This policy was last updated 2nd April 2019.
The website www.smartcompany.com.au and SmartCompany and StartupSmart emails and newsletters are published by Private Media Pty Ltd. In this policy, “us” “we” or “our” means SmartCompany and Private Media.
Private Media takes its obligations under the Australian Privacy Principles as contained in the Act very seriously, and has implemented practices, procedures and systems to ensure we comply with those laws.
The scope of this Policy applies to new visitors and current visitors and newsletter subscribers of smartcompany.com.au website.
2 Collection of your personal information
2.1 Types of information collected
2.1.1 Identifiable information:
In the process of running the smartcompany.com.au newsletters, we collect a range of personal information about you at the time of subscribing to our newsletters. This information includes:
- Full name
- E-mail address
From time to time we have resources our website visitors can download. As part of downloading these resources we will ask you for additional personal details such as:
- Phone number
- Company Name
2.1.2 De-identified information:
The purpose of De-identified information we collect from you is for website general analytics and statistics on our daily visitors. This data is collected via browser cookies that our website will drop on your browser so it can track how readers use our site. Our de-identifiable analytics data collection is done by Google Analytics.
These cookies track data such as:
- Time on a page
- If the visitor is new or has been to smartcompany.com.au website before
- Pages visited
- If a visitor read one or more pages on smartcompany.com.au
- Website from which a user arrived to smartcompany.com.au, such as social media, google search results or a newsletter.
2.2 Why we collect this information from you
In order to provide our services to you as a newsletter subscriber, we need this information so that we can:
- Email you our newsletters that are part of your subscription with smartcompany.com.au
- Some web cookies are necessary for the successful function of the website’s platform so we can display the right content to you
2.3 How this information is collected
2.3.1 Identifiable Information
All identifiable information described above is collected via webforms on smartcompany.com.au.
2.3.2 Non-identifiable information
All non-identifiable information is collected automatically when you visit smartcompany.com.au website.
2.3.3 Unsolicited personal information
If we receive your personal information from a third party without having asked you for it, then within a reasonable time, we will determine whether we could have collected it in the ways outlined above. If we determine that it could not have been collected in one of those ways and it is legal and reasonable to do so, then as soon as practicable we will:
- destroy the information; or
- ensure that it is de-identified before storing in our systems
2.4 How this data is stored
SmartCompany website is published, hosted and managed in Australia by Private Media with web servers in Sydney. Our marketing automation tool, Pardot, is hosted in the Cloud and managed and provided by Salesforce.com Inc in the United States, also hosted in the United States.
We use strict computer and user access mechanisms to protect this data you provide in a secure way. For the purpose of protecting your data we use:
- Secure Socket Layer (ssl) on smartcompany.com.au that will encrypt your data being transmitted between the web form on the site and our servers.
- Firewalls protects smartcompany.com.au and other systems storing data 24/7
- 2 factor authentication (2FA) is used for systems storing your data so that only authorised employees have access to this.
- Daily backups that are securely stored in the Cloud are taken daily to protect any data loss as part of a system failure.
2.5 How long we keep your data for
Personal information required as part of your newsletter subscription with SmartCompany is stored for as long as the subscription is active, unless:
- you unsubscribe from our newsletters; or
- you advise us in writing to delete records relating to you.
2.6 How this data is used
In addition to the purpose of newsletter subscription with SmartCompany, we also use your information for direct marketing. Direct Marketing is the promotion of goods and services directly to you through emails.
SmartCompany will use your personal information for the purposes of direct marketing only if we have collected your personal information directly from you and we have consent from you
2.6.1 Circumstances where we need your consent for direct marketing
Unless it would be impracticable or unreasonable, we need your consent when:
- collecting your personal information from a third party for the purpose of direct marketing; or
- you would not reasonably expect to receive the direct marketing.
If at any time you want to know who provided us with your personal information, then please contact us using the contact details below at the end of this policy.
2.6.2 Opting-out of direct marketing
We will always provide a simple means for you to “opt-out” from receiving direct marketing, which typically involves an “opt-out”, “unsubscribe” or “manage subscription preferences” link on emails.
If at any time in the future you do not want us to send you direct marketing material, then you can simply inform our Privacy Officer using the contact details below at the end of this policy.
3 Sharing your information
We will only hold your personal information for the particular purpose for which we collected it and we will not use or disclose your personal information for the purposes of direct marketing material if you have previously told us not to.
We will not use or disclose your personal information for another purpose unless:
- we first obtain your consent; or
- we are required to by law,
- we reasonably believe it is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body. In this circumstance we will make a note of such disclosure.
4 Your Rights
All newsletter subscribers of smartcompany.com.au have the rights to:
- Request access to personal information that SmartCompany holds about you
- Only the person that provided the data via the means stated in point 2.3 above can request access to their own data. Access to data of others will be denied unless it is required by law enforcement.
- Request personal data to be corrected, for example you have changed jobs and which all communication to be sent to your new work email address.
When writing to us requesting a copy of your personal information we need the following details:
- Your full name
- Your email address
5 Privacy Complaints
If you have a concern or complaint relating to our handling of your personal information or any breaches of the Australian Privacy Principles, please send a written note outlining the nature of the complaint to the Privacy Officer using the contact details below at the end of this policy.
We will endeavour to respond to your complaint within 10 business days of receipt. If unresolved, the complaint may be referred to an external complaints resolution entity and finally, if necessary, taken to the Office of the Australian Information Commissioner.
6 Contact SmartCompany Privacy Officer
Privacy Officer, SmartCompany
Level 6, 22 William Street
MELBOURNE VIC 3000
Email: [email protected]