Privacy Policy

1. Outline

1.1 This Privacy Policy, which is subject to the Privacy Act and APPs to which we are bound, regulates how we collect, use and disclose personal information. 

1.2 Amendment. We may change, vary or modify all or part of this Privacy Policy at any time in our sole discretion. It is your responsibility to check this Privacy Policy periodically for changes. If we adopt a new Privacy Policy:

    1.2.1 we will post the new Privacy Policy on the relevant Platform; and

    1.2.2 it will then apply through your acceptance of it by subsequent or continued use of the Platform and/or our Services.

1.3 Employee records. This Privacy Policy does not apply to our acts and practices which relate directly to the employee records of our current and former employees.

1.4 Jurisdiction. The laws of Australia apply to this Privacy Policy..

2. Purpose

2.1 Primary purpose. We collect your personal information to lawfully carry out our functions and activities and provide you our Services (Primary Purpose).

2.2 Related purposes. In addition to the Primary Purpose, we may use the personal information we collect and you consent to us using your personal information to:

   2.2.1 provide you with further information about the Services you requested and any other services and events you may be interested in;

   2.2.2 personalise and customise your experiences with us

   2.2.3 help us review, manage and enhance our Services and develop insights used in reports or other content developed by us;

   2.2.4 when considering making offers to job applicants and prospective employees or for employment purposes;

   2.2.5 communicate with you, including by email, telephone and mail;

   2.2.6 conduct surveys or promotions;

   2.2.7 to process payments and administer your account;

   2.2.8 investigate any complaints about or made by you, or if we have reason to suspect you have breached any relevant terms; or

   2.2.9 as required or permitted by any law..

3. What we collect

3.1 Personal information we collect about you may include:

  3.1.1 identification information such as your name, address, telephone number, gender, email address, date of birth and location; and

  3.1.2 financial Information such as identification documents, passwords, credit card details, bank account details and other related financial information.

3.2 We will only collect, hold, use or disclose your sensitive information with your consent..

4. How we collect

4.1 How we collect. Your personal information may be collected:

  4.1.1 when you complete an application, consent, purchase, account sign-up or similar form in paper, via our Platform or otherwise;

  4.1.2 when you contact us to make a query or request or interact with our Platform;

  4.1.3 when you participate in one of our Services, competitions or surveys;

  4.1.4 from those who act on your behalf;

  4.1.5 from publicly available information;

  4.1.6 from government regulators, law enforcement agencies and other government entities;

  4.1.7 from business contacts, external service providers and suppliers;

  4.1.8 from prospective employees; or

  4.1.9 by other means as we will reasonably inform you of (as relevant).

4.2 Third party collection. If we collect any personal information about you from someone other than you, to the extent not already set out in this Privacy Policy, we will inform you of the fact that we will collect, or have collected, such information and the circumstances of that collection before, at or as soon as reasonably practicable after we collect such personal information.

4.3 Unsolicited information. If we receive unsolicited personal information about you that we could not have collected in accordance with this Privacy Policy and the Privacy Act, we will, within a reasonable period, destroy or de-identify such information received.

4.4 Minors. It is our policy to not collect personal information from persons who are under the age of 18 years or offer to send any promotional material to such persons.

4.5 Anonymity. You are not obliged to give us your personal information. If you would like to access any of our Services on an anonymous basis we will take reasonable steps to comply with your request, however:

  4.5.1 you may be precluded from taking advantage of some of our Services; and

  4.5.2 we will require you to identify yourself if:

       a) we are required by law to deal with individuals who have identified themselves; or
       b) it is impracticable for us to deal with you if you do not identify yourself or elect to use a pseudonym.

4.6 Destruction. We will destroy or de-identify your personal information if the purpose for which we collected the
personal information from you no longer exists or applies. Where a relevant legal requirement otherwise applies, we will retain in a secure manner your personal information for a period of seven years after which we may destroy it.

5. Use

5.1 Primary use. We will only use and disclose your personal information:

  5.1.1 for purposes which are related to the Primary Purpose; or

  5.1.2 if we otherwise get your consent to do so, in accordance with this Privacy Policy and the Privacy Act.

5.2 We will not use your personal information for any purpose for which you would not reasonably expect us to use your personal information.

5.3 We will not sell, trade, rent or licence your personal information to third parties.

5.4 Direct marketing. At the time you provide your personal information, we will offer you a choice as to whether you want to receive direct marketing communications about services. If you choose not to receive these communications, we will not use your personal information for this purpose. We will otherwise only use or disclose your personal information for the purposes of direct marketing if:

  5.4.1 we collected the information from you;

  5.4.2 it is reasonable in the circumstances to expect that we would use or disclose the information for direct marketing purposes;

  5.4.3 we provide you with a simple means to ‘opt-out’ of direct marketing communications from us; and

  5.4.4 you have not elected to ‘opt-out’ from receiving such direct marketing communications from us.

5.5 You may opt out of receiving such communications by:

  5.5.1 checking the relevant box on the form used to collect your personal information;

  5.5.2 clicking a link on the email communication sent to you; or

  5.5.3 contacting us using our contact details below.

5.6 We may offer you the opportunity to receive information from third parties regarding products or services that may be of interest to you. If you choose to receive such information, we may forward messages from such third parties to you. If we do so, we will not provide such third parties with any of your personal information..

6. Disclosure

6.1 How we disclose. We may disclose personal information and you consent to us disclosing such personal information to:

  6.1.1 third parties engaged by us to perform functions or provide products or Services on our behalf;

  6.1.2 your referees and former employers;

  6.1.3 our professional advisors, including our accountants, auditors and lawyers;

  6.1.4 our related bodies corporate;

  6.1.5 persons authorised by you to receive information held by us;

  6.1.6 a government authority, law enforcement agency, pursuant to a court order or as otherwise required by law;

  6.1.7 a party to a transaction involving the sale of our business or its assets; and

  6.1.8 any persons as required or permitted by any law.

6.2 We will not disclose your sensitive information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act or to comply with any other regulatory requirement.

6.3 Overseas disclosure. We may in some circumstances send your personal information to other overseas recipients, for example due to our database servers or our parent company or subsidiaries (including any member of the Citizen Global Network) being located outside Australia or for processing by staff operating outside Australia who work for us or for one of our suppliers engaged to, among other things, fulfil your product orders, process your payment details or provide support services. It is not currently practical for us to list all countries in which overseas recipients of your personal information are located, however the likely locations of such recipients are: Europe, Asia, Oceania, Middle East, Africa and Americas.

6.4 If we send personal information to overseas recipients, we will take reasonable measures to protect your personal information such as ensuring all information is de-identified where appropriate before being transmitted. However, you acknowledge and agree that if we disclose your personal information to overseas recipients, we are not obliged to take reasonable steps to ensure overseas recipients of your personal information comply with the Privacy Act and the APPs..