1. Purpose of policy
1.1 Organisational Plasticity Institute Pty Ltd is committed to complying with its obligations under the Privacy Act 1988 (Cth).
1.1 This Policy sets out:
(a) how and why we collect and use your Personal Information; and
(b) what controls you have over your Personal Information in our possession.
1.2 This Policy is subject to change at our discretion. The current version will always be available on our website at sparkup.io. This Policy was most recently updated on 11 June 2020.
2.1 In this Policy:
Act means the Privacy Act 1988 (Cth);
OAIC means the Office of the Australian Information Commissioner;
SparkUp or we or us means SparkUp [Entity to be decided) or its associated entities as appropriate.
Personal Information means information about you which personally identifies you or may reasonably be used to personally identify you;
Platform means the website wwww.sprakup.io and any mobile application;
Sensitive Information has the meaning given to that term in the Act; and
3. Types of Personal Information we collect
3.1 We collect information related to individuals who access our Platform, such as our customers’ employees or others authorised by our customers to use our Products. The type of information we collect includes:
(a) identity data including names and usernames or similar identifier;
(b) contact data including contact details such as billing and delivery addresses, email addresses and telephone numbers;
(c) transaction data including details about payments and other details of products and services purchased from us;
(d) technical data including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access our Platform;
(e) profile data including usernames and passwords, searches made and pages visited on our websites or in apps, interests, feedback and survey responses;
(f) usage data including information about the Platform is used, products and services;
(g) marketing and communications data including our users preferences in receiving marketing from us and our third parties and communication preferences;
3.2 Where we solicit Personal Information, we only collect:
(a) non-Sensitive Information, if it is reasonably necessary for the services we provide;
(b) Sensitive Information, if it is reasonably necessary for or directly related to the services we provide and you have consented to its collection, or its collection is permitted or authorised by law.
3.3 We may collect various other types of Personal Information, including Sensitive Information, in the course of conducting our business where it is provided by our customers or other persons without being solicited.
4. How we collect Personal Information
4.1 We may collect Personal Information about you when:
(a) you access or use our Platform;
(b) you communicate with our employees or customers;
(c) you deal with us in the course of our business;
(d) we solicit it from third party information in the course of our business;
4.2 If we solicit Personal Information, we will generally solicit it directly from the person it relates to or their agents, unless it is unreasonable or impracticable for us to do so.
4.3 If you choose not to provide us with your personal information, we may not be able to provide you with access to and use of certain features of the Platform.
4.4 You may use ‘anonymous mode’ if you do not wish to provide audio and video data.
5. How we store and protect Personal Information
5.1 We may hold Personal Information in physical documents or in electronic form. Physical files are kept securely inside our access-controlled premises. Electronic files are only accessible through our secure network.
5.2 We take reasonable steps to:
(a) ensure that Personal Information we collect is accurate, up-to-date, complete and relevant, other than where it is only collected to provide advice in respect of a particular point in time, in which case we will seek to ensure it is accurate, complete and relevant as at that particular point in time;
(b) ensure that Personal Information we use or disclose is accurate, up-to-date, complete and relevant, having regard to the purposes for which Personal Information is used or disclosed;
(c) protect Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure; and
(d) destroy or de-identify Personal Information which we no longer need for the purposes for which it was collected, except where it is necessary to retain it in order to maintain ongoing records for our customers.
5.3 We cannot guarantee the security of information transmitted via the internet. As such, transmission of Personal Information via the internet is at your own risk.
5.4 Links to third-party websites may appear on our website. Your use of those links is entirely at your own risk and we make no representations or warranties regarding third parties’ privacy practices.
5.5 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. Why we collect, hold, use and disclose Personal Information
6.1 We collect, hold, use and disclose Personal Information for various purposes, including:
(a) enabling access and use of our Platform;
(b) personalising content and experiences on our Platform;
(c) communicating with you;
(d) responding to your enquiries and information requests;
(e) storing information at third-party data centres;
(f) assessing the performance of aspects of our business;
(g) conducting business processing functions;
(h) storing information at third-party data centres;
(i) administrative, marketing (including direct marketing), planning, treatment or service development, qualify control and research purposes of our company, its related bodies corporate, dental practitioners, contractors or third-party service providers;
(j) updating your personal information;
(k) complying with our legal obligations;
(l) credit verification purposes, transactions, fraud and credit worthiness;
(m) billing purposes and debt collection;
(n) any other uses identified at the time of its collection.
6.2 We may disclose your Personal Information to such persons as is necessary to achieve the above purposes. This will often include disclosure to your employer (where your access to the Platform is through or organised by your employer), our related bodies corporate, contractors or other third-party service providers.
6.3 We may use or disclose Personal Information for secondary purposes where it would be reasonable to expect us to do so, and that secondary purpose is related (or directly related in the case of Sensitive Information) to the primary purpose.
6.4 Unless you inform us that you opt out, we may use your Personal Information for the purposes of sending you direct marketing publications. However, we will not disclose your Personal Information for the purposes of third-party direct marketing.
7. Using our Platform and cookies
7.1 While we do not use browsing information to identify you personally, we may record certain information about your use of our Platform, such as which pages are visited, the time and date of visits and the internet protocol address assigned to the computer or mobile used to access the Platform.
7.2 We may also use google analytics and 'cookies' in order to enhance the Platform experience for our customers. Cookies are small files that store information on a computer, TV, mobile phone or other device. They enable the entity that put the cookie on the device to recognise you across different websites, services, devices and/or browsing sessions. Cookies can be disabled through your internet browser, but our Platform may not work as intended if you do so.
8. Overseas disclosure
8.1 We may disclose Personal Information to third parties overseas for the purposes for which we collect and use that information. This will generally be limited to third party providers of services such as payment processing, website hosting, data storage, electronic communications and data analysis. Any such disclosure will be done in accordance with the Act.
8.2 We will attempt to ensure that persons to whom the disclosed Personal Information relates have comparable rights in relation to that information once disclosed overseas.
8.3 This will generally be limited to third party providers of services such as payment processing, website hosting, data storage, electronic communications and data analysis.
9. How you can access, correct and update Personal Information
9.1 You may contact us to access your Personal Information or to correct inaccurate, out-of-date, incomplete, irrelevant or misleading Personal Information by:
Mail: 153 Walker Street – North Sydney – 2060 NSW - Australia
Email: [email protected]
9.2 We will respond to those requests within a reasonable period in accordance with our obligations under the Act.
9.3 If we refuse a request to access or correct Personal Information, where reasonable, we will provide our reasons for doing so and information about your ability to complain about such refusal.
10.2 We will investigate and attempt to resolve your complaint in accordance with the Act.
10.3 You may contact the OAIC if you are not satisfied with the outcome of this process.
11. Further information
11.2 More information on the Act is available on the website of the OAIC at www.oaic.gov.au.