We will only collect and process personal information about you where we have a lawful basis to do so. Lawful basis includes consent (where you have given us consent), contract (where the information is necessary to perform an agreement between you and us) and legitimate interests (including security, compliance with applicable laws, and enabling us to administer our business).
- What is personal information
- What personal information do we collect
- What is aggregated data
- Why do we collect your personal information
- When and how do we collect your personal information
- When do we disclose your personal information
- How do we store and protect your personal information
- How long do we store personal information
- What if you don’t want us to collect your personal information
- What if you don’t want to receive further communications from us
- How can you access, correct, update and/or delete personal information we have collected
- What if we transfer your personal information out of Australia
- How to contact our Privacy Officer
- References to the European Union
What is personal information?
Personal information is defined as information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
What personal information do we collect?
We may collect personal information including (but not limited to) your name, date of birth, address, telephone number, mobile number and email address.
We will not, at any time, email you requesting financial information. If you receive a request to provide sensitive personal information (such as credit card details) in an email, do not provide this information because the request may be fraudulent. You can help us identify attempts at fraud. If anything suspicious occurs, please contact our Privacy Officer (see contact details below).
What is Aggregated Data?
Aggregated Data is information stored or produced in such a manner that the underlying information will no longer be identifiable to any specific user or customer. We may share Aggregated Data with our business partners or other third parties to help us make improvements to our services, conduct marketing and research and deliver services to our users and customers.
Why do we collect your personal information?
Generally we collect personal information from you (or about you) to allow us to:
- communicate with you about our services and your account;
- supply you with the selected services or products you request from us;
- tailor service or product offerings to suit your needs;
- manage the efficient operation of our website and services;
- monitor the number of users accessing our website;
- process payments between you and us;
- provide information to users and customers regarding their use of our website (if required);
- ensure your experience with us is a positive one; and
- notify you about new service offerings, products, promotions or upcoming events.
Personal information collected or received by us will only be used for the stated purpose for which it was provided.
When and how do we collect your personal information?
We collect most personal information directly from you when you open an account on our Website or use our services. Your consent may be express (e.g. you agree to the use of your information by ticking a box or) or implied by an action you take or do not take (i.e. because you have agreed to terms and conditions that contain information about the use or disclosure of your information).
You provide us with your information when you access our website, open an account on our platform, purchase products from us, apply to work with us, make a refund, return or other claim, deal with us on the phone, or write to us.
We may also collect information about how you use our website to help us evaluate our service and product offerings. For example, we may do this when you click on a link from our website. This information is derived from cookies that identify the computer you used to access our website or platform and collect information such as:
- your server address;
- your top level domain name (for example .com, .gov, .sg, .net, .edu, etc);
- the time and date of your visit to the website;
- the pages, documents or services you have accessed or viewed; and
- the type of browser you are using.
We may also use third-party tracking technologies, such as Mixpanel and Google Analytics, to record similar information regarding you and your activity on our website.
- analyse and track usage of our website;
- determine the popularity of certain content or services on our website;
- deliver advertising and content targeted to customer interest on our website;
- improve our website, products and services;
- track the number of users on our website; and
- for other legitimate internal business.
When do we disclose your personal information?
- for the purpose it was collected;
- if we sell all or part of our business(es) and the purchaser also requires your personal information;
- to enforce our legal rights or those of others;
- to prevent actual or potential fraud or illegal activity; or
- if we are required to do so by law.
If personal information is disclosed to a third party, we are required to take reasonable steps to ensure that third party is subject to legally enforceable obligations to protect that information which are comparable to the requirements of the Australian Privacy Principles found in the Privacy Act 1988 (CTH).
If you voluntarily provide information in discussion forums or other publicly accessible areas of our website the information can be viewed and therefore used by others. We advise you not to disclose contact information that you do not wish to have publicly available. We are not responsible for personal information you choose to submit to publicly accessible areas of our website.
How do we store and protect your personal information?
We will take reasonable steps to maintain the integrity and security of any personal information we have stored, including taking reasonable steps to prevent interference and loss, misuse, unauthorised access, copying, disposal, modification or disclosure of personal information.
Note that no information transmitted over the Internet can be guaranteed to be completely secure. While we will endeavour to protect your personal information as best as possible we cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk.
We have obligations to notify you if you are affected by an eligible data breach. We will take all reasonable precautions to take remedial action to prevent such an event. However, as we cannot guarantee that remedial action will be sufficient to prevent all instances of a breach, we will take steps to notify you of an eligible data breach as soon as practicable, or no later than 72 hours (where feasible) for citizens of the European Union, and provide recommendations as to what steps you should take to mitigate any serious loss or damage.
How long do we store your personal information?
We retain information for as long as required, allowed or we believe it to be necessary for the provision of our services to user and operation of our business but do not undertake retention obligations. We may dispose of information at our discretion without notice, subject to applicable law that specifically requires the handling or retention of information. You must keep your own separate back-up records.
What if you don’t want us to collect your personal information?
You are not obligated to provide us with your personal information. You may choose whether you purchase our products or receive communications from us. Whilst it is your choice not to provide your personal information to us this may impede our ability to provide you with our services.
When you directly visit our site, use a search engine or click a link you can set your web browser to remove or reject cookies by selecting the appropriate settings on your browser. If you wish to opt-out of having your web browsing information used for re-marketing and evaluative purposes you may download and install the Google Analytics Opt-out Browser Add-on or a similar opt-out application of your choice.
Removing or rejecting cookies may impact the availability and functionality of our website and updates to your web browser may affect the functionality of the Google Analytics Opt-out add-on or other opt-out applications.
What if you don’t want to receive further communications from us?
Should you wish to remove yourself from our contact database you may do so at any time by contacting our Privacy Officer via the contact details below.
How can you access, correct, update and/or delete personal information we have collected?
At any time you may contact our Privacy Officer (details below) and request your personal information be modified or deleted.
We will deal with all requests for access to, modification or deletion of personal information as quickly as possible, but no later than 30 calendar days from the date of your request. We will inform you as soon as we can if we believe additional time will be required to process your request and the reasons why. For example, requests for a large amount of information, or information which is not currently in use, may require further time before a response can be given.
We will provide you your personal information in a structured, commonly used, machine-readable format.
In some cases, we will refuse to give you access to personal information we hold about you. This includes, but is not limited to circumstances where giving you access would:
- be unlawful;
- reveal personal information about another individual;
- prejudice an investigation of unlawful activity;
- prejudice enforcement related activities conducted by, or on behalf of, an enforcement body;
- reveal evaluative information generated within Rubbedin Pty Ltd’s business in connection with a commercially sensitive decision-making process;
- reveal information related to a prosecution if all proceedings relating to the prosecution have not been completed;
- pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
- be contrary to the national interests of Australia.
Further, we will refuse access where your request is frivolous or vexatious, and where we reasonably believe that unlawful activity, or misconduct of a serious nature, is being or may be engaged in against Rubbedin Pty Ltd and giving access would be likely to prejudice the taking of appropriate action in relation to that matter.
If we refuse to give you access we will provide you with reasons for our refusal, unless doing so would be unreasonable in the circumstances. We will also take reasonable steps to give you access in a way that meets your needs without giving rise to the reasons of our refusal. Further, we will provide details of how you may make a complaint about our decision.
Citizens of the European Union are entitled to the right to erasure of personal information in certain circumstances, including but not limited to where the information is no longer necessary for the purpose for which it was collected, or where the EU citizen withdraws their consent and there is no other legal ground for processing their personal information. Please contact our Privacy Officer to discuss your request to remove your personal information.
If you are a citizen of the European Union you acknowledge and agree that Rubbedin Pty Ltd may exercise any of the exceptions to the right of erasure, where appropriate, including situations where the information is necessary for:
- exercising the right of freedom of expression and information;
- compliance with legal obligations;
- the performance of a task carried out in the public interest; and
- the establishment, exercise of defence of legal claims.
For further information in this respect please see Article 17 of the General Data Protection Regulation (EU).
What if we transfer your personal information out of Australia?
We may transfer personal information to locations outside of Australia and when we do we take appropriate steps to ensure that any third-parties responsible for transferring or receiving that information are bound by legally enforceable obligations to protect that information which are comparable to the Australian Privacy Principles expressed in the Privacy 1988 (Cth). We only transfer information outside of Australia when it is necessary for the performance of a service you have requested from us, performance of an agreement between you and us or the performance of a contract between us and a third-party where that contract is in your interest.
How to contact our Privacy Officer
Mail: Unit 1, 43 Neumann Road, Capalaba Qld 4157
Phone: +61 (07) 3245 3255
References to the European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.