PRIVACY POLICY

Apromore Holding Pty Ltd (ABN 51 635 938 760) and its related entities (collectively “Apromore”, “we”, “us” or “our”) understand that protecting your Personal Information is important. This Privacy Policy sets out our commitment to protecting the privacy of Personal Information provided to us, or collected by us, when interacting with you.

This Privacy Policy takes into account the requirements of the Australian Privacy Act 1988 (Cth). In addition to Australian laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the Personal Information of individuals located in the EU and UK.

1. When does this Privacy Policy apply?

This Privacy Policy applies to Personal Information that Apromore handles as a result of:

• You accessing or using any of our services, including our software applications and cloud products (collectively referred to herein as “Services”).
• You visiting or interacting with any of our websites and our social media pages (collectively referred to herein as “Sites”).
• You contacting our customer support team.
• You completing any webform on a Site.
• You registering and/or attending any of our virtual and in-person events including seminars, training sessions and other marketing and promotional activities.
• You (or your employer) inquiring about or engaging in a commercial transaction with us.
• You interacting with us in person, such as when you visit our offices.

We consider the protection of privacy of children very important. Our Services and our Sites are not directed at children. We do not knowingly collect Personal Information from children under the age of 18 without obtaining parental consent. If an individual is under 18 years of age, they should not use or access our Sites or Services at any time or in any manner. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information.

2. The information we collect

“Personal Information” means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

We collect and process the following types of Personal Information.  

Identity Data: We collect information such as your first name, last name, age and gender.

Contact Data: We collect your email address, telephone and physical address in order for us to contact you.

Financial Data: We collect information such as bank account details and payment card details for payments we make to you and/or payments you make to us.

Transaction Data: We collect details about payments to you from us, and from you to us including the Services you have purchased from us, or the products and services we have purchased from you.

Technical and Usage Data: When you access any of our Sites or Services, we may collect and process details such as your internet protocol (“IP”) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our Sites and Services (including through the use of Internet cookies), and communications with our Sites and Services.

Profile Data: We collect and process information about you when you register for an account to any of our Services, when you create or modify your account profile to our Services and when you set profile preferences within the Services. This information includes your username and password for our Services, job position, account profile picture, purchases or orders you have made with us, and support requests you have made.

Marketing and Communications Data: We collect information relating to your preferences in receiving marketing from us and our third parties and your communication preferences.

Professional Data: Where you are a worker of ours or applying for a role with us, we collect your professional history such as your previous positions and professional experience.

Sensitive information: Sensitive Information is a sub-set of Personal Information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. In the course of doing business with you, we may collect, or come across such sensitive information in different situations, including during the course of onboarding you as a client.

3. How we collect your Personal Information

We collect Personal Information as follows:

• when you provide it directly to us, including face-to-face, over the phone, over email, or online such as uploading or submitting information to our Services, our Sites and customer support channels;
• when you complete a form, such as subscribing for a Service, or submitting an enquiry;
• when you use any Site or Services (including from any analytics and cookie providers or marketing providers. See “Cookies” section below for more detail on the use of cookies at Apromore);
• from third parties;
• from your employmer as a result of providing the Services;
• from other users of our Services; or
• from publicly available sources.

4. Why we process Personal Information

We have set out below, in table format, a description of the purposes for which we collect, hold, use and disclose your Personal Information.

5. Our Disclosure of Personal Information to Third Parties

We may disclose Personal Information to:

• Our employees, contractors and/or related entities.
• Authorised partners who assist us in selling and providing our Services, provided such authorised partners agree to follow this Privacy Policy. This may include authorised partners that store data outside of Australia.
• Third party service providers who act as data processors under our instruction such as our IT service providers, data storage, web-hosting and server providers.
• Our marketing or advertising providers.
• Our third party event hosts, sponsors and/or presenters for one of our events you sign up to, including any webinars and trainings. We may provide your Personal Information to the respective third party who may use it to provide access to the event or to contact you for related marketing and advertising purposes.
• Our professional advisors, bankers, auditors, our insurers and insurance brokers.
• Our payment systems operators or processors.
• Our existing or potential agents or business partners.
• If we merge with, or are acquired by, another company, or sell all or a portion of our assets, your Personal Information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred.
• Courts, tribunals and regulatory authorities, in the event you fail to pay for Services we have provided to you.
• Courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.
• Third parties to collect and process data, such as analytics providers and cookies.
• Any other third parties as required or permitted by law, such as where we receive a subpoena.
  
  

6. Google Analytics

We have enabled Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device:

• Android: Open the Google Settings app on your device and select “ads” to control the settings.
• iOS devices with iOS 6 and above: Use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

To find out how Google uses data when you use third party websites or applications, please see here.

7. Disclosures outside of Australia

We may process and store Personal Information overseas, including in, the United States of America and Europe. Where we disclose your Personal Information to third parties, those third parties may also store, transfer or access Personal Information outside of Australia, including but not limited to, the United States of America, and Europe (such as Estonia, Germany, Italy and Spain). We will only disclose your Personal Information overseas in accordance with the Australian Privacy Principles.

8. Your rights and controlling your Personal Information

Your choice: Please read this Privacy Policy carefully. If you provide Personal Information to us, you understand we will collect, hold, use and disclose your Personal Information in accordance with this Privacy Policy. You do not have to provide Personal Information to us, however, if you do not, it may affect our ability to do business with you.

Information from third parties: If we receive Personal Information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the Personal Information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your Personal Information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your Personal Information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. 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 in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.

9. Storage and Security

We are committed to ensuring that the Personal Information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure Personal Information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

10. Cookies

10.1 What are Cookies?

Cookies are small text files that are stored on a computer, mobile or other device, when an individual visits a website. Cookies are used to allow websites and applications to perform essential functions, to work more efficiently and to assist in managing customized settings (eg. a user’s preferred language) by remembering certain information about an individual, either for a single visit (using a “session cookie”) or for repeat visits (using a “persistent cookie”). The information collected from the use of cookies may include Internet Protocol (IP) addresses, browser types, device types, the pages visited on a website and on third-party websites.

10.2 Why we use Cookies?

We may use Cookies and other technologies such as “web beacons” or “pixels” on our Sites, Services and email messages we send. We use these technologies to:

• Ensure our Sites and Services are operating properly by enabling essential functions that allow a website visitor to navigate around a website, to login to secure areas of a website, to use website features and to store preferences set by a website visitor such as their preferred language (“Necessary Cookies”).
• Measure and analyse website traffic and interactions with our Site content, online advertisements or email messages (“Performance Cookies”). This includes information such as where the website visitor has come from (eg. search engines, referring domains), pages viewed, how many times a visitor has been on a website and website performance such as any errors or issues encountered by the visitor. Performance Cookies help us optimise our Sites and Services and enhance user experience by allowing us to identify errors and to understand content popularity.
• Enable customised user experience by displaying content that is relevant to the website visitor and their interests based on their interaction with our Sites, other websites and our marketing campaigns (“Targeting Cookies”). Targeting Cookies collect any type of browsing information necessary to create profiles and to understand user habits in order to develop an individual and specific advertising routine.
• Enable additional functionalities and features on our Sites and Services and to support Site and Service performance (“Functional Cookies”). Functional Cookies may be set by us or by our third party services providers to support features such as live web chat, optional security parameters like single sign-on (SSO) and publishing comments on a Site.
• Enable us to send content via email messages to individuals in a format that can be read and to allow us to determine whether an email was opened. This information may be used by us to reduce or eliminate the number and types of email messages we send to you.

You can find more information about the individual cookies we use and the purposes for which we use them by clicking the “Cookie Settings" Button below.

Cookie Settings

10.3 Cookies Settings

If you wish to review and/or change your Cookie settings for this website, please click on the “Cookie Settings” button below. You can always update these settings by returning to this page.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of a Site or Service.

11. Links to other websites

Our website may contain links to other party websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any Personal Information which you provide whilst visiting those websites. This Privacy Policy does not apply to these outside websites or locations, or to any information that is collected after an individual clicks on such links to these outside websites

12. Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

13. Contact Us

For any questions or notices, please contact us at privacy@apromore.com.

APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their Personal Information. Personal Information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the Personal Information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What Personal Information is relevant?

This Appendix applies to the Personal Information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal basis for processing

We collect and process Personal Information about you only where we have legal basis for doing so under applicable laws. We have set out below, in a table format, a description of the ways we plan to use your Personal Information, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. We note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean we can no longer do business with us. Further information about your rights is available below.

Data Transfers

The privacy protections available in the countries to which we send data for the purposes listed above may be less comprehensive than what is offered in the country in which you initially provided the information. Where we transfer your Personal Information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred Personal Information in accordance with this Privacy Policy and Appendix 1. This includes:

• only transferring your Personal Information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for Personal Information; or
• including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the Personal Information that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your Personal Information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your Personal Information to a third party and, in some circumstances, to have Personal Information relating to you transferred to you or another organisation.

If you are not happy with how we are processing your Personal Information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.