Effective Date: July 2020 Your Privacy and Circular Digital ABN 46 448 219 925 (collectively and individually referred to as “Circular Digital”, “we”, “our”, or “us”).
WHO WE ARE AND HOW YOU CAN CONTACT US
You can contact us for privacy related questions by emailing us at firstname.lastname@example.org or completing the form on our contact page.
We will only use your personal information in compliance with Australian Privacy Laws (Privacy Act (1988 (Cth)), Australian Privacy Principles and to the extent applicable, with the EU General Data Protection Regulation (GDPR) and any replacement legislation or regulation or guidelines and standards governing the use, storage or transmission of personal data.
OUR ROLE IN YOUR PRIVACY
As we are the providers of the products and services on this Site, we determine how and why your data is processed. We do not sell or rent your details to any third parties. We are committed to protecting your privacy and we want you to know exactly what information is collected and how we use it.
WHEN AND HOW WE COLLECT DATA
From the moment you visit our Site, we are collecting data, sometimes you might provide this data by completing a form or sending us an email, otherwise we might collect the data automatically. We may also collect data when:
You interact with us on social media
You accept our cookies and other tracking technologies on any device you use to interact with us
You voluntarily submit your data to us for any reason.
TYPES OF DATA WE MAY COLLECT
Contact details (name, address, email)
Financial Information (bank details when you become our customer)
Data about the products or services you purchase
Data that identifies you (your IP address, login, browser type, time zone, browser plugins, geolocation, what operating system and version)
Data on how you use our Site (URL clicks, products and services views, how long you are on our pages and other actions)
HOW AND WHY WE USE YOUR DATA AND DISCLOSURE
Under data laws, we are only allowed to use your data for specific reasons and where we have the legal basis to do so. We will use your data for the purposes it was collected and related purposes including:
To run our Site
Provide you with products, information and services
Improve our Site
Make your experience on our Site more efficient and enjoyable
Market research e.g. we may contact you for feedback about our products and services
Provide you with information about events, other products or services or opportunities that may be of interest
Marketing (with your consent)
Monitor your compliance with our Website Terms and Conditions
We may disclose your data for the purposes it was collected and also:
As required by law subject to our obligations
With your consent
Within our business
Send you marketing material (with your consent)
GOOGLE ANALYTICS AND FACEBOOK
WHAT ARE YOUR CHOICES?
DON'T PROVIDE US WITH PERSONAL DATA
You can choose not to provide us with any personal data. However if you do this, we will not be able to provide you with any products or services, however, you can continue to use our Site and browse the pages of our Site.
TURNING OFF COOKIES
DON'T WANT MARKETING?
We will always let you know before we collect any data from you what the intended use is and if we intend to use it for marketing and if third parties are involved we will obtain your consent (which you can withdraw at any time). You can change your mind about marketing material by opting out by (a) completing the contact us form on our contact page or by unsubscribing within the email if you have previously subscribed to our newsletter.
WHAT ARE YOUR RIGHTS?
You can exercise your rights at any time by contacting us via the contact us page on our Site or via email at email@example.com.
YOU CAN ACCESS INFORMATION WE HOLD ABOUT YOU
We will provide you with the information within 30 days of your request, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We will tell you if we can’t comply with your request and why.
You can contact us to ask us to correct any information we hold about you, that you believe is inaccurate.
OBJECTIONS TO USING DATA FOR PROFILING OR AUTOMATED DECISIONS
We may use your data to determine what products and services are relevant to you (e.g. tailoring our emails based on your behaviour). Otherwise, the only circumstances in which we will use this data is to provide our products and services to you.
YOU HAVE THE RIGHT TO BE FORGOTTEN
You have the right to request for your data to be erased. This means we have to delete all information that we hold about you, except to the extent of any information we are required to hold due to our legal obligations.
YOU HAVE THE RIGHT TO MAKE A COMPLAINT REGARDING THE USE OF YOUR DATA
If you have any complaints regarding how your data is handled, please contact us via our contact us page or via email firstname.lastname@example.org. If you are not satisfied with our response to your complaint you may seek a review by contacting the Office of the Australian Information Commissioner.
HOW SECURE IS THE DATA COLLECTED
We realise that our customers trust us to protect their data and whilst we cannot guarantee the security of any information you transmit to us, or receive from us, we take that task seriously and maintain reasonable and appropriate physical, electronic and procedural safeguards to help protect your data. This includes the following:
Password access to accounts
Storing electronic data with reputable third party storage providers who have appropriate security protections
Limit access to personal information to individuals who need to know.
WHERE DO WE STORE DATA
We use service providers based in Australia. If we transfer personal data outside of Australia, we will ensure that your privacy rights are adequately protected by ensuring these service providers have the same or similar measures in place to protect data shared.
HOW LONG DO WE STORE DATA
We will keep your data for as long as we need it and this period will also depend on your interactions with us. If you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing and tax purposes. When we no longer need to keep your information, we will delete it.
THIRD PARTIES WHO PROCESS YOUR DATA
We share data with third parties in the following circumstances:
Our suppliers and service providers working for us
Our professional and legal advisors
Law enforcement or other government authorities
Where we have your consent to do so or otherwise where we are legally permitted to do so.
All are our real time credit card authorisations are handled by secure third party gateway providers and these are secured by the highest level of security. The following measures are taken to protect your data:
Payments are fully automated with an immediate response.
Your complete credit card number cannot be viewed by us or any outside party.
All transaction data is encrypted for storage within our third party gateway suppliers bank-grade data centre, further protecting your credit card data.
Our third party gateway provider is an authorised third party processor for all the major Australian banks.
Our third party gateway provider will at no time touch your funds, all monies are directly transferred from your credit card to the merchant account held by us.
We use third party gateway providers that are widely respected for providing secure and reliable online payment solutions. We have chosen to deal with the best so you can feel safe that your personal information is kept safe and secure at all times. While we attempt to protect the information in our possession, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances.
The Payment Card Industry Data Security Standard (PCI DSS) is an information security standard for all organisations that handle branded credit cards from major card schemes. PCI DSS is a standard mandated by the card brands like Visa, Mastercard, American Express and Discover and is managed by the PCI Security Standards Council.
PCI-DSS requirements help ensure the secure handling of credit card information through our Site and the service providers.
AGE OF CONSENT
By using this site, you warrant that you are at least the age of majority in your State or Territory of residence. Our Site should not be used by anyone under the age of majority and we do not knowingly collect data from anyone under the age of majority.
COOKIES AND HOW TO BLOCK THEM
WHAT ARE COOKIES?
Unfortunately they are not the edible kind! “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. Cookies can also be used to analyse traffic and for advertising and marketing purposes. They do not harm your systems and the HELP function in your browser will tell you how to restrict or block the cookies. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. If you use browser settings to block all cookies, you may not be able to access all or parts of our Site.
We may use web beacons (or clear gifs) on our website and in our emails. So basically when we send emails, we have the ability to track behaviour such as who opened the emails, who clicked the links and collect information such as your IP address, your browser or email type, we then put this information together to improve the performance of our email campaigns and provide you with better and/or services specific to your needs. You will always have the ability to opt out of any emails we send just click the link in the email that says “unsubscribe”.