Effective Date 8 September 2021
1 Introduction
(a) We are committed to respecting your privacy. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information in connection with your use of our website, mobile application (app) and other services, features, products, content or applications offered by us (services).
(b) By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
(c) Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
(d) In this policy, “we”, “us” and “our” refer to Swift Media Limited (ACN 006 222 395) and our related bodies corporate.
2 The personal information that we collect
(a) We may collect the following types of personal information:
(i) Contact Data: We may process data enabling us to get in touch with you. The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website or app using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
(ii) Account Data: We may process your website and app user account data. The account data may include your account identifier, name, email address, business name, account creation and modification dates, website/app settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website and/or app. If you log into our website/app using a social media account, we will obtain elements of the account data from the relevant social media account provider.
(iii) Transaction Data: We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website and app. The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
(iv) Communication Data: We may process information contained in or relating to any communication that you send to us or that we send to you. The
communication data may include the communication content and metadata associated with the communication. Our website and app will generate the metadata associated with communications made using the website and app contact forms.
(v) Usage Data: We may process data about your use of our website, app and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
(b) We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
(i) register on our website or app;
(ii) communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
(iii) interact with our sites, services, content and advertising; or
(iv) invest in our business or enquire as to a potential purchase in our business.
3 Purpose of collecting, using and disclosing personal information
We may collect, hold, use and disclose your personal information for the following purposes:
(a) Operations – We may process your personal information for the purposes of operating our website and app, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control.
(b) Publications – We may process account data for the purposes of publishing such data on our website, app and elsewhere through our services in accordance with your express instructions.
(c) Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, and/or telephone, providing support services and complaint handling.
(d) Direct marketing – We may process contact data, account data and/or transaction data for the purposes of us or our carefully selected business partners creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. Any such communication will be in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
(e) Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website, app and services, as well as researching and analysing other interactions with our business.
(f) Record keeping – We may process your personal information for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally.
(g) Security – We may process your personal information for the purposes of security and the prevention of fraud and other criminal activity.
(h) Insurance and risk management – We may process your personal information where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice.
(i) Legal claims – We may process your personal information where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
(j) Legal compliance and vital interests – We may also process your personal information where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4 Providing your personal information to others
(a) We may disclose personal information for the purposes described in this privacy policy to:
(i) our employees and related bodies corporate;
(ii) third party suppliers and service providers (including providers for the operation of our websites, apps and/or our business or in connection with providing our products and services to you);
(iii) insurers, professional advisers, dealers and agents, to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice;
(iv) payment systems operators (eg merchants receiving card payments), only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds;
(v) our existing or potential agents, business partners or partners;
(vi) our sponsors or promoters of any competition that we conduct via our services;
(vii) anyone to whom our assets or businesses (or any part of them) are transferred;
(viii) specific third parties authorised by you to receive information held by us; and/or
(ix) other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law or otherwise with your consent.
(b) In addition to the specific disclosures of personal information set out in this Section 4, we may disclose your personal information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal information where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5 Transfers of your personal information
(a) Your personal information is processed in Australia and elsewhere throughout the world through us and our service providers (including third party suppliers and cloud providers), where the laws may differ from the laws where you reside. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
(b) Your consent to this Privacy Policy followed by your submission of such personal information represents your consent to the transfer of your information outside of your country of origin, where laws regarding processing personal information may be less stringent than your country. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is secure and consistent with this Privacy Policy and no transfer of your personal information will take place to an organisation or a country unless there are adequate controls in place including the security of your data and personal information.
(c) You acknowledge that personal information that you submit for publication through our website, app or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal information by others.
6 Third party service providers
When you use our website or app, third parties may collect, store and/or process the information detailed in this Privacy Policy. These third parties are carefully selected to ensure that they, and their related entities who may access your personal information, provide your information with equal protection to that stated in this Privacy Policy and as required by applicable privacy laws and the applicable platform provider’s (e.g. Google and Apple) rules, policies and guidelines. We use commercially reasonable efforts to engage with these third parties that post a privacy policy governing their collection, retention, processing and use of non-personal and personal information.
7 Retaining and deleting personal information
(a) We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
(b) We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website and app, or We are legally obligated to retain this data for longer time periods.
8 Your rights
(a) We undertake to respect the confidentiality of your personal information and to guarantee you can exercise your rights.
(b) You have the following rights under this Privacy Policy, and by law if you are within the European Economic Area (EEA) or United Kingdom:
(i) the right to access – you can ask for copies of your personal information;
(ii) the right to rectification – you can ask us to rectify inaccurate personal information and to complete incomplete personal information;
(iii) the right to erasure – you can ask us to erase your personal information;
(iv) the right to restrict processing – you can ask us to restrict the processing of your personal information;
(v) the right to object to processing – you can object to the processing of your personal information;
(vi) the right to data portability – you can ask that we transfer your personal information to another organisation or to you;
(vii) the right to complain to a supervisory authority – you can complain about our processing of your personal information; and
(viii) the right to withdraw consent – to the extent that the legal basis of our processing of your personal information is consent, you can withdraw that consent.
(c) These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
(d) You may exercise any of your rights in relation to your personal information by written notice to us, using the contact details set out below. If you are located in the EEA, you have the right to complain to a data protection authority. For more information, please contact your local data protection authority in the EEA.
9 About cookies
(a) A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
(b) Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
(c) Cookies may not contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10 Cookies that we use
We use cookies and/or similar technologies for the following purposes:
(a) authentication and status – we use cookies to identify you when you visit our website and as you navigate our website or use our app, and to help us determine if you are logged into our website and/or app;
(b) shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website and app;
(c) personalisation – we use cookies to store information about your preferences and to personalise our website and app for you;
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. Often targeting or advertising cookies will be linked to site and app functionality provided by the other organisation.;
(f) analysis – we use cookies to help us to analyse the use and performance of our website, app and services; and
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
11 Cookies used by our service providers
(a) Our service providers use cookies and those cookies may be stored on your computer when you visit our website or use our app.
(b) We use Google Analytics. Google Analytics gathers information about the use of our website and app by means of cookies. The information gathered is used to create reports about the use of our website and app. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.
12 Managing cookies
(a) Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(i) https://support.google.com/chrome/answer/95647 (Chrome);
(ii) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(iii) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(iv) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(v) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(vi) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
(b) Blocking all cookies will have a negative impact upon the usability of many websites.
(c) If you block cookies, you will not be able to use all the features on our website.
13 Security
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorised access or use will never occur. To the fullest extent permitted by law we are not responsible or liable for unauthorised disclosure or access, hacking, or other security intrusions or the theft, alteration, deletion, corruption, destruction, damage, or loss of any data or information included in the user generated content.
14 Links
Our website and app may contain links to websites and apps operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites or apps.
15 Accessing or correcting your personal information
(a) You can access the personal information we hold about you by contacting us. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
(b) There is no charge for requesting access to your personal information, but we may charge you a reasonable amount to cover matters such as retrieving, copying & sending out information in connection with an access request. There is no charge for correcting your personal information.
(c) We will respond to your requests to access or correct personal information in a reasonable time & will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date & complete.
(d) If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
16 Making a complaint
If you think we have breached any applicable privacy laws, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
17 Amendments
(a) We may update this policy from time to time by publishing a new version on our website.
(b) You should check this page occasionally to ensure you are happy with any changes to this policy.
(c) We will notify you of any significant changes to this policy by email and/or a prominent notice on our website and app prior to any significant changes becoming effective.
18 Our details
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
1060 Hay Street, West Perth WA 6005
info@swiftnetworks.com.au
+61 8 6103 7595