For the purposes of this Policy, ‘Subscriber’, refers to an individual or an entity that registers to use our Services.
We provide Subscribers with use of and access to the Services as part of a Subscription Plan, a free Account or a free trial of the Services as set out in our Terms and Conditions (T&Cs) which can be viewed at www.spenda.co/terms-and-conditions
By using or subscribing for the Services you:
You may withdraw or vary your consent by emailing email@example.com. Appstablishment may terminate your use of and access to the Services if you withdraw your consent.
What information we collect
In using our Services, you provide us with the following information which we store securely:
5. Account Information
6. Operational Information
7. Access Logs:
We gather information and store it in log files when you interact with our Services. This information includes Internet protocol (IP) addresses, browser type, URLs of referring/exit pages, operating system, language and location preferences, time/date stamp, search history, device identification numbers and system configuration information. We may correlate personal information with information gathered in access logs to improve our Service.
8. Analytics Information:
We collect analytics to help us improve our products and services and provide a better experience for our Subscribers and their customers. This may include information on functions and features of the Service being used, username, IP address and any other information needed to detail the operation of the function and the parts of the Services.
We also collect operational data as a result of running queries against our user base for the purposes of generating Usage Data. Usage data is data about our Subscribers and their business and is aggregated data about a category or group of features, services, or users that is not of itself personal information. We may incidentally come across sensitive or personal information when we compile Usage Data.
9. Cookies and other tracking technologies:
A cookie is software stored temporarily or placed on your device’s hard drive. The main purpose of a cookie is to allow a web server to identify a User’s device and tailor web pages and/or login information to their preferences.
Cookies help us promptly display information which we consider to be of interest to you to use the capabilities of the Platform. By gathering and remembering information about your preferences through cookies, we can provide you with a better experience. Cookies do not give us access to your devices and the information we collect through cookies does not include Personal Information.
We utilise various categories of cookies, which are summarised below along with the options available to you to manage them:
To opt out of receiving cookies, instruct your browser to stop accepting cookies or prompt you before accepting a cookie from websites you visit, by changing your browser options. To learn more about cookies visit www.allaboutcookies.org.
Blocking or deleting cookies used in our Services may adversely affect aspects of our Services provided to you.
10. Information from Third Party Services:
We may receive personal information from third parties such as social media, data enrichment or authentication services. Any information we access is governed by the authorisation procedures of that service.
11. Other Information:
We collect personal information from you when you submit forms on our sites or when you participate in any interactive features of our Services, surveys, competitions, promotional activity, request customer support, download content, via third party sites, or otherwise communicate with us.
How we collect your personal information
12. We may collect your personal information in a number of ways, including when you engage us to provide the Service or when you register as a user with us for any of our products, such as when you submit forms on our sites or when you participate in any interactive features of our Services, surveys, competitions, promotional activity, request customer support, download content, via third party sites, or otherwise communicate with us.
The purpose for collecting your personal information and how we use it
13. We continually work to improve our Service for our Subscribers. As such, we collect and use your personal information for the purpose of providing the Service and directly related purposes. Such purposes include:
14. We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to the Service.
Disclosure of your personal information
When you register for the Services, we may share your information only as described below:
16. Where appropriate, we will disclose your personal information to your employer, principal or administrator for verification purposes.
17. Marketing Materials, BLOGS, Forums and Wikis:
Our websites offer publicly accessible services such as blogs, forums, and wikis. Any information you provide in these areas may be read, collected, and used by others who access them. Information you provide may remain even after you cease using the Service. To request removal of your personal information from us, please contact us using the information listed below. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to and why.
18. Related Parties, Business Partners, Service Providers and Others:
We use and work with third party service providers to provide application development, hosting, website, infrastructure, maintenance, backup, payment processing, customer relationship management, marketing, accounting, human resources, business intelligence and analytics, data enrichment, customer support and other services for us. These service providers may have access to or process your information for the purpose of providing those services for us. You acknowledge that you are providing your information to these third parties, some of which may be located in countries outside of your location, acting on behalf of us. if we disclose your personal information to external service providers overseas, we will take reasonable steps to ensure that they comply with the Privacy Act 1988 (Cth)
We also obtain contact information from select Business Partners to better understand your preferences and to deliver you more personalised marketing.
19. We may also disclose any of the personal information we collect to our related bodies corporate and our advisers such as lawyers and accountants, our related entities and our external service providers (on a confidential basis).
20. Parties You Authorise:
22. We will not disclose your personal information other than when required or permitted by law, to a third party if we believe the disclosure is reasonably necessary or with your permission.
Your obligations when we disclose personal information to you
24. If we give you or provide you access to the personal information of any individual in connection with our Service, you must only use it:
25. You must also ensure that your representatives, agents, employees and contractors meet the above requirements.
Accuracy and correction of your personal information
26. We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date whenever we collect, use or disclose it. However, we also rely on you to advise us of any changes to your personal information.
27. You may access, change, or correct information about you by logging into your account at any time or by making a request to us using the contact details below. Please note we may need to verify your identity before granting access or otherwise changing or correcting your information.
Your obligations when you provide us with the personal information of others
28. You must not provide us with personal information of any other individual unless you have the express consent of that individual to do so. If you do provide us with such information about another individual, before doing so you:
Security of information
29. We take reasonable steps to protect any information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure.
30. Data protection measures are never completely secure and despite the security measures we have in place, we cannot guarantee your information during transmission through the Internet, while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.
You must take care to ensure you protect your personal information (for example, by protecting any usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.
Your Choices and Privacy Rights
31. If you make a request by contacting us at the contact details below, we will provide you with access to the personal information we hold about you unless otherwise required or permitted by law. We will notify you of the basis for any denial of access to your personal information.
32. If you wish to deactivate your account, you may do so by emailing us using the contact details provided below. Please note we may need to verify your identity before processing such a request.
33. Opting out of Promotional Communication: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email or contacting us using the contact details provided below. Please note you will continue to receive messages from us regarding Services (e.g., account verification, purchase and billing confirmations and reminders, technical and security notices).
Requests to opt-out of transfers to third-party providers may be submitted, but limitations on data sharing may make it difficult or impossible to process this request and still utilise the Services.
34. Children’s use of the services
Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal information from persons under the age of 16 and if we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.
If You become aware that a child has provided us with personal information, please contact us at the address listed below and we will take steps to delete such information.
Transfer of data from your home country
35. To bring you the Services, we operate globally with global partners. In order to provide you with the Services, your personal information may be transferred to, and processed in countries outside of your home country, including to Australia, New Zealand, United Kingdom and the United States.
These countries may have laws different and where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
36. Australian users: The third parties we share data with do not control and are not permitted to access or use your personal data, except for the limited purpose it was provided. For the purposes of Australian privacy legislation relating to Australian users, we do not disclose personal data to third parties located overseas.
37. We retain information we collect where we have an ongoing business need to do so in connection with the purposes set out above. For Information about how long any of our Subscribers retain your personal information, please contact that Subscriber.
38. If we have no ongoing need to process your information, we will either delete or anonymise it or, if this is not possible (if information has been stored in backup archives), then we will aim to securely store your personal information and isolate it from any further processing if and until deletion is possible.
How to make a complaint
41. We will refer your complaint to our Privacy Officer who will investigate the issue and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. We will try to resolve any complaint within 14 working days. If this is not possible, you will be contacted within that time to let you know how long it should take us to resolve your complaint.
42. If you are not satisfied with our determination, you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
How to contact us
44. No fee will be charged by us for an access request. However, you may be charged the reasonable cost of complying with the access request.
NOTE: For further information on privacy, visit the Federal Privacy Commissioner’s website at: http://www.privacy.gov.au
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