Privacy Policy
Purpose This document is a privacy policy.
Party 1 Name parties not applicable
Party 2 Name parties not applicable
Jurisdiction Australia
1. Introduction
- Provider has adopted this Policy in accordance with the privacy law.
- This Policy outlines how Provider deals with Personal Information, which it collects in conjunction with the Services.
- Provider may also collect information about Individuals who do not use the Services.
- Capitalised words in this Policy are defined terms. Defined terms are explained at the end of this Policy.
2. Collecting information directly from people
Provider collects Personal Information directly when an Individual:
- contacts Provider by telephone, fax, email or another from of communication;
- gives Provider his or her information in person on a paper form;
- sends the Provider a message through SMS or a third party app;
- other ways Provider collects information directly;
- registers or subscribes for an account;
- the Service automatically captures Personal Information in content Individuals post on the Services;
- Provider’s server and analytics service may log details about website visits;
- location services, when switched on, capture Individuals’ locations;
- Provider’s website will likely place a cookie on Individuals’ devices;
- store visitors’ P. addresses; and
- creates a profile on Provider’s Service;
3. Collecting information from third parties
Provider collects Personal Information about Individuals from third parties when:
- Individuals link their account on the Service with accounts on social networks such as Facebook;
- third parties such as Client Kiosk give Provider access to files containing Personal Information;
- Provider conducts research on Individuals, including potential customers; and
- Individuals pay for an account on the Service using PayPal or Stripe.
4. Types of Information that Provider collects and holds
Using processes described in this Policy, Provider collects the following categories of Personal Information about Individuals:
- (Content) whatever Personal Information is included in content Individuals enter using Provider’s Services;
- (Social Media) any Personal information collected through Individuals’ use of social media;
- (Identity Information) name, address, date of birth, nationality, PayPal account details, usernames;
- (Contact Information) email address, social media profiles, telephone number, third-party usernames, residential, Provider and postal addresses;
- (Behaviour Information) habits, movements, trends, decisions, associations, memberships, finances, purchases;
- (Internet Data) webpage views, IP address, referring web site addresses, location, browser type, operating system, domain name, access times and other data typically collected by analytics services like Google Analytics;
5. Sensitive Information
Privacy law categorize certain types of Personal Information as “sensitive information”. Provider collects the following kinds of sensitive information:
- at the option of users using the forum functionality, information or opinions about an Individual’s:
- racial or ethnic origin;
- philosophical beliefs;
- criminal record; and/or
- to use the Services at all, health information about an Individual, including:
- any information or opinion about the Individual’s health, health services, or wishes regarding health care; and
- information collected to provide, or in providing, a health or counselling service of any kind; and
- other information regarding drinking habits;
If Individuals submit, post or store any sensitive information using the Services, Provider takes this as consent to its management of it in accordance with this privacy policy.
6. How Provider stores Personal Information
Provider holds and stores Personal Information using:
- (Storage Services) third party data storage services, including applications and software and Provider’s server with GoDaddy and Thinkific; and
- (Provider Devices) devices operated by employees and contractors of Provider’s business;
7. Security
Provider will take reasonable precautions to protect Personal Information from unauthorised access. This includes measures to secure the Provider’s physical facilities and electronic networks.
Provider secures Personal Information that Provider collects with an SSL certificate, passwords and secure employee and contractor digital accounts.
For more information on security, please contact Provider using the details in the “contacting us” below.
8. Deletion procedures
Provider will depersonalise any Personal Information within 7 days of the cancellation of a subscription.
9. Why data is held, used and disclosed
Provider’s handling of Personal Information includes holding, using and sometimes sharing the Personal Information so that Provider can:
- provide functionality within the Services;
- provide notifications and support;
- offer marketing and promotions, competitions, surveys and questionnaires;
- transact with Individuals and process payments;
- assess and improve the Services;
- provide secure access to the Services; and
- offer support information and programs through the Service;
For more information on when Provider shares Personal Information, see below.
10. Handling of data
Some collection, holding, use and disclosure of Personal Information happens simply by virtue of Individuals using the Services. The purpose of the Service is to allow Individuals and Provider to enter, manage, communicate and publish information, including Personal Information.
11. Disclosing Personal Information
- Provider provides the functionality for users to share Personal Information with others on an electronic forum. Users of the Services should understand that using forums, comments, messages and correspondence has the effect of disclosing Personal Information to third parties.
- When Provider uses the services of companies that Provider works with to provide the Services, they may get access to the Provider’s data, including Personal Information. Such third party services may include:
- (Hosting) Cloud and web hosting service providers;
- (SaaS) providers of software as a service;
- (Support) providers of IT support services, web and software development;
- (Online payment) providers of online payment systems such as Paypal;
- (Data analytics) Google Analytics (see [http://www.google.com/intl/en/policies/privacy/](http://www.google.com/intl/en/policies/privacy/)); and
- marketing agencies.
- Provider will only share Personal Information with these third parties to the extent reasonably necessary to perform their functions.
- These third parties may have their own privacy and security policies. For more information about this, please contact Provider using the details listed in the “contacting us” section below.
- For information on disclosures to overseas recipients, see below.
12. Disclosing information overseas
- The Provider may store or process some Personal Information overseas. Individuals may not have the same rights relating to their information when it is overseas as they would under Australian privacy law.
- By providing Provider with Personal Information, Individuals consent to the transfer of their Personal Information to overseas recipients as contemplated by this privacy policy.
- If Individuals consent to such transfer, Provider will not be accountable for overseas recipients’ handling of their Personal Information.
13. Contacting us
Individuals may edit content and account details within the Services.
However, Individuals can also contact the Provider using the details below if they want to access, correct or delete Personal Information or lodge a complaint.
Privacy Officer - privacy@jessicagwynne.com
Provider reserves the right to refuse access or correction where there are reasonable grounds for doing so, for example if providing access would be unlawful or would compromise the privacy of another person.
14. Complaints process
If Individuals have a complaint about privacy, they can contact Provider using the details listed above.
Provider will respond to complaints in writing within a reasonable period (usually 10 business days from the day Provider receives an email).
Provider will try to work with Individuals to resolve complaints entirely within 20 business days, although that period may be longer if it is reasonable to take longer given the nature of the complaint.
If Individuals are unsatisfied with our response, they may refer the complaint to the Office of the Australian Information Commissioner (http://www.oaic.gov.au/).
15. Amendment
Provider may amend the Privacy Policy at its sole discretion. Individuals that continue to use the Services after receiving notice from Provider of such an amendment, agree to be bound by the Privacy Policy as amended.
16. Definitions
Individual, Individuals
means a natural person.
Personal Information
means information about an Individual whose identity is apparent, or can reasonably be ascertained, from that information. This includes information like names, telephone numbers, email addresses and physical addresses.
Policy, Policies
means this document, drafted in accordance with the Privacy Act 1988 (Cth).
Provider
means Client Kiosk Pty Ltd trading as Jessica Gwynne.
Service, Services
means the online services offered by Client Kiosk Pty Ltd.