1. WHO WE ARE
At Zitcha Pty Ltd ACN 656 936 597. ("Zitcha", "we", our", or "us") we recognise the importance of your privacy and understand your concerns regarding the security of the personal information which you provide to us.
2. DEFINITION OF PERSONAL INFORMATION
"Personal information" means any information relating to a natural person who can be identified, directly or indirectly, in particular reference to an identifier such as a name, an identification number or an online identifier.
3. HOW WE COLLECT PERSONAL INFORMATION
We collect certain personal information directly from you. For example, we collect personal information from you via the information you:
submit to us directly through the Website;
submit via a lead form;
provide to any other entities owned by Zitcha; and
upload directly into the media channel or client relationship management (CRM) system.
If we receive personal information that we have not requested (unsolicited information) then we will destroy or de-identify the information if it is lawful and reasonable to do so.
4. WHAT PERSONAL INFORMATION WE COLLECT AND HOLD
A. Information collected directly from you
Certain visitors to the Website choose to interact with it in ways that require us to gather personal information. The amount and type of information that we gather depend on the nature of the interaction and the services sought by the visitor.
Examples of the types of personal information that we may collect from you include your contact information, such as your name, telephone number and email address.
B. Information we collect automatically
Like most website operators, we automatically collect information from you and your devices when you access the Website. We may collect your Internet Protocol (IP) address, browser type, language preference, referring site, and the date and time of each visitor request.
Our purpose in collecting non-personally identifying information is to better understand how visitors use the Website
C. Information collected during the provision of services
Depending on the scope and nature of the services being provided, we may collect some or all of the following information:
online sales data (i.e. e-commerce transactions, not including any payment details);
offline sales data exports (i.e. a unique personal identifier such as a loyalty identification number); and
CRM data including customer and lead lists.
When visitors leave comments on the Website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string in order to help spam detection.
If you upload images to the Website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Website can download and extract any location data from images on the Website.
5. WHY WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities and as necessary to provide our services to you. We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions.
Specifically, we may collect and hold information about you in order to provide you with services available for order on our Website.
Additionally, we may use the information obtained through the Website to respond to and communicate with you about your requests, questions and comments and allow you to order our services.
If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to answer your enquiry or provide you with our services.
recognize your computer when you visit the Website;
track you as you navigate the Website;
enable the use of e-commerce capabilities;
offer and provide products, services and information to you;
display content on our Website, such as photos;
operate, evaluate and improve our business and Website usability;
personalise the Website, including targeted advertisements that may be of particular interest to you;
help diagnose technical and service problems; and
gather demographic information about our users.
We may also use your personal information for purposes which are required by law such as sharing your personal information in order to comply with legal obligations to which we are subject.
6. LAWFUL BASIS FOR PROCESSING YOUR INFORMATION
We normally collect or use information from you where we have your consent to do so, where we need the information to perform a contract with you or to provide our services or products to you upon your request, or where the processing is in our legitimate interests and not overridden by your data protection interests or rights and freedoms.
7. HOW WE PROTECT YOUR PERSONAL INFORMATION
We respect the privacy of personal information and will take reasonable steps to keep it strictly confidential.
The personal information you submit directly to us will be stored by electronic means on HubSpot. This means your personal information may be processed and stored in the EU and the US.
If you are based outside of Australia, by using our Website and accessing our services you consent to the transfer of your personal information to Australia, and the processing and use of that data in Australia.
We also have an Internal Data Breach Response Plan which will be followed in the event of a data breach.
You are encouraged to upload all other data via API integration and/or directly through the media channel or CRM.
The security of your personal information is important to us and whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we will use all reasonable efforts to prevent it.
Submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our Website whilst it is in transit over the internet and any such submission is at your own risk.
8. DIRECT MARKETING
We may use your information to offer you products and services that we think may be of interest to you, unless you have opted out of marketing communications.
We will never provide your information to third parties for marketing purposes without receiving your consent.
A. What are cookies?
If you leave a comment on our Website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal information and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article on the Website, an additional cookie will be saved in your browser. This cookie includes no personal information and simply indicates the post ID of the article you just edited. It expires after one day.
C. Disabling Cookies
You can choose if and how cookies will be accepted by configuring your preferences and options in your browser. However, if you decide not to display cookies you may not experience optimum performance of our Website.
11. LINKS TO EXTERNAL SITES
The Website and all articles published on the Website may include embedded content (for example videos, images, articles, etc.) from other websites. If you click on embedded content you will be directed to that third party's website. Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
We may use third-party web analytics services on our Website. These service providers help us analyse how users use our Website and help us improve our services.
The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use anonymized, aggregated data collected from users of our Website in connection with their own businesses, including in order to improve their products and services.
Those who engage in transactions with us are asked to provide additional information, including, as necessary, the personal and financial information required to process the transactions. In each case, we collect such information only insofar as is necessary or appropriate to fulfil the purpose of your interaction with us. You can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.
14. THIRD PARTY PAYMENT PROCESSOR
Payment of all fees must be made in accordance with the process specified on the Website. Where payments are processed using a platform operated by a third party, you must comply with the terms and conditions relating to the operation of the platform which will be notified to you separately.
15. RETENTION OF INFORMATION
We will only retain your personal information for as long as is reasonably necessary in relation to the purposes for which it was collected. We will also retain personal information to ensure compliance with any applicable statutory or regulatory obligations imposed on us in relation to the retention of records.
However, if you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our Website (if any), we also store the personal information they provide in their user profile. All users can see and edit their personal information at any time. Website administrators can also see and edit that information.
Where you have requested we stop processing your personal information for marketing purposes, we may retain a record of your request to ensure we abide by your request in the future.
16. WHAT RIGHTS YOU HAVE OVER YOUR INFORMATION
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
A. Request (i) information as to whether your personal information is retained and (ii) access to and/or duplicates of your personal information retained, including the purposes of the processing, the categories of personal information concerned, and the data recipients as well as potential retention periods.
B. Request rectification, erasure, removal or restriction of your personal information, for example, because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn.
C. Refuse to provide us with, or withdraw, your consent to processing of your personal information at any time.
D. Object, on grounds relating to your particular situation, that your personal information shall be subject to processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal information or present you our compelling legitimate grounds for an ongoing processing.
E. Object to us sending you direct marketing and profiling you for the purpose of direct marketing.
F. Object to your data being subject to any automated decision making, including profiling (decisions based on data processing by automatic means, for the purpose of assessing several personal aspects).
G. In certain circumstances receive your personal information that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from us.
H. Lodge a complaint regarding our processing of your personal information with a relevant authority in a country where you live, work, or where you believe a breach may have occurred, or take legal action in relation to any potential breach of your rights regarding the processing of your personal information.
Individuals who wish to contact Zitcha about information privacy, their personal information or a data breach enquiry can do so by contacting Zitcha at:
Email: [email protected]
Telephone: +61 03 7068 9245 (Australia)