Your privacy is important to us. This Privacy Policy explains in general terms how we collect, use and protect your Personal Information in line with the Privacy Law.
We endeavour to maintain a Privacy Policy that is transparent, accountable and offers choice regarding the collection and use of your Personal Information. If you have questions or complaints regarding thisPrivacy Policy or our practices, see our contact details at the end of this document.
1. Definitions used in this Privacy Policy
1.1 In this Privacy Policy:
(a) App means our software application called "SignifyOne®" and any other software applications we own or are licensed to use.
(b) customer means an individual who obtains services from us, including from use of theApp.
(c) Personal Information means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion and includes any further Personal Information that we obtain from any continuing contact or when receiving services or by the provision of services and includes Sensitive information.
(d) Privacy Law means the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
(e) Sensitive Information is Personal Information which includes information or an opinion about an individual’s racial or ethnic origin, political opinion or association, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, biometric information, genetic information or health information.
(f) service provider refers to an individual registered with us to provide services to a customer.
(g) services means any services we provide to you, including from the use of the App.
(h) we, us and our means Jashre Pty Ltd (ACN 673 305 710) and any entities related to or associated with that company, and any successor or assignee company.
(i) website means our website hosted at https://www.signifyone.com/or any other websites nominated by us.
(j) you means any person who uses the App or who provides Personal Information to us, or whose Personal Information we collect.
2. Information you provide to us
2.1 When you use the App, communicate by phone, send us an email, send information to us through our website, or write to us, you provide us with Personal Information that we may collect, store and use.
2.2 By providing us with Personal Information, you consent to that information being collected, stored, used and disclosed by us and our associates in accordance with this Privacy Policy.
2.3 We will not use Sensitive Information to send you direct marketing communications without your consent.
3. Collection of Sensitive Information
3.1 We may collect Sensitive Information from you when you use the App and where required for us to provide services that you request from us. The type of Sensitive Information we may collect from you, or record, may relate to your sexual preferences. By using the App and providing Sensitive Information to us, you consent to us using and collecting that information in accordance with thisPrivacy Policy and the Privacy Law.
4. Other information we receive and store
4.1 If you use our website, we may utilise "cookies" which enable us to monitor traffic patterns and to serve you more efficiently if you revisit our website. A cookie does not identify you personally but may identify your internet service provider or computer. We may store cookies on your computer.You can set your browser to notify you when you receive a cookie, and this will provide you with an opportunity to either accept or reject it in each instance. However, you should be aware that by rejecting our cookies, we may be unable to provide our products or services to you or our ability to do so may be affected or limited.
5. Tracking emails to our customers & service providers
5.1 When we send group emails to a selected group such as an email containing a newsletter, we sometimes track who opened email and hyperlinks. We do this to measure the performance of ouremail campaigns and to improve our response.
5.2 You do not have to provide us with any Personal Information if you are a visitor to our website and you may choose to remain anonymous or to provide us with a pseudonym if you do not wish to reveal your identity. However, you should be aware that by remaining anonymous or by providing a pseudonym, we may be unable to provide services to you or our ability to do so may be affected or limited. We may also be unable to respond to any request, particularly if we have a concern inrelation to the dissemination of information to an unknown party.
6. Information from other sources
6.1 Unless it is unreasonable or impracticable to do so, we will collect your Personal Information directly from you. Sometimes we may have information provided by others or it may be necessary for us to collect your Personal Information from a third party or from a publicly available source. We will only collect Personal Information in that way where we are permitted to do so under the Privacy Law.Where Personal Information is collected from another party, we will take reasonable steps to inform you, at or as soon as possible after collection. We may obtain additional information about you by independent means, such as social media websites.
6.2 If you provide us with someone else’s information, you should only so do where you have their authority or consent. You should also take reasonable steps to inform them of the disclosure and of the matters set out in this Privacy Policy.
6.3 Our website may include links to 3rd party websites. If you choose to access those websites (even via link) you will be subject to their terms, including their privacy policy. We do not endorse or accept any other website by providing a link to it.
7. Use and disclosure of your Personal Information
7.1 We collect and use your Personal Information for some or all of these reasons:
(a) to facilitate your use of the App and for us to provide you with our services;
(b) for administration and management services;
(c) to bill and collect sums owed to us by you. Uses for this purpose include sending you emails, invoices, receipts, account reminders and notices, to alert you if we need a different credit card number and to otherwise collect money owed. We may use third parties to handle secure credit card transaction processing, who maintain all PersonalInformation in confidence, to process your orders and credit card payments;
(d) to send you SMS, email or other forms of message to let you know about changes that may affect our services and to notify you of changes to this Privacy Policy, service arrangements, documents and agreements;
(e) to help implement and maintain compliance with our Terms and Conditions governing the use of the App and our services;
(f) to provide customer support and obtain feedback;
(g) to protect our rights and safety, and that of our customers, service providers, agents and others; and
(h) as may be required by law.
7.2 As a customer, you consent to us providing such of your Personal Information to our related entities or service providers as is necessary to enable them to provide services to you.
7.3 We will only collect your Personal Information where it is reasonably necessary to enable us to undertake one or more of our activities.
8. Security of Personal Information
8.1 We will take reasonable commercial measures to ensure the security of your Personal Information, whether kept in electronic form or hard copy.
8.2 We use a range of physical and electronic procedures to ensure the privacy of your Personal Information is safeguarded. These include restricting physical access to our offices and maintaining a secure computer system and database.
8.3 Our servers are protected by password, propriety software, firewalls, lock and key and other security measures.
8.4 Password protected access levels and user privileges limit access to your electronically stored Personal Information. This means that a user will only have access to your Personal Information that is necessary to carry out their work. Hard copy records are shredded and disposed of by secure means.
8.5 Our employees and service providers are obliged to respect and maintain the confidentiality of any Personal Information held by us.
8.6 No data transmission over the internet can be guaranteed to be secure and you acknowledge and accept that risk when you use the App and our services.
9. We safeguard your Personal Information
9.1 We do not sell, lend or trade your Personal Information to third parties. We do not provide your Personal Information to third parties so that those third parties can directly market their goods or services to you without your consent.
9.2 We sometimes employ computer programmers to carry out work for us and they may have access to your Personal Information. They are only permitted to use your Personal Information for the purpose of carrying out the work that we have contracted them to do and for no other purpose. They are not permitted to retain any records of your Personal Information.
9.3 We utilize cloud services technology. Our servers are in Australia and your Personal Information will be stored on those servers. We do not provide your Personal Information to any overseas person or entity. We will inform you if our practices change in relation to those matters.
10. Notice of breach of security
10.1 We will notify you, as soon as possible, if a breach in security results in an unauthorized intrusion into our system that materially affects you and will subsequently report the corrective action taken in response to the intrusion. Specifically, we will comply with our obligations under the Privacy Law if a notifiable data breach occurs and will liaise with the Office of the Australian InformationCommissioner to manage that breach.
11. Data breach
11.1 If a data breach occurs, we will:
(a) take all reasonable steps to recover or otherwise secure your Personal Information;
(b) limit access to your Personal Information;
(c) minimise the risk of harm; and
(d) take such other steps as we may decide would be prudent for us to take in the circumstances.
11.2 We will also notify you of any breach if we form the view that the breach is likely to result in any serious harm.
12. Notification of changes
12.1 Any changes to this Privacy Policy will be posted to our website and will become effective at the time the changes are posted.
12.2 You accept the terms of our revised Privacy Policy when you engage with us in any manner after those changes have been made.
13. Accuracy of data and your rights to make changes
13.1 Where we obtain any data from your use of our website or through other information which you provide to us, you acknowledge that we or our related entities will own the data and any rights which may subsist in it. Such data will normally be collected in aggregated form and not contain Personal Information which would otherwise identify you.
13.2 We do our best to keep your details accurate and up to date. To do this, it is necessary for you to provide us with timely information. If your data changes, then you should notify us of those changes so that we can keep your records up to date. If you believe that any Personal Information which we have collected about you is inaccurate, incomplete or not up to date, please contact us and we will take all reasonable steps to correct it in accordance with the Privacy Law.
13.3 We retain your Personal Information only for so long as reasonably required to meet the purposes for which we have the right to use the information. We will give you access to any of your PersonalInformation that we hold about you as quickly as possible and within 30 days of any request you make for such information. We may charge for providing this information to you, if permitted by law.
13.4 In some circumstances we may refuse to give you access to Personal Information and in those circumstances, we will explain why. Access may be denied for these reasons:
(a) we reasonably believe that giving the information would pose a serious threat to the life,health or safety of an individual or to public health and safety;
(b) providing access would create an unreasonable impact on the privacy of others;
(c) the request is frivolous or vexatious;
(d) the request relates to existing or anticipated legal proceedings and is not available by the process of discovery;
(e) providing access would prejudice negotiations with the individual making the request by revealing our intention;
(f) access would be unlawful;
(g) denial of access is authorised or required by law;
(h) access would prejudice enforcement related activities of an enforcement body;
(i) access would reveal evaluative information of “a commercially sensitive”, decision making process or information; or
(j) any other reason that is provided for in the Privacy Law.
14. Credit related information
14.1 If we provide services to you on credit (that is, where you will pay for those services after we start providing them to you), we may be a 'credit provider' for the purposes of the Privacy Laws.
14.2 We may collect, hold and use certain credit related information about you, we will generally only obtain this information from you. We do not collect or exchange information with credit reporting bodies and other credit providers. We use credit related information to assist us in determining whether we will provide or continue to provide services to you on credit and to manage our relationship with you.
14.3 Unless otherwise required by law, we only disclose your credit related information to third parties in limited circumstances permitted by the Privacy Law. We may disclose your credit related information to parties that provide credit related services to us such as debt collectors, credit management agencies, advisers and our agents. We may also disclose your credit related information to a third party that you or we request act as a guarantor in relation to any credit provided to you, or as required by law or the order of a court or tribunal.
15. How you can access and/or amend your credit related information
15.1 You may request access to any credit related information that we hold about you and/or request that we correct any credit related information that we hold about you. We will endeavour to respond to your request within 30 days (or such longer period as you may agree).
15.2 If we correct credit related information that we hold about you without you first making a correction request, we will take reasonable steps to notify that correction to you.
15.3 You may complain about any failure by us to comply with Part IIIA of the Privacy Act or the CreditReporting Code. If your complaint relates to our failure to provide access to or to correct any credit related information that we hold about you, you may lodge a complaint directly with the Office of the Australian Information Commissioner. If your complaint does not relate to these matters, you must first lodge a complaint with Us in accordance with the procedure set out in this Privacy Policy, which sets out how we will deal with such complaints.
16. We reserve our rights
16.1 We reserve the right to disclose or use Personal Information as permitted by the Privacy Law in circumstances not set out in this Privacy Policy.
17. Effective date
17.1 This Privacy Policy is effective with respect to all Personal Information that we have collected todate.
18. Resolving privacy complaints
18.1 We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
18.2 If you have any concerns or complaints about the way we have collected, used or disclosed and stored your Personal Information, you can tell us by contacting us at:
Jashre Pty Ltd
Att: Privacy Officer
PO Box 1062, Cleveland QLD 4163
Phone: +61 1300 681 302
Email: office@jashre.com
18.3 To resolve a complaint, we:
(a) will liaise with you to identify and define the nature and cause of the complaint;
(b) may request that you provide the details of the complaint in writing;
(c) will keep you informed of the likely time within which we will respond to your complaint; and
(d) will inform you of the legislative basis (if any) of our decision in resolving such complaint
18.4 We will keep a record of the complaint and any action taken in a privacy register.
18.5 Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information. The Commissioner can be contacted at:
The Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au
