Privacy Policy

Privacy Policy

Last updated: 13 February 2020

This Privacy Policy explains what information Promopeer Group Pty Ltd ACN 633 091 997 and its related entities (Promopeer) collect about you and why, what we do with that information, how we share it, and how we handle the content you provide to us as we provide you with our products and services.

1              Introduction

1.1          Scope of Privacy Policy

This Privacy Policy applies to the information that we obtain through your use of our services, via a "Device" or when you otherwise interact with Promopeer.

By using our services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

1.2          Definitions

Terms used in this Privacy Policy will have the following meaning:

(a)           Content means any information or data that you upload, submit, post, create, transmit, store or display when interacting with Promopeer.

(b)           a Device is any computer used to access our services, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.

(c)           Information means all of the different forms of data, content, and information collected by us as described in this Privacy Policy.

(d)           our services include our:

(i)            Website(s); and

(ii)           online marketplace for brandable products.

(e)           Personal Information means information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymised such that it does not allow for the ready identification of specific individuals.

(f)            Websites means any of Promopeer's websites, including but not limited to promopeer.com, and any related websites, sub-domains and pages, and any of Promopeer’s social media pages/accounts.

1.3          Changes to our Privacy Policy

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Last Updated" date at the top of this Privacy Policy and, in some cases, where appropriate we may provide you with additional notice (such as adding a statement to our Website or sending you an email notification). We encourage you to review our Privacy Policy whenever you use our services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using our services.

2              Collection of Information

2.1          Information you provide to us

We collect the following information that you provide:

(a)           Account Information: we collect information about you and your company if you register for an account with us, make purchases or otherwise use, access, or interact with our services. Information we collect may include but is not limited to your name, address, email address, phone number, job title, or credit card details.

You may provide this information directly when you place an order for our services, or in some cases another person may provide it on your behalf (most commonly when an intermediary facilitates your use of our products). If you are providing information (including Personal Information) about someone else, you confirm that you have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.

(b)           Content: we collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our services, ordering our products or accessing our Websites. Such Content includes any Personal Information or other sensitive information that you choose to include (“passively-collected Personal Information”).

(c)           Other: we collect other data that you submit to our Websites or as you participate in any features of the our services, participate in a survey, contest, promotion, sweepstakes, activity or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us. For example, information regarding a problem you are experiencing with a Promopeer service could be submitted to our Support Services or posted in any public forums. Any information, including Personal Information, that you submit to our Websites could be visible to the public unless submitted to a secure area in the Website.

 

2.2          Information we collect from your use of our services

We may collect the following information whilst you use our services:

(a)           Web Logs: As with most websites, we gather certain information and store it in log files when you interact with our Websites. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your Devices, your mobile carrier, and system configuration information.

(b)           Analytics Information: We and our analytics provider collect and store analytics information when you use our Websites to help us improve our products and services.

(c)           Information Derived from Content: Analytics information also consists of data we collect as a result of running queries against Content across our user base for the purposes of generating Usage Data. "Usage Data" is aggregated data about a group or category of services, features or users that does not contain Personal Information. Though we may happen upon sensitive or Personal Information as we compile Usage Data from Content across user instances, this is a by product of our efforts to understand broader patterns and trends. It is not a concerted effort by us to examine the Content of any particular customer.

(d)           Cookies and Other Tracking Technologies: We may use various technologies to collect information, including cookies that we save to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory. We use cookies to:

(i)            improve and customize our services and your experience;

(ii)           allow you to access and use the Websites; and

(iii)          count visits and understand which areas and features of the Websites are most popular.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Websites. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Websites or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

2.3          Information we collect from other sources

We may also obtain information from third parties and combine that with information we collect through our services. For example, we may have access to certain information from a third party credit reporting agency. Any access that we may have to such information from a third party will be handled in accordance with the procedures determined by that service and this Privacy Policy. By authorising us to connect with a third party service, you authorise us to access and store your name, email address(es), current city, and other information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.

2.4          Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

We do not anticipate collecting Sensitive Information from you. However, if such information comes into our possession, it will be used by us only:

(a)           for the primary purpose for which it was obtained

(b)           for a secondary purpose that is directly related to the primary purpose

(c)           with your consent; or

(d)           where required or authorised by law.

3              How we use Information we collect

3.1          General uses

We use the information we collect about you (including Personal Information to the extent applicable) for a variety of purposes, including to:

(a)           provide, operate, maintain, improve, and promote our services;

(b)           enable you to access and use our services (e.g. facilitate and streamline orders, take advantage of limited time promotions);

(c)           process and complete transactions, and send you related information, including purchase confirmations and invoices;

(d)           communicate with you, including responding to your comments, questions, and requests;

(e)           providing customer service and support;

(f)            providing you with information about services, features, surveys, newsletters, offers, promotions, contests and events;

(g)           providing other news or information about us and our select partners;

(h)           sending you technical notices, updates, security alerts, and support and administrative messages;

(i)            process and deliver contest or sweepstakes entries and rewards;

(j)            monitor and analyse trends, usage, and activities in connection with our services and for marketing or advertising purposes;

(k)           investigate and prevent fraudulent transactions, unauthorised access and other illegal activities;

(l)            personalize our services, including by providing content, features, or advertisements that match your interests and preferences;

(m)          enable you to communicate, collaborate, and share Content with us and our staff; and

(n)           for other purposes about which we notify you.

 

3.2          Information sharing and disclosure

We will not share or disclose any of your Personal Information with third parties except as described in this policy. We do not sell your Personal Information or Content. Circumstances where we may share or disclose your Personal Information include:

(a)           Customers and Suppliers: Our Website and online marketplace connects customers of brandable products and print services with the suppliers of those products and services.  In order to operate our marketplace, we need to share your Personal Information with the following third parties:

(i)            suppliers of brandable products and print services, if you are a customer utilising our Website and marketplace; and

(ii)           customers of brandable products and print services, if you are supplier utilising our Website and marketplace.

(b)           System Administration: you should be aware that our systems administrator may be able to access information about you and your account.

(c)           Service Providers: we work with third party service providers to provide and deliver our services, process payments, perform analysis and other services for us. These third parties may have access to or process your Information as part of providing those services for us.

(d)           Laws: we may disclose your Information (including your Personal Information) to a third party if:

(i)            we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request;

(ii)           to enforce our agreements, policies and terms of service;

(iii)          to protect the security or integrity of Promopeer's products and services;

(iv)          to protect Promopeer, our customers or the public from harm or illegal activities; or

(v)           to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

(e)           Business Transfers: we may share or transfer your information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

(f)            Anonymised Data: we may also share aggregated or anonymized information that does not directly identify you with the third parties described above.

(g)           Marketing: we may share your Personal Information with our marketing services providers so as to market our products and services to you (including direct marketing).

(h)           With Your Consent: we will share your personal information with third parties when we have your consent to do so.

4              Information we do not share

We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission.

5              Data storage, transfer and security

Promopeer hosts data with hosting service providers in numerous countries including Australia. We will make reasonable attempts to ensure that the servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any passively- collected Personal Information you choose to store in Websites are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

6              Your Choices

You may opt out of receiving promotional communications from Promopeer by emailing us to have your contact information removed from our promotional email list or registration database. Although opt-out requests are usually processed immediately, please allow ten (10) business days for a removal request to be processed. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our services.

7              Accessing and updating your information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

8              International users

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Information to us in Australia. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.

 

For any questions or notices, please contact: hello@promopeer.com