What is personal information?
Personal information is any information which can be used to identify you. This includes information about you as a person (such as your name, address and date of birth), your devices, payment details and information about how you use a website or online service.
What personal information do we collect?
The personal information we collect falls into the following categories:
- ‘voluntarily provided’ information that you knowingly and actively provide to us when using or participating in any of our services and promotions
- ‘automatically collected’ information sent by your devices while accessing our products and services.
When you visit our website, our servers may automatically log the standard data provided by your web browser such as your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the website, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error occurred, and other technical information relating to the problem. You may or may not receive notice of such errors.
When you visit our website or interact with our services, we may automatically collect data about your device including:
- device type
- operating system
- unique device identifiers
- device settings
- geo-location data.
The type of data we collect will depend on the individual settings of your device and software. You should check the policies of your device manufacturer or software provider to understand what information may be made available to us.
We may ask for personal information e.g. when you subscribe to services or newsletter or when you contact us, including:
- business name
- social media profiles
- date of birth
- telephone number
- mailing address.
We may collect transaction data which accumulates over the normal course of operations on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information created or generated as users interact with our services.
Why we collect personal information
We only collect and use personal information that is reasonably necessary for us to provide our services to you such as:
- to enable you to access and use our website, associated applications and associated social media platforms
- to provide you with our platform’s core features and services
- to enable you to customize or personalise your experience on our website
- to deliver products and/or services to you
- to contact and communicate with you
- for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you
- for internal record keeping and administrative purposes
- for technical assessment, including to operate and improve our app, associated applications and associated social media platforms.
How we collect personal information
- register for an account
- purchase a subscription
- sign up to receive updates from us via email or social media channels
- use a mobile device or web browser to access our content
- contact us via email, social media or on any similar technologies
- when you mention us on social media.
Disclosure of personal information to third parties
We may disclose personal information to:
- a parent, subsidiary or affiliate of our company
- third-party service providers such as IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors and payment systems operators to enable them to provide their services
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- credit reporting agencies, courts, tribunals and regulatory authorities if you fail to pay for goods or services we provide to you
- 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
- third parties, including agents or sub-contractors who assist us in providing information, products, services or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer, all or substantially all of our assets and business.
Third parties we currently engage include:
- Google Analytics https://policies.google.com/privacy
- Google Cloud: https://cloud.google.com/terms/cloud-privacy-notice
- Payrix https://www.payrix.com/wp-content/uploads/sites/2/2022/02/PAX-Privacy-Policy.pdf
- Sengrid https://www.twilio.com/legal/privacy
- Slack – https://slack.com/intl/en-au/trust/privacy/privacy-policy
- Xero – https://www.xero.com/au/legal/privacy/
Security of your personal information
When we collect and hold personal information we will use all commercially acceptable means to prevent loss, theft and unauthorised access, disclosure, copying, use or modification. Access to personal information is only provided to those employees for whose role it is necessary to have access to such information and a regular audit of employees with access to personal information is undertaken and updated as required.
Whilst we do not disclose personal information to overseas recipients, in the course of delivering our services we store personal information with trusted third party providers who may process data in centralised operations outside Australia which may include the US and Asia-Pacific regions. All personal information, when transferred, is encrypted.
When engaging third party providers we review the privacy policies governing their operations to ensure that they comply with our privacy and security requirements. A list of third party suppliers currently engaged, together with links to their privacy policies, can be found above.
Whilst we do our best to protect your personal information, no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security. As such, it is important that you select appropriate passwords to ensure the security of your personal information within the bounds of our services.
How long we keep your personal information
We keep your personal information only for as long as we need to. This will depend on, subject to the terms of this policy, what we are using your information for. E.g., if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
If necessary, we may retain your personal information to comply with legal, accounting, or reporting obligations or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
Your rights and controlling your personal information
|Marketing permission||If you have previously agreed to us using your personal information for direct marketing purposes you may change your mind at any time by contacting us on the details below|
|Access||You may request to access the personal information that we hold about you by contacting us on the details below|
|Correction||If you believe that any of your personal information that we hold is incomplete or inaccurate you may contact us on the details below. We will take reasonable steps to correct any information found to be incomplete or inaccurate|
|Non-discrimination||We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (e.g. processing transaction data) we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services if you fail to provide us with your personal information|
|Notification of data breaches||We will comply with all applicable laws in respect of any data breach|
|Unsubscribe||To unsubscribe from our email database or opt-out of communications please contact us on the details below, or opt-out using the opt-out facilities in the communication. We may need to request specific information from you to help us confirm your identity in order to action such request|
If you believe we have breached a relevant data protection law and wish to make a complaint, please contact us on 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. If you are dissatisfied with our handling of your complaint, you may also contact the Office of the Australian Information Commissioner.
If we, or our assets, are acquired, or in the unlikely event that we go out of business, our data, including your personal information, would be included in the assets transferred to any parties who acquire us. You acknowledge that such transfer may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information in accordance with this policy.
Limits of Our Policy
Changes to This Policy
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the link to the amended policy.
If required by law we will seek your permission to any new uses of your personal information, or give you the opportunity to opt in or out, as applicable.
For any questions or concerns regarding your privacy, please contact:
Hamlet Legal Team
This policy is effective as of 1 January 2019.
Last updated: 20 April 2023