In these Terms, ‘us’, ‘we’ and ‘our’ means Civic Ledger Pty Ltd and our related bodies corporate.
We may disclose that information to third parties that help us deliver our services (including information technology suppliers, communication suppliers and our business partners) or as required by law. If you do not provide this information, we may not be able to provide all of our services and products to you. We may also disclose your personal information to recipients that are located outside of Australia including to third party suppliers for example cloud providers located in the United States and Singapore.
how we store and use, and how you may access and correct your personal information;
how you can lodge a complaint regarding the handling of your personal information; and
how we will handle any complaint.
If you would like any further information about our privacy policies or practices, please contact us via firstname.lastname@example.org.
Accuracy, completeness and timeliness of information
The information on our website is not comprehensive and is intended to provide a summary of the subject matter covered. While we use all reasonable attempts to ensure the accuracy and completeness of the information on our website, to the extent permitted by law, including the Australian Consumer Law, we make no warranty regarding the information on this website. You should monitor any changes to the information contained on this website.
We are not liable to you or anyone else if interference with or damage to your computer systems occurs in connection with the use of this website or a linked website. You must take your own precautions to ensure that whatever you select for your use from our website is free of viruses or anything else (such as worms or Trojan horses) that may interfere with or damage the operations of your computer systems.
We may, from time to time and without notice, change or add to the website (including the Terms) or the information, products or services described in it. However, we do not undertake to keep the website updated. We are not liable to you or anyone else if errors occur in the information on the website or if that information is not up-to-date.
Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we do not endorse and are not responsible for the content on those linked websites and have no control over or rights in those linked websites.
Intellectual property rights
Unless otherwise indicated, we own or license from third parties all rights, title and interest (including copyright, designs, patents, trademarks and other intellectual property rights) in this website and in all of the material (including all text, graphics, logos, audio and software) made available on this website (Content).
Your use of this website and use of and access to any Content does not grant or transfer any rights, title or interest to you in relation to this website or the Content. However we do grant you a licence to access the website and view the Content on the terms and conditions set out in this Agreement and, where applicable, as expressly authorised by us and/or our third party licensors.
Any reproduction or redistribution of this website or the Content is prohibited and may result in civil and criminal penalties. In addition, you must not copy the Content to any other server, location or support for publication, reproduction or distribution is expressly prohibited.
All other use, copying or reproduction of this website, the Content or any part of it is prohibited, except to the extent permitted by law.
You must not do any act that we would deem to be inappropriate, is unlawful or is prohibited by any laws applicable to our website, including but not limited to:
any act that would constitute a breach of either the privacy (including uploading private or personal information without an individual’s consent) or any other of the legal rights of individuals;
using this website to defame or libel us, our employees or other individuals;
uploading files that contain viruses that may cause damage to our property or the property of other individuals;
posting or transmitting to this website any non-authorised material including, but not limited to, material that is, in our opinion, likely to cause annoyance, or which is defamatory, racist, obscene, threatening, pornographic or otherwise or which is detrimental to or in violation of our systems or a third party’s systems or network security.
If we allow you to post any information to our website, we have the right to take down this information at our sole discretion and without notice.
Warranties and disclaimers
To the maximum extent permitted by law, including the Australian Consumer Law, we make no warranties or representations about this website or the Content, including but not limited to warranties or representations that they will be complete, accurate or up-to-date, that access will be uninterrupted or error-free or free from viruses, or that this website will be secure.
We reserve the right to restrict, suspend or terminate without notice your access to this website, any Content, or any feature of this website at any time without notice and we will not be responsible for any loss, cost, damage or liability that may arise as a result.
To the maximum extent permitted by law, including the Australian Consumer Law, in no event shall we be liable for any direct and indirect loss, damage or expense – irrespective of the manner in which it occurs – which may be suffered due to your use of our website and/or the information or materials contained on it, or as a result of the inaccessibility of this website and/or the fact that certain information or materials contained on it are incorrect, incomplete or not up-to-date.
Jurisdiction and governing law
Your use of the website and these Terms are governed by the law of Victoria and you submit to the non-exclusive jurisdiction of the courts exercising jurisdiction in Victoria.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
What personal information do we collect?
We may collect the following types of personal information:
mailing or street address;
telephone number and other contact details;
age or date of birth;
credit card information;
your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
information you provide to us through customer surveys; or
any other personal information that may be required in order to facilitate your dealings with us.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
register on our website or app;
communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
interact with our sites, services, content and advertising; or
invest in our business or enquire as to a potential purchase in our business.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
to enable you to access and use our website, services or app;
to operate, protect, improve and optimise our website, services or app, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
to consider your employment application.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our service or products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).
To whom do we disclose your personal information?
our employees and related bodies corporate;
third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
professional advisers, dealers and agents;
payment systems operators (eg merchants receiving card payments);
our existing or potential agents, business partners or partners;
our sponsors or promoters of any competition that we conduct via our services;
anyone to whom our assets or businesses (or any part of them) are transferred;
specific third parties authorised by you to receive information held by us; and/or
other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Using our website and cookies
We may collect personal information about you when you use and access our website.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we only allow access on a needs basis and we do not make copies of this information other than for the purposes of providing our products and services. However, we cannot guarantee the security of your personal information.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the email addresses provided. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
We retain your information for no longer than necessary for the purpose for which it was collected. In determining how long your information will be stored, we will consider:
- the purpose(s) and use of your information both now and in the future;
- what information we need to:
- best provide you with products and services;
- manage your relationship with us;
- meet our statutory obligations;
- develop our products and services; and
- meet our customers’ and previous customers reasonable expectations.
Geographic Data Transfers
We store our data with GDPR compliant CRM vendors and Email vendors. Civic Ledger does not transfer your personal data. In all instances, we make sure our CRM vendors, Email vendors take steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
Data Subjects’ Rights within the EEA
In the EEA, data subjects have the following rights:
- to request access to your information and information related to our use and processing of your information;
- to request the correction of your information (we may seek to verify the accuracy of the personal information before rectifying it);
- in certain situations to ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
- in certain situations, you can also ask us to send the personal information you have given us to a third party.
- to ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA.
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.
This will not affect the lawfulness of our processing of your data prior to your withdrawal;
- to object to the processing of your information for certain purposes, namely:
- to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests;
- to object to us using or processing your information for direct marketing purposes.
You may also exercise your right to object to us using or processing your information for direct marketing purposes by clicking the unsubscribe link contained at the bottom of any marketing email we send to you and updating your preferences, or as a subscriber by visiting the preference centre on our website and changing your preferences.
For more information on how to object to our use of information collected from cookies and similar technologies, please see our cookies policy. You can exercise your rights by writing to us at Civic Ledger Pty Ltd, Level 26, 1 Bligh Street, Sydney NSW 2000 (For Australia region).
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Chief Executive Officer, Civic Ledger
Level 26, 1 Bligh Street, Sydney, New South Wales, 2000, Australia
Effective: 25 May 2018