This policy explains how and why we collect, use, hold and disclose your personal information.
”We”, “us” and “our” means Addendo Pty Ltd ACN 642 415 209.
You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
Our system is encrypted and we do not have access to a majority of the information that is uploaded into our system (‘encrypted personal information’). This means that the only information that we can see is the information that you list in the About You section and also a list of the sections you have completed (‘non-encrypted personal information) (but not the information in those sections).
We also cannot change your email or password attached to any account.
1. WHAT IS PERSONAL INFORMATION?
Personal information is any information about an identified individual or an individual who can be reasonably identified from the information.
2. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We collect information about you and your interactions with us, for example, when you purchase or use any of our products or services, call us, interact with our chatbot or otherwise visit our website. The information we collect from you may include your identity and contact details, your history of purchases and use of our products and services and details of enquiries or complaints you make and all information you store and upload in your vault. We may also collect or hold financial information when processing payments – or our third party payment processing party may collect or hold that information.
We may collect information about how you access, use and interact with the website. This information may include the location from which you have come to the site and the pages you have visited and
technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.
3. WHY DO WE COLLECT, HOLD AND USE YOUR PERSONAL INFORMATION?
We collect, hold and use your personal information so that we can:
• provide you with products and services, and manage our relationship with you;
• contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
• comply with our legal obligations and assist government and law enforcement agencies or regulators; or
• identify and tell you about other products or services that we think may be of interest to you.
If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.
4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We will collect your personal information directly from you whenever you interact with us.
5. HOW DO WE STORE AND HOLD PERSONAL INFORMATION?
We store most information about you in computer systems and databases operated by either us or our external service providers.
We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted.
The security of your personal information is important to us. Accordingly, we take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification and disclosure.
However, we cannot guarantee the absolute security of that information, or that our systems will be completely free from third party interception or are incorruptible from viruses. We cannot and do not guarantee that information you send from your computer to us over the Internet will be protected by any form of encryption (encoding software).
In light of this, we cannot and do not ensure or warrant the security or privacy of your personal information, including payment and bank account details. You transmit your personal information to us at your own risk.
6. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO, AND WHY?
We may transfer or disclose your non-encrypted personal information to our related companies. Encrypted and non-encrypted personal information may also be disclosed when profiles are shared to family and friends – but this is only ever in accordance with your account settings and permissions that you have set up.
We may disclose non-encrypted personal information to external service providers so that they may perform services for us or on our behalf.:
• organisations who carry out credit, fraud and other security checks;
• third party software providers who store details of customer accounts for us or who provide other IT services;
• marketing businesses engaged by us to disseminate materials to which recipients have consented; and
• we may also disclose your non-encrypted personal information to third parties outside our group of companies:
• where we have your express permission to do so;
• where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties, including to your key holders;
• if we sell, assign or otherwise transfer part or the whole of our business, in which case your personal information, which was collected by us through your use of the service, may be among the items transferred or sold to the extent that it is relevant to our business;
• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of our business, our personnel or customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services to you. We deal with third parties that are required to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we gave it to them.
We may disclose personal information outside of Australia to third party technology suppliers such as cloud providers located in various countries.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
7. DO WE DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
We may disclose your non-encrypted personal information to our development team located outside Australia.
8. DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING?
We will use your non-encrypted personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
9. THIRD PARTIES
10. ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
Because much of your personal information is encrypted and not accessible by us, if you wish to access or request correction of the personal information that we hold about you, you must do this by logging into your account and updating your own details.
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. Our contact details are set out below.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
12. CONTACT DETAILS
If you have any questions, comments, requests or concerns, please contact us at: email@example.com
13. CHANGES TO THIS POLICY
From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.
You may obtain a copy of our current policy from our website or by contacting us at the contact details above.
14. SENSITIVE INFORMATION
The personal information collected by us may include sensitive information, which is defined in the Act as information or an opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. We will only use sensitive information:
• for the primary purpose for which it was obtained;
• for a secondary purpose that is directly related to the primary purpose;
• with your consent; or
• where required or authorised by law.