Legal

Privacy Policy

Effective starting May 25, 2018

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through this website (Site). In this Privacy Policy we, us or our means Elevio Pty Ltd ABN 46 609 441 116. When we collect, store and use your personal information, we do so in accordance with the rules set down in the Australian Privacy Act 1988 (Cth) and, to the extent applicable, by the European Union General Data Protection Regulation (EU) 2016/279 (the GDPR).

Personal information

Personal information: The types of personal information or personal data we may collect about you include:

  • your name;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your age and/or date of birth;
  • your demographic information, such as postcode; and
  • any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access and use our services or the services of our customers, including storing it;
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes; and
  • to comply with our legal obligations and resolve any disputes that we may have.

Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
  • third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia including in in the U.S.A.

Where we disclose your personal information to third parties, including data processors, we will request or ensure that the third party handle your personal information in accordance with this Privacy Policy. The third party will only process your personal information in accordance with written instructions from us and we require that the third party either complies with the privacy shield principles set out in the GDPR or another mechanism set out by applicable EU & Swiss data protection laws for the transfer and processing of personal information. When we refer to ‘processing’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.

Please note that we use the following third parties to process your personal information: Amazon Web Services, U.S.A.

By providing us with personal information, you consent to the disclosure of your personal information to third parties who are outside Australia and, if you are a European Union (EU) citizen, to third parties that are outside the EU. Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the GDPR), you acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.

Our responsibilities as a ‘processor’ under the GDPR

Where we are a processor, we have contracts containing certain prescribed terms in our contracts with controllers, including:

  • not to use a sub-processor without the prior written authorisation of the data controller;
  • to co-operate with supervisory authorities;
  • to ensure the security of its processing;
  • to keep records of processing activities;
  • to notify any personal data breaches to the data controller; and
  • to employ a data protection officer and appoint (in writing) a representative within the European Union if required by the GDPR. (These are not required for the company at the present time).

Your rights and controlling your personal information

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Complaints: If you believe that we have breached the Australian Privacy Principles or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the Office of the Australian Information Commissioner if you wish to make a complaint.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and web beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see https://www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

For more information regarding cookies and web beacons please visit https://elev.io/legal/cookies 

Links to other websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy.  We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

For any questions or notices, please contact our Privacy Officer at:

Elevio Pty Ltd ABN 46 609 441 116

4/38 Down Street, Collingwood, Victoria, 3066, Australia

Email: privacy@elev.io

Last update: 26th April 2018