1. collect and manage your personal information;
2. use and disclose your personal information;
3. store and keep secure your personal information;
5. are transparent about our privacy practices; and
6. can communicate with you about your personal information.
How we collect and manage your personal information
1.2 Types of information collected
We only collect information to the extent that this is reasonably necessary in connection with our service offerings and may include:
▪ Personal details including your name, address and postcode;
▪ Contact details including your phone number and email address;
▪ Payment details including your credit card or direct debit account details;
▪ Business details including the nature of your business, information and materials (including your intellectual property) provided by you to us in connection with the services you request;
▪ Training details such as processing and making arrangements for your training related to the services you request;
▪ Usage details such as information about how you use our services, your preferences, browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit;
▪ Social media details including any information you allow a social media site to share with us;
▪ Feedback such as your comments, enquiries, complaints and other feedback you provide.
If you decide not to provide us with certain personal information, we may not be able to fully investigate your comments, enquiries or complaints or provide our services to you.
1.3 How we collect personal information
Our preference is to collect personal information directly from you unless it is unreasonable or impracticable for us to do so.
Information will generally be collected in the course of our dealings with you, including:
▪ directly from you, such as when you apply for or use our services, contact us with a comment, enquiry or complaint, engage in our training programs or seminars, or access our website, mobile applications or social media platforms;
▪ our related businesses and partners;
▪ our third party service providers, including IT, market research and where competitions and promotions are run on our behalf; and
▪ information that is publicly available.
In addition, you warrant that you have obtained the irrevocable consent to provide the personal information from those individuals whose personal information may be collected by us.
We may combine and compare personal information about you with other information collected from or held by others. We do this to better understand your interests and preferences which helps us enhance your experience with us.
How we use and disclose your personal information
We will not use or disclose personal information for purposes other than those connected with the primary purpose of collection, or a reasonably related secondary purpose which we believe you should reasonably expect.
Secondary purposes might include disclosure to maintenance personnel or other third party service providers who may be unable to avoid accessing personal information in the course of providing technical or other support services to us.
We may also share your personal information with third parties including:
▪ Advertisers: we may, from time to time, engage marketing strategies, including targeted online advertising and online behavioural marketing and may disclose some of your personal information to third parties, including advertisers and partners. You agree that we may provide any of the data we have collected from you in non personally identifiable form to those third parties. If you engage with an advertisement, the advertiser may collect personal information from you.
▪ Related Businesses: businesses or third-party websites we are affiliated with may, from time to time, sell or provide products or services to you through or in connection with our services (either individually or jointly with us). We will share your personal information with that affiliated business only to the extent that it is related to such product or service. We have no control over the privacy policies and practices of third party websites or businesses so if you choose to interact with an affiliated website or business, you should review all policies of that business or website.
▪ Our Partners: we engage others to perform tasks on our behalf and need to share your personal information with them to provide products and services to you. Unless we tell you otherwise, our partners do not have any right to use the personal information we share with them beyond what is necessary to assist us.
▪ Reports/Analytics: We store data that is used in the form of aggregated and generic statistics or reports in order to better understand user profiles for the improvement of the products offered by us.
2.1 Direct marketing
We will not use or disclose personal information for the purposes of direct marketing to you unless:
(a) you have consented to receive direct marketing materials; or
(b) you would reasonably expect us to use your personal details for this purpose; or
(c) we believe you may be interested in the material but it is impractical for us to obtain your consent.
We may contact you by SMS, post, email, telephone, our websites and mobile applications, and through social media. In every instance, we will ensure that our direct marketing material incorporates an option for you to elect to receive no further marketing communications.
Even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services, questionnaires and other factual information. This form of communication is not regarded as “direct marketing” under the Privacy Act.
2.2 Manage your preferences and unsubscribing
You can contact us at any time if you no longer wish to receive marketing materials from us, our related businesses or partners, or to update your preferences.
If you receive marketing correspondence by SMS, email or telephone from us, you can opt out from any or all of our marketing by clicking the “unsubscribe here” function at the base of any marketing email communication or following the OPT-OUT instructions in any SMS communication you receive from us.
How we store and secure your personal information
We mostly hold personal information electronically in our IT systems and databases which may utilise cloud technology in connection with the storage of personal information.
We use third party service providers to store some or all personal information. As such, we are unable to control the location in which personal information is stored. It is not practicable for us to specify in advance which country will have jurisdiction for any off-shore activities. All of our service providers, however, are required to comply with the Privacy Act in relation to the transfer or storage of personal information.
3.1 Data security
We have risk management systems in place to protect the personal information which we hold and limit misuse or loss and unauthorised access, modification or disclosure. This includes firewalls and encryption of customer data during storage and transmission. We will destroy or de-identify personal information once we no longer require it for our business purposes.
When using our website, mobile applications and services you should be aware that no data transmission over the internet can be guaranteed as totally secure. Although we have risk management systems in place and strive to protect such information, we do not guarantee your personal information is secure and you provide your personal information at your own risk.
Please contact us immediately if you become aware of a breach of security.
To help us keep your personal information safe, please do not share your login details, preferences, unique reference details or any other information with any other person.
3.2 Data retention
We will retain your personal information for as long as reasonably necessary to fulfil any valid or lawful purpose including:
▪ providing services to you;
▪ investigating and defending any actual or potential claim or complaint;
▪ exercising our rights and obligations under contract or law; or
▪ as otherwise permitted by law.
When it is no longer reasonably necessary to keep your personal information, we will destroy your personal information. However, we may de-identify data which we may retain for statistical purposes.
Cookies and similar technologies allow our websites and mobile applications to interact more efficiently with the device used and to help us improve the content and functionality of our websites and mobile applications. They also generate detailed statistics about traffic to our websites, how individuals interact with advertisements on our (and third party) websites, browsing and other activity, and can measure and record conversions and sales.
How we are transparent about our practices
How we can communicate with you about your personal information
We will take reasonable steps to ensure that the personal information which we collect remains accurate and complete.
You have a right to request access to or correct your personal information held by us and you may request further information about our personal information handling practices.
We will provide you with access to your personal information held by us unless we are permitted under the Privacy Act or law to refuse to provide you with such access. If this is the case we will let you know the reasons in writing.
Please contact us using the details below if you:
(a) wish to have access to the personal information we hold about you;
(b) consider that the personal information we hold about you is not accurate, complete, irrelevant, out of date or misleading; or
(c) require further information on our personal information handling practice.
You can contact us about your personal information by:
Writing to us at:
PO Box 3316 Merewether NSW 2291 Australia
Emailing us at: firstname.lastname@example.org
We will need to verify your identity before we can process your request.
There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.
We will take reasonable steps, consistent with our obligations under the Privacy Act, to correct that information if you so request. We will respond to all requests for access and/or correction within a reasonable time of you making a request (a more complex request will usually take us 45 days) and will give you access in the manner you request unless it is unreasonable or impracticable for us to do so.
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us using the above details.
If you remain dissatisfied with the way in which we have handled a privacy issue, we suggest you approach an independent advisor or contact the Office of the Australian Information Commissioner for guidance on alternative courses of action which may be available.
In this policy we use the expressions:
“personal information” to refer to information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. It also means information protected under the Privacy Act that relates to the affairs or personal particulars of a person;
“we”, “us” and “our” as a reference to Ecommerce Industries Pty Ltd ACN 644 072 033 and Ecommerce Media Pty Ltd ACN (648 640 439) (together, Ecommerce Group) and other related subsidiaries;
“you” and “your” to refer to each and every individual whose personal information we may handle from time to time.
Any reference to us assuming an obligation under the Privacy Act, Australian Privacy Principles or other privacy legislation can be interpreted as a reference to us also procuring our service providers to undertake a reciprocal obligation to the extent relevant.