Privacy Policy - Competition Cloud

Comps for Good – Privacy Policy

Introduction
1. We respect your right to privacy and are committed to safeguarding the privacy of the personal information of our customers and users of the Site. We adhere to the Australian Privacy Principles established by the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy (Policy) sets out how and why we collect, hold, use and disclose your personal information.
2. In this Policy:
  1. “personal information” has the same meaning given to it in the Privacy Act, which, in simple terms, means information that can be used to identify you;
  2. “Site” means:
    1. our website at www.competitioncloud.com.au;
    2. any mobile phone application operated by us and known as ‘Competition Cloud’ (and our other applications associated with the ‘Competition Cloud’ mobile phone application); and
    3. any other website and application that we own and operate; and
  3. “we”, “us”, and “our” means Comps for Good Pty Ltd (ACN 660 255 005) as trustee for the Competition Cloud Trust (ABN 35 328 704 937).
3. By accessing the Site or using our services, you consent to the terms of this Policy, including consenting to us collecting, holding, using and disclosing your personal information in accordance with this Policy, and you agree to be bound by the Policy.
What personal information we collect and hold
1. From time to time, we may receive and collect your personal information when it is entered into by, or otherwise collected from, you or third parties when using the Site. When you use the Site, we may ask you to provide certain personal information such as:
  1. your name, phone number, address and email address;
  2. other information arising from your use of the Site, including but not limited to, other online messaging addresses and social media identities.
2. We may also collect additional information from you, which might contain your personal information, when you:
  1. provide feedback;
  2. change your content or email preferences;
  3. respond to competitions, promotions and surveys;
  4. provide financial or bank account information;
  5. communicate with our customer support;
  6. enquire about, or apply for, a job with us;
  7. otherwise contact us.
3. The third parties from which we may receive and collect personal information about you include:
  1. any of our related bodies corporate;
  2. third party persons or organisations who administer, promote or offer (or any combination of the foregoing) (each such person or organisation, the Third Party Promoter) competitions, promotions and surveys that are from time to time made available on the Site (each, a Third Party Promotion);
  3. Third party online analytics providers, including but not limited to, Google and its partners.
  4. third party payment providers, including but not limited to, PayPal (Payment Providers); and
  5. publicly available sources of information.
4. We may also collect other information about you when you access and use the Site, including:
  1. your use of our products and services;
  2. information regarding your interactions with the Site, including:
    1. when you interact with a Third Party Promotion or certain activities, including surveys, promotions, competitions and other activities in relation to the Site (other than Third Party Promotions) that may be determined, administered, offered or advertised, by us (Competition Cloud Promotions) (Third Party Promotion and Competition Cloud Promotions, collectively Activities) on the Site;
  3. the location from which you access the Site; and
  4. the pages you have visited.
5. We may also collect other technical data when you access and use the Site, which may include your unique device ID, IP address, tracking codes, cookies, operating system, and the type of internet browser you are using. We may use this technical information in an aggregated manner to analyse how our users interact with the Site, so we can improve our service and seek to provide the best possible user experience.
Why we collect, hold and use your personal information
1. We collect, hold and use your personal information so we can:
  1. create and maintain a member account on the Site for you;
  2. provide our products and services to you, including the Activities;
  3. advise you of new products, services and opportunities as they become available;
  4. contact you, for example, to respond to your queries or complaints;
  5. improve our products and services, including the Activities;
  6. comply with our legal obligations;
  7. identify and assist you with your use of our services; and
  8. identify and tell you about other products or services we think may interest you; and
  9. process any enquiry or application by you about a job with us.
2. If you do not provide your personal information to us, we may not be able to provide our services or the Site to you, communicate with you or respond to your queries.
3. The Site may make third party social media features available to you. We cannot ensure the security of any personal information you choose to make public by using a social media feature, or that third parties who have access to such publicly available information will respect your privacy. We therefore take no responsibility for your use of such social media features.
Who we disclose your personal information to and why
1. We may disclose your personal information to:
  1. our related bodies corporate, employees, representatives and officers so we can provide our services and application to you;
  2. other users of the Site (for example, other members of the Site) so those users can review and comment on any feedback you may have given to an Activity;
  3. Third Party Promoters so that we can enter you into an eligible Third Party Promotion;
  4. third party organisations who we engage us to supply and deliver vouchers, prizes and other benefits in connection with your use of the Site or your participation in any Activity;
  5. our external service providers so they can perform services for us in connection with the Site, including but not limited to, Payment Providers and Google; and Facebook.
  6. our professional advisers, insurers or agents insofar as reasonably necessary for the purposes set out in this Policy or as required by law.
2. We may also disclose your personal information to other third parties in the following circumstances:
  1. if we are required or authorised to do so by law (including under the Privacy Act) including, for example, by any court order, subpoena, warrant, during the course of any legal proceeding or in response to a law enforcement agency request;
  2. if we sell or transfer our business assets to a third party; or
  3. if you have otherwise consented to the disclosure expressly or by implication.
3. We are not responsible for the privacy practices of the owners or controllers, including but not limited to Third Party Promoters, of such third party websites or applications.
How we store and hold your personal information
1. We store most personal information that we collect in computer systems and databases operated by us or our external service providers, such as third party cloud storage providers. We may store some personal information in paper files that we store securely.
2. We are committed to ensuring that all personal information we receive and collect is secure. To prevent unauthorised access, we have put suitable procedures in place to secure personal information, and protect it from misuse, interference, loss, unauthorised access, modification and disclosure.
3. These procedures include:
  1. the use of identity and access management technologies to control access to systems on which information is processed and stored;
  2. requiring all employees to comply with internal information security policies and keep information secure;
  3. requiring all employees to complete training about information security; and
  4. monitoring and regularly reviewing our practices against our own policies and against industry best practice.
4. Personal information we collect may occasionally be stored, processed in or transferred between third parties located in countries outside of Australia. These countries can include (but are not necessarily limited to) United States, India, and Philippines .
5. Although we take measures to safeguard against unauthorised disclosures of information, we cannot guarantee that any personal information we collect will not be used or disclosed in a manner inconsistent with this Policy.
Use of your personal information for marketing
1. We may use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related bodies corporate, our business partners or service providers.
2. Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication. However, if you do opt-out from our electronic marketing communications, we may not be able to provide you with our full service.
Sensitive Information
1. Sensitive information is information that relates to topics such as your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation (Sensitive Information). Depending on the nature of the Activity, we may collect Sensitive Information from you. Sensitive Information will only be collected with your prior consent and only if it is directly related to, or reasonably necessary for, the Activity that is being conducted.
2. Your decision to be involved in an Activity that requires you to give Sensitive Information is entirely at your discretion.
Anonymity
1. In limited circumstances, where lawful, and if not required for any Activity, you can deal with us anonymously or use a pseudonym, for example, by providing us with feedback on about the Site. However, in many instances, if we cannot identify you or if you do not provide us with the personal information we request, we may not be able to provide you with our services, assist you to participate in the Activity or respond to your enquiry or claim
Third party links
1. The Site may occasionally contain links to other websites or applications, which we do not own or control. These links are meant for your convenience only. Links to third party website or applications do not constitute our sponsorship, endorsement or approval of these third parties.
2. We are not responsible for the privacy practices of the owners or controllers of such third party websites or applications.
Cookies
1. We may from time to time use cookies on the Site. Cookies are very small text files which a website or application may store on your device and which contain information about your interaction with the Site. Cookies are used to identify you when you return to the Site, to improve your experience, by saving browsing information and your preferences, and showing content that is relevant to you.
2. Most devices automatically accept cookies, but you can choose to reject cookies by changing your device settings. However, this may prevent you from being able to use the full functionality of the Site.
Geo-location
1. When you visit the Site, we may use GPS technology (or other similar technology) to determine your location at the time of your visit, which allows us to display advertisements that are relevant to you. We will not share your current location with other users or partners.
Access to, correction and deletion of your personal information
1. You may access or request the correction or deletion of personal information that we hold about you.
2. While there is no charge to request access to your personal information, we may require you to pay an administrative fee to meet our reasonable costs to provide access to your personal information (such as photocopying costs or costs for time spent to collate large amounts of material). If you would like access to your personal information or believe that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us. Our contact details are set out in the ‘Our contact details’ section below.
3. We will respond to your requests to access, correct or delete your personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.
4. We may refuse your request to access or correct your personal information if we are permitted to do so under the Privacy Act.
5. You can request the deletion of your data by contacting us. Our contact details are set out in the ‘Our contact details’ section below.
Complaints about privacy
1. If you have any complaints about our privacy practices, including your request to access or correct your personal information, please contact us.
2. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
3. If you remain unsatisfied with the way we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
Our contact details
1. If you have any questions, comments, requests or concerns, please contact us by email and/or letter at the details below:

Email: privacy@competitioncloud.com.au

Letter: Attention: Privacy Officer

Ground Floor, 470 St Kilda Rd Melbourne Vic 3004, Australia

Changes to our Policy
1. We may review and update this Policy from time to time. Each updated version of this Policy will be effective immediately when it is published on the Site. You may obtain a copy of our Policy from our website or by contacting us at the contact details above. Please check back from time to time to review our Policy.

Date of last revision: 27 September 2022