Privacy policy.
This privacy policy (Privacy Policy) sets out how DigitalPaths Pty Ltd ACN 652 747 512 (we, our, us) collects, stores, uses, protects, shares and discloses your personal information. It applies to our platform accessible at digitalpaths.co and its related services, products, websites, applications and tools (together the Platform). By visiting or using the Platform you agree to the collection, storage, usage and disclosure of your personal information by us in the manner described in this Privacy Policy.
Capitalised words in this Privacy Policy have the same meaning as in the Terms and Conditions available on the Platform.
1. Types of Personal Information we collect
As part of delivering our Services we may collect personal information about you as defined under the Privacy Act 1998 (“Privacy Act”). We will only collect personal information where it is reasonably necessary for the performance of our functions or activities. The personal information we collect may include the following:
● Account information: this includes information you provide to us during the Account registration phase such as your name, business details, information of Authorised Users, and any other information that will assist us in delivering the Services to you and includes information regarding any subscriptions. Where Clients create Accounts for Authorised Users, we may also collect detail provided to us in respect of such Authorised Users.
● Participant activity: when you use the Platform, or your Authorised Users use the Platform we collect the details of each service to fulfil the provision of the Services to you. This also includes data provided by third party services where integrated with the Platform and any information provided by a Client about their customers.
● Financial information: this includes information such as payment card details and bank account details. We use this information to send to our third party payment gateways or make payments.
● Platform use information: When you use our Platform, for example when you contact us we collect information that enables the Platform to be able to run.
● Surveys: information in connection with client surveys, questionnaires and promotions.
● Contact information: when you use our Platform, for example when you contact us we collect information that enables the Platform to be able to run.
● Other information: we collect related to your use of the Platform: your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information and any other information provided by you to us via our Platform or our online presence, or otherwise required by us or provided by you.
In respect of personal information of Authorised Users or customers of our Clients that use our Platform (or that are otherwise transmitted through the Platform), such personal information may be processed by the Services on behalf of the relevant Client. When working in such processing capacity we will be acting on the instructions of our Clients and you will need to review the privacy policy of the relevant Client as in this instance they will have control of the personal information, and we will only process it on behalf of our Clients in accordance with their instructions and not for our own purposes.
Ultimately, the Client is in control of the personal information of Authorised Users and its customers and we act only to process that personal information in accordance with their instructions. This means that you should contact the Client with any requests.
2. How we collect Personal Information
We may collect personal information either directly from you, or from third parties, including where:
● you register or sign up to the Platform (or when you login through social media);
● you or a third party use the Platform to enter in content;
● you use the Platform generally (such as by viewing the Platform);
● you subscribe to any of our newsletters;
● you contact us through our Platform;
● you submit any of our online sign up forms;
● you provide written requests;
● through the provision of identity documents;
● you communicate with us via email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise;
● you interact with our Platform, social applications, services, content and advertising; and
● you invest in our business or enquire as to a potential purchase in our business.
We may also collect your personal information from third parties including your other service providers and publicly available sources. If a Client signs up on your behalf we will collect information about you provided by the relevant Client. If a Client provides information about you, we will collect that information provided by the Client. We rely on their acknowledged consent on your behalf. Where we collect your personal information from a third party, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Social media and cookies
We may also collect personal information from you when you use or access our Services or our social media pages. This may be done through use of web analytics tools, 'cookies' or other similar tracking technologies that allow us to track and analyse your Services usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. We may use “persistent cookies” to save your registration ID and login password for future logins to the Platform. We may use “session ID cookies” to enable certain features of the Platform, to better understand how you interact with the Platform and to monitor aggregate usage and web traffic routing on the Platform. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Platform.
3. Use of your Personal Information
We collect and use personal information for the following purposes:
● to operate the Platform and provide services or information to you including to:
o facilitate the interaction between you and us (and the Platform) to enable us to provide the Services to you;
o facilitate the provision of data insights as requested by a Client;
o any other act to otherwise enable you to participate on the Platform;
o assist in streaming and personalising information for you;
o enable us to process your personal data;
o enable us to receive payment;
o prevent and detect fraud and/or money laundering;
o enable us to provide your personal data to others whom you consent or where permitted under the Privacy Act (as detailed below);
o to manage our relationship with you, including information about similar products or terms and conditions or send you an email reminder that a task you have performed on our Platform remains uncompleted such an incomplete form;
o enable you to communicate with us regarding your use of the Platform;
o verify your identity (including via third party service providers);
o to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing the Services to you;
o communicate with you about your Account, or any transaction;
● to be de-identified for the purposes of generating statistical data and improving the Platform;
● for record keeping and administrative purposes;
● to improve and optimise our service offering and customer experience;
● to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
● to administer and protect our Services;
● to enable you to take part in a competition;
● to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth)). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
● to manage risks, fraud and security (including using your mobile phone number and any other relevant identifier for two-factor authentication purposes);
● to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
● to consider an application of employment from you.
We will not sell, rent, lease or give away your information to any third party in ways different from what is disclosed in this Privacy Policy or any agreement we have with you.
4. Disclosure of your Personal Information
We may disclose your personal information to our employees and volunteers, service providers who assist us to provide the Services to you such as those service providers in our business operations, payment processing providers, database maintenance, data storage and hosting, mailing houses, information technology service providers, contractors and other third parties located inside or outside of Australia. If we disclose personal information outside of Australia, we will take reasonable steps to ensure that any overseas recipient deals with such personal information in adherence with the Australian Privacy Principles.
We may also disclose your personal information to third parties to whom you expressly ask us to send the personal information to or to third parties where permitted under the Privacy Act. This also includes:
(a) the relevant Client that you expressly authorise;
(b) your authorised representatives;
(c) government and regulatory authorities and other similar organisations, as required or authorised by law; and
(d) such entities that we propose to merge with or be acquired by.
If you access third-party services to login to the Platform, or to share information with, these third-party services may be able to collect your information in accordance with their privacy policies. We may also send your personally identifiable information to our payment service providers.
Any information that you post or share or otherwise disclose to the Platform or our social media platforms, becomes available to the public, as controlled by any applicable privacy settings you set. Please note that others may also share your content or share content about you. Anything that you share on the Platform or on social media platforms is at your own risk.
We may also aggregate and/or make anonymous your personal information including sensitive information to make it available for the purposes of generating statistical data for the conducting of research and improving the Platform.
5. Storage and Security
We use third-party cloud services provided by global providers which includes hosting, data storage (with instances that may be in different physical locations depending on routing services) and other services.
We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measure to protect these systems. However, we cannot guarantee the security of your personal information.
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
6. Google Analytics and similar technologies
We may use Google Analytics for usage statistics. Google Analytics collects information anonymously and reports website trends without identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. Site owners can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. Please see the following links for more information about Google Analytics: http://www.google.com/analytics/,http://www.google.com/privacy.html and http://www.google.com/analytics/tos.html.You can also opt-out of Google Analytics for Display Advertising by going to the Google Ads Preferences Manager.
7. Links
From time to time we may include embedded content from, and links to, other websites. Those websites are not under our control. The links and embedded content are provided for your convenience only. We do not endorse, and are not responsible for the content, validity, accuracy or your use of, those websites. You should check the terms and conditions of use of those websites before you use them.
You may not create a link to the Platform from another website (other than to the home page) without our prior written consent, which may be given or withheld at our sole discretion.
8. Requesting access or correcting your Personal Information
Subject to the Privacy Act, you have a right to access and correct any personal information about you that we may hold. If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.
If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
If we receive a request from you to access or correct personal information we will respond to you within a reasonable time after receiving your request and in the manner requested by you, if it is reasonable and practicable for us to do so. We may charge a reasonable fee for giving access to the information.
9. If we can’t collect your Personal Information
If you do not provide us with the personal information described above, some or all of the following may happen:
● we may not be able to provide the Platform to you, either to the same standard or at all;
● we may not be able to provide you with information about the Platform that you may want;
● we may be unable to tailor the content of our Platform to your preferences and your experience of our Services may not be as enjoyable or useful;
● we may not be able to provide you with information on our Services;
● delays in processing your request(s) may occur.
10. Notifiable data breach
In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions in Part IIIC of the Privacy Act or any other subsequent sections or legislation which supersede this Part IIIC, we will follow our relevant notifiable data breach procedures in compliance with the Privacy Act and relevant laws.
11. Updates
This Privacy Policy is subject to occasional revision and we reserve the right, at our sole discretion, to modify or replace any part of this Privacy Policy. It is your responsibility to check this Privacy Policy periodically for changes. Continued use of our Platform or Services shall indicate your acknowledgement of that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications. We may amend this Privacy Policy from time to time. Not all changes to our Privacy Policy will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.
12. Enquiries, requests & complaints
Enquiries regarding this Privacy Policy or the personal information we may hold on you, should be addressed with the Privacy Officer, whose contact details are below.
If you think your personal information, held by us, may have been compromised in any way or you have any other Privacy related complaints or issues, you should also raise the matter with the Privacy Officer.
We will ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances.
If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission, whose contact details are below.
Office of the Australian information Commission
Telephone 1300 363 992
Email enquiries@oaic.gov.au
Office Address Level 3, 175 Pitt Street, Sydney NSW 2000
Postal Address GPO Box 5218, Sydney NSW 2001
Platform www.oaic.gov.au
Contacting us
Entity DigitalPaths Pty Ltd ACN 652 747 512
Contact Details Please see contact details at the bottom.