
- 9.1 If an individual has a complaint about our handling of their Personal Information:
- 9.1.1 they should in the first instance address their complaint in writing to us through the contact details below; and
- 9.1.2 they have the right to submit a complaint to a relevant supervisory authority under the Privacy Standards.
- 9.2 If we become aware of any unauthorised access to an individual’s Personal Information, we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
10 Contacting INDIVIDUALS
- 10.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies and changes affecting our services. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
11 CONTACTING US
- 11.1 All correspondence with regards to privacy should be addressed to:The Privacy Officer
Qwilr Pty Ltd
Level 1, 7 Hudson St
Redfern NSW 2016
You may contact the Privacy Officer by email in the first instance.
12 CHANGES TO THIS POLICY