Privacy Policy

SpacePAL is committed to protecting your privacy

SpacePAL Pty Ltd ABN: 70 621 227 512 (‘SpacePAL’, ‘we’, ‘us’ or ‘our’) respects your privacy. We are committed to protecting the Personal Information of all customers, users and visitors to our website (SpacePAL.com.au), mobile application (SpacePAL App) or any other service, software or platform we manage (collectively, our ‘Platform’). We are also committed to protecting the Personal Information of all individuals we interact with in the conduct of our business, including but not limited to our employees, prospective employees, business contacts, third-party service providers and employees of third-party service providers.

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Overview
What Personal Information we collect
How we collect Personal Information
How we use Personal Information
How we store and protect Personal Information
How we disclose Personal Information
Cookies
Google Analytics
Links to external websites
Marketing communications
Accessing, correcting and updating Personal Information
Complaints
Contact
Updates to this Privacy Policy

Overview
This Privacy Policy sets out the basis on which we collect, use, store and disclose your Personal Information and sets out your rights to access the Personal Information we collect and store about you, and how you can contact us about our privacy practices.

By ‘Personal Information’ we mean information or an opinion about an identified individual, or an individual who is reasonably identifiable, as defined in the Privacy Act 1988 (Cth) (‘Privacy Act’).

This Privacy Policy supports the Australian Privacy Principles contained in the Privacy Act. It outlines our approach to privacy and how we endeavour to safeguard your Personal Information. This Privacy Policy applies when you visit, browse, access, sign up for or use the products, services, features, technologies or functions offered on our Platform, and in relation to Personal Information we may otherwise collect when you interact with us in the conduct of our business.

By visiting, browsing, accessing, signing up for or using the products, services, features, technologies or functions offered on our Platform, or when you otherwise interact with us in the conduct of our business, you indicate that you have read, understood and accept this Privacy Policy and you agree to abide by it.

You also consent to the collection, use, storage and disclosure of your Personal Information as detailed in this Privacy Policy. You do not have to consent to SpacePAL collecting, using, storing and disclosing your Personal Information, however if you do not do so, or if your Personal Information cannot be verified, we may not be able to provide you with the products, services, benefits or features you have requested, engage or do business with you, or provide you with a personalised experience on our Platform. We will notify you if your identity cannot be verified through the Personal Information you provide us.

This Privacy Policy is to be read in conjunction with our Terms of Use.

What Personal Information we collect
The type of Personal Information SpacePAL collects from you depends on the context in which you interact with us. Personal Information we collect may include your:
• Full name, date and place of birth, address(es), telephone number(s), electronic address(es) and other contact details;
• Business name, ABN and ACN;
• Verification of identity details such as a copy of and details contained on your driver licence, credit or debit card and other identification information or documents;
• Transaction details relating to your use of our products, services or benefits;
• Demographic information, such as your suburb or postcode;
• Account login credentials, password and details relating to your unique user identity question;
• Communications, enquiries or customer interactions with us;
• Employment and professional background such as employer, occupation, role or position, qualifications, training records, licences and tax file number; and/or
• Any other information you supply to us.

We do not collect full credit or debit card details. All online payment transactions are processed by our third-party service provider, Stripe Payments Australia Pty Ltd (‘Stripe’). Stripe collects full credit or debit card details, and we cannot retrieve these details. Credit or debit card details are masked on our Platform, except for the last four digits. By providing you with our products, services, benefits or features, you consent to Stripe processing your online payment transactions and to Stripe’s Privacy Policy. We strongly recommend you review Stripe’s privacy policy.

We may collect your sensitive information in accordance with the Privacy Act, but only if you agree to provide it to us. For example, if you apply for employment with us or you are employed with our third-party service providers, we may require you to provide us with a National Police Check.

We may collect information about your use and interaction with our Platform to safeguard you from fraudulent activities and to prevent your Personal Information from being exploited. Accordingly, we may collect technical information from your computer, mobile, tablet or other device/technology to identify any malicious, fraudulent, illegitimate or illegal activities.

On occasion, you may provide us with, and we may collect from you, Personal Information relating to a third-party, such as for drop off, collection and delivery purposes or when providing details of referees for employment purposes. In such cases, it is your responsibility to ensure those individuals are aware of, read, understand and accept this Privacy Policy.

How we collect Personal Information
SpacePAL collects Personal Information from you using lawful and fair means. Personal Information we collect from you directly includes when you:
• Visit, browse, access, sign up for or use the products, services, features, technologies or functions offered on our Platform;
• Submit your Personal Information on our Platform;
• Sign up to our marketing communications;
• Contact us by telephone, email, chat, mail or in person;
• Contact our customer support team, third-party service providers or suppliers;
• Contact us or submit your Personal Information through our social media and blog pages;
• Participate in a survey or submit feedback;
• Enter a competition or promotion;
• Interact with us, our third-party service providers or suppliers in any manner relating to the conduct of our business; and/or
• Are employed or apply for employment with us or with our third-party service provider.

We may obtain Personal Information about you from third parties, related companies, credit reporting bodies, identity verification services and publicly or commercially available sources, for the purpose of complying with applicable laws.

You may elect to give us access to Personal Information stored by third-party websites, such as social media sites. You may also allow for social media integration, such as login to your SpacePAL account using your social media login credentials. Personal Information we receive in such manner is controlled by the third-party website and varies from site to site. By linking a third-party website with your SpacePAL account, you authorise us to have access to this information and consent to the collection, use and disclosure of this Personal Information as detailed in this Privacy Policy.

We may obtain Personal Information if you participate in a competition or promotion, which is conducted by us directly or through a third-party service provider.

If you are employed or apply for employment with us or you are employed with our third-party service providers, we may obtain Personal Information about you directly or from our third-party service providers or other third parties such as recruitment agencies, employment agencies and referees. Further, we may require you to provide us with a National Police Check.

How we use Personal Information
We use Personal Information to:
• Provide you with access to relevant parts of our Platform;
• Identify customers and supply you with the products, services, benefits or features you have requested;
• Provide customer support;
• Communicate with you regarding our products, services, benefits or features you have requested;
• Contact you by telephone, email messaging, mobile messaging (SMS/MMS), mail or any other forms of contact you supply to us;
• Send push notifications on your mobile device;
• Carry out accounting, billing and administrative functions;
• Process authorised financial transactions;
• Resolve disputes and troubleshoot problems on our Platform;
• Deliver targeted marketing communications about our products and services and those of our third-party service providers, including direct marketing;
• Inform you of competitions, promotions, offers or additional benefits;
• Invite you to participate in our events or surveys;
• Conduct market research;
• Market and promote our business, products, services, benefits or features. If you submit comments on our Platform about our products and services, you consent for us to use your comments on our Platform and any other marketing collateral, in which we will identify you only by your first name;
• Notify you of service, security, privacy and other updates relating to our Platform;
• Manage, support, improve or develop our business;
• Undertake statistical and analytical functions;
• Consider you for employment at SpacePAL;
• Confirm your identity for the purposes of applicable laws and to assess your suitability for the products, services, benefits or features you have requested;
• Monitor, measure and improve satisfaction of our services and those of our third-party service providers;
• Measure activity, improve and develop our Platform;
• Facilitate the process involved in enabling a sale or merger, if SpacePAL is sold to or merges with another company;
• Conduct fraud monitoring, detection and prevention activities;
• Satisfy our legal and regulatory obligations, including with our third-party service providers and suppliers;
• Protect our lawful interests, investigate and prevent potentially illegal activities;
• Comply with applicable laws; and/or
• Pursue our legitimate business interests and as is reasonably necessary in the conduct of our business.

SpacePAL does not buy or sell Personal Information.

How we store and protect Personal Information
SpacePAL stores Personal Information in electronic form on our internal database, which is held on our online server, as well as in hard copy, physical form.

All credit or debit card details are securely stored and protected by our third-party service provider, Stripe. Stripe’s security measures can be found on their webpage Security at Stripe and the way in which Stripe stores and protects Personal Information can be found in Stripe’s Privacy Policy. We strongly recommend you review Stripe’s security measures and privacy policy.

Personal Information is subject to access controls. Our authorised administrator users have full access to Personal Information. All other SpacePAL employees, our third-party service providers and employees of our third-party service providers have restricted access to Personal Information, limited to a need-to-know basis depending on the function or job they perform and the services they provide to you.

We may combine or link Personal Information we already hold about you to other Personal Information we collect about you.

We take reasonable physical, technical and administrative safeguards to store your Personal Information safely and protect it from misuse, interference, loss, unauthorised access, modification or disclosure. Examples include: all access to our online server is encrypted in transmission by electronic security technologies such as Secure Sockets Layer (SSL) and Transport Layer Security (TLS); monitoring SpacePAL employees to their access to Personal Information; and auditing our third-party service providers and their employees to ensure their access to Personal Information is limited to a need-to-know basis depending on the function or job they perform.

Where you have registered with SpacePAL and provided us with your account login credentials, password and details relating to your unique user identity question to access certain parts of our Platform, you are responsible for keeping this Personal Information secure. You should select a strong password, avoid a generic user identity question and you should not share this information with any other party.

We retain your Personal Information if we are providing you with products, services, benefits or features you have requested. We may retain your Personal Information after we cease providing you with our products, services, benefits or features for the purposes of complying with legal, taxation, accounting and financial reporting requirements and for monitoring, detecting and preventing fraudulent or illegal activities. We retain data in line with limitation periods and obligations required by applicable laws. If your Personal Information is no longer required, we take reasonable steps to ensure it is not compromised. In such circumstances, we securely destroy or permanently de-identify your Personal Information, unless we are required to retain the information under applicable laws.

No data transmission or storage system is guaranteed as entirely secure. Irrespective of our reasonable precautions to protect your Personal Information, we cannot take responsibility or guarantee the security of any Personal Information you send to us, or receive from us. SpacePAL is not liable for any misuse, interference, loss, unauthorised access, modification or disclosure of your Personal Information. Any Personal Information you transmit to us is at your own risk.

How we disclose Personal Information
SpacePAL will only disclose Personal Information as outlined in this Privacy Policy or as otherwise notified to you at the time of collection. We may share Personal Information with:
• Our related companies, employees, third-party service providers and employees of our third-party service providers;
• Our online payment processor, Stripe. The manner in which Stripe discloses Personal Information can be found in Stripe’s Privacy Policy. We strongly recommend you review Stripe’s privacy policy;
• Our service providers, suppliers and professional advisors who assist in the conduct of our business, such as development or hosting of our Platform, storage, courier, credit reporting, fraud prevention, identity verification, marketing and promotion, market research, statistics and analytics, customer service, debt recovery, legal, accounting, auditing, business consulting or technology services;
• Referees you have nominated when applying for employment with us;
• A company intending to acquire, invest or merge with us; and/or
• Other parties where you have provided your express consent or direction.

We will disclose Personal Information to law enforcement, government authorities or other third parties, as authorised by applicable laws or in circumstances permitted by the Privacy Act. For example: in response to a subpoena, court order, or other legal obligation; where we have reasonable grounds to suspect unlawful activity or misconduct of a serious nature is being, or may be engaged in; or where we reasonably believe that disclosure is necessary to prevent fraudulent or illegal activities relating to SpacePAL’s products, services, benefits or features.

SpacePAL does not disclose Personal Information to overseas recipients.

Cookies
SpacePAL uses cookies to improve and personalise your experience on our Platform and provide you with a better service. Cookies are an industry standard and used by most websites. Cookies make our Platform more user friendly by allowing our web applications to customise their operations to you. Cookies store information about your preferences and do not personally identify you as the user.

We may use cookies to save your password so you don’t need to re-enter it each time you access our Platform. We may also use cookies to collect statistical information relating to your use of our Platform, which include: your IP address; your geolocation; the date and time you access our Platform; pages you have accessed; how you were referred to each page and time spent on each page; your carrier/operating system; and your browser type.

Most web browsers are set up to automatically accept cookies. Cookies can be managed by accessing the settings in your browser. You can set your browser to refuse cookies, unless cookies are needed to safeguard our Platform or to prevent fraudulent activities. However, if you refuse cookies you may be prevented from taking full advantage of our Platform and we may not be able to provide you with the products, services, benefits or features you have requested.

By visiting, browsing, accessing, signing up for or using the products, services, features, technologies or functions offered on our Platform and agreeing to this Privacy Policy, you consent to SpacePAL placing and storing cookies on your browser for the purposes outlined in this Privacy Policy.

Google Analytics
SpacePAL uses Google Analytics, a web analysis service, to collect, monitor and analyse information about customers, users and visitors to our Platform. Google Analytics transmits and stores our Platform’s traffic data to Google servers in the United States. Google Analytics provides us with reports which assist us in understanding our Platform’s usage and traffic. Google Analytics does not personally identify you as the user or correlate your IP address with any other data held by Google.

You can refuse the use of Google Analytics by setting your browser to disable cookies used by Google Analytics. However, if you refuse cookies used by Google Analytics, you may be prevented from taking full advantage of our Platform.

By visiting, browsing, accessing, signing up for or using the products, services, features, technologies or functions offered on our Platform and agreeing to this Privacy Policy, you consent to Google processing data about you in the manner described in Google’s Privacy Policy and for the purposes outlined in this Privacy Policy.

Links to external websites
SpacePAL’s Platform may include links to external websites. These external websites are not in our control and are not subject to this Privacy Policy or our Terms of Use. We are not responsible for Personal Information you may provide whilst visiting external websites. We strongly recommend that you make your own enquiries as to the privacy policy and terms of external websites.

Our Platform may link to social media sites. If you choose to ‘like’ or ‘share’ information from our Platform through social media sites, we strongly recommend you review the privacy policy of those sites. If you have an account with a social media site, that site may link your visits to our Platform with Personal Information.

Marketing communications
SpacePAL may send you marketing communications, including direct marketing by telephone, email messaging, push notifications on your mobile device, mobile messaging (SMS/MMS), mail or any other forms of contact you supply to us. You may opt out of receiving marketing communications by notifying us using the details in the Contact section below or by clicking the unsubscribe link in marketing communications. You can also manage your marketing preferences or disable marketing options at any time by logging into your SpacePAL account. You can further manage your push notification preferences or deactivate them using the settings feature on your mobile device.

Accessing, correcting and updating Personal Information
You can contact SpacePAL to access, correct, or update Personal Information we hold about you.

If you request access to Personal Information, we will endeavour to make it available to you within 30 days, unless giving access is unlawful or we are subject to restrictions or we are required to process your request earlier under applicable laws.

It is important your Personal Information is accurate and current. Please keep us informed if your Personal Information changes. SpacePAL will take reasonable steps to ensure Personal Information we collect, use, store and disclose is correct, up-to-date and complete.

If you request to correct or update Personal Information, we will correct, update, or, if we consider it more appropriate, note your request for amendment of Personal Information on your record.

You can access, correct or update Personal Information by using the details in the Contact section below or by logging into your account and updating details.

To access, correct or update Personal Information you must verify your identity by providing your full name, address, and answering your unique user identity question.

Complaints
If you have a complaint about the way we handle your Personal Information, you can contact us using the detaiusls in the Contact section below. We will consider your complaint and take all reasonable steps to remedy any issues. We will endeavour to respond to you within 30 days. If you are not satisfied with the outcome of your complaint, you may seek a review by contacting the Office of the Australian Information Commissioner.

Contact
If you have any questions about this Privacy Policy or the way in which we handle Personal Information, or you would like to access, correct or update your Personal Information, or if you have a complaint, please contact:
The Privacy Officer
SpacePAL Pty Ltd
PO Box 3037, Bellevue Hill, NSW 2023
privacy@spacepal.com.au

Updates to this Privacy Policy
This Privacy Policy was last updated on 27 July 2018 and replaces any other Privacy Policy published by us to date. We may revise this Privacy Policy from time to time by updating this page. You should check this page from time to time to make sure you are aware of any updates. By continuing to use our Platform, you accept this Privacy Policy, including any updates.