- Provider has adopted this Policy in accordance with the privacy law.
- This Policy outlines how Provider deals with Personal Information, which it collects in conjunction with the Services.
- Provider may also collect information about Individuals who do not use the Services.
- Capitalised words in this Policy are defined terms. Defined terms are explained at the end of this Policy.
2. Collecting information directly from people
Provider collects Personal Information directly when an Individual:
- Contacts Provider by telephone, fax, email or another from of communication;
- Gives Provider his or her information in person on a paper form;
- Sends the Provider a message through SMS or a third party app;
- Other ways Provider collects information directly;
- Registers or subscribes for an account;
- The Service automatically captures Personal Information in content Individuals post on the Services;
- Provider’s server and analytics service may log details about website visits;
- Provider’s own analytics services may monitor Individuals’ computers and send back regular ‘health checks’ and other information;
- Location services, when switched on, capture Individuals’ locations;
- Provider’s website will likely place a cookie on Individuals’ devices; and
- Store visitors’ I.P. addresses.
3. Collecting information from third parties
Provider collects Personal Information about Individuals from third parties when:
- Individuals link their account on the Service with accounts on social networks such as Facebook;
- Provider utilises IT service providers such as Microsoft;
- Telecommunications networks such as Telstra and others;
- Individuals follow the Provider on social networks;
- Third parties give Provider access to files containing Personal Information;
- Provider conducts research on Individuals, including potential customers; and
- Individuals review the Provider online.
4. Organisations using the services
Provider provides the Services to Organisations, which may utilise them for facilitating their business. Both Provider and the Organisations may collect Personal Information from Individuals, including when:
- Individuals register for or access a website provided by the Organisation with the Services;
- Organisations collect information directly from Individuals using the Service;
- Organisations give Provider access to their files containing Personal Information; and
- Organisations enter or process information (such as notes or files) about Individuals using the Services.
- Telecommunications networks and other third parties use the Services to facilitate interactions between themselves, Organisations and Individuals.
5. Types of Information that Provider collects and holds
Using processes described in this Policy, Provider collects the following categories of Personal Information about Individuals:
- (Content) whatever Personal Information is included in content Individuals enter using Provider’s Services;
- (Identity Information) name, signature, date of birth, nationality, license & registration details, bank and credit card details, family details, employment details, educational qualifications, usernames;
- (Contact Information) email address, social media profiles, telephone & fax number, third-party usernames, residential, Provider and postal addresses;
- (Behaviour Information) habits, movements, trends, decisions, associations, memberships, finances, purchases;
- (Internet Data) webpage views, IP address, referring web site addresses, location, browser type, operating system, domain name, access times and other data typically collected by analytics services like Google Analytics;
- (Customer Information) any information shared by Organisations with Provider, including financial details, software and identity information and other information;
6. Sensitive Information
Privacy law categorizes certain types of Personal Information as “sensitive information”. Provider does not actively collect sensitive information, but information that Individuals post or store, or Organisations share, using the Services may fall into this category.
7. How provider stores Personal Information
Provider holds and stores Personal Information using:
- (Storage Services) Provider’s own storage services and third party data storage services, including applications and software;
- (Provider Devices) devices operated by employees of Provider’s business; and
- (Paper Files) printed paper and third party physical storage services.
Provider will take reasonable precautions to protect Personal Information from unauthorised access. This includes measures to secure the Provider’s physical facilities and electronic networks.
Provider secures Personal Information that Provider collects with methods such as credentials, passwords, pins, encryption, session expiry, firewalls, SSL network encryption, and through the use of reputable vendors.
For more information on security, please contact Provider using the details in the “contacting us” below.
9. Deletion procedures
Provider deletes Personal Information within 90 days of written notice from Individuals requesting removal of their data.
10. Why data is held, used and disclosed
Provider’s handling of Personal Information includes holding, using and sometimes sharing the Personal Information so that Provider can:
- provide functionality within the Services;
- provide notifications and support;
- offer marketing and promotions, competitions, surveys and questionnaires;
- transact with Individuals and process payments;
- assess and improve the Services;
- provide secure access to the Services;
- providing personalised Services;
For more information on when Provider shares Personal Information, see below.
11. Handling of data
Provider shares Personal Information with others in the following ways:
- displaying information about Individuals on pages, profiles, walls, and accounts;
- publishing details about Individuals in their pages on Provider’s website;
- sharing profile and activity information with social networks, and posting to those social networks if Individuals have given permission for this to occur;
- PR publications;
- showing usernames and contact details on forums, blogs, comments, messages and correspondence; and
- facilitating the sharing of information about sales, inquiries and payments.
13. Service providers can access personal information
When Provider uses the services of companies that Provider works with to provide the Services, they may get access to the Provider’s data, including Personal Information. Such third party services may include:
- (Hosting) Cloud and web hosting service providers;
- (SaaS) providers of software as a service;
- (Telecommunications providers) such as Telstra and other Organisations;
- (Support) providers of IT support services such Amazon Web Services, Microsoft, IBM and other web and computer software development Organisations;
- (Data analytics) Google Analytics (see [http://www.google.com/intl/en/policies/privacy/](http://www.google.com/intl/en/policies/privacy/));
- (Online payment) providers of online payment systems; and
- (Apple device functionality providers) Apple location services, Siri dictation, Apple Maps, Apple Notifications (see [http://www.apple.com/au/privacy/](http://www.apple.com/au/privacy/)).
Provider will only share Personal Information with these third parties to the extent reasonably necessary to perform their functions.
These third parties may have their own privacy and security policies. For more information about this, please contact Provider using the details listed in the “contacting us” section below.
For information on disclosures to overseas recipients, see below
14. Disclosing information overseas
The Provider may store or process some Personal Information overseas. Individuals may not have the same rights relating to their information when it is overseas as they would under Australian privacy law.
If Individuals consent to such transfer, Provider will not be accountable for overseas recipients’ handling of their Personal Information.
15. Contacting us
Individuals contact the Provider using the details below if they want to access, correct or delete Personal Information or lodge a complaint.
Provider reserves the right to refuse access or correction where there are reasonable grounds for doing so, for example if providing access would be unlawful or would compromise the privacy of another person.
16. Complaints process
If Individuals have a complaint about privacy, they can contact Provider using the details listed above.
Provider will respond to complaints in writing within a reasonable period (usually 10 business days from the day Provider receives an email).
Provider will try to work with Individuals to resolve complaints entirely within 20 business days, although that period may be longer if it is reasonable to take longer given the nature of the complaint.
If Individuals are unsatisfied with our response, they may refer the complaint to the Office of the Australian Information Commissioner (http://www.oaic.gov.au/).
- Individual, Individuals – means a natural person.
- Organisation, Organisations – means third party Organisations using the Services including IT providers, data storage services, physical storage services, marketing services and other services.
- Personal Information – means information about an Individual whose identity is apparent, or can reasonably be ascertained, from that information. This includes information like names, telephone numbers, email addresses and physical addresses.
- Policy, Policies – means this document, drafted in accordance with the Privacy Act 1988 (Cth).
- Provider – means Cloud Specialists Pty Ltd
- Service, Services – means IT and technology services provided by Cloud Specialists Pty Ltd.