- using our services and products comprising of brand management and/or analytics tools, including BrandVantage, including, but not limited to, MongoFramework, Infinity Crawler, sitemap tools or robot exclusion tools (Services and Products);
- accessing, requesting information on, enquiring about, using, receiving or providing feedback in relation to, Turner Software's operations or Services and Products (online, in writing, by telephone or in person); or
- otherwise providing, or consenting to the collection of, Personal Information by Turner Software, its officers, agents or employees,
after this Policy has been brought to your attention, you acknowledge and consent to the use, collection, storage or disclosure of your Personal Information by us in accordance with this Policy and the Privacy Act.
If you do not agree to us handling your Personal Information in the manner set out in this Policy we will not be able to provide our Services to you and you should not provide us with any personal information.
Our Data Breach Policy forms part of this Policy and sets out our approach to any data breach.
What is Personal Information?
We follow the definition of Personal Information given in the Privacy Act:
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
What kinds of Personal Information might we collect and hold?
The Personal Information we may collect, hold and process about you depends upon how you interact with us. This information may vary depending on the specific needs of Turner Software, however, it may include your:
- name, address, email address, telephone number and identification information;
- requests and information you input into our website to access our Services and Products;
- information about people you interact with online, including via social media;
- demographic information such as age or date of birth, location and activities;
- business relationship and history with us;
- business or associated companies or entities;
- messages, emails, voicemail and other correspondence and frequency of enquiries;
- comments and feedback and responses to surveys;
- interaction with websites, including our website;
- information about how you use our website;
- what computer configurations and software you use;
- your IP address and/or other device identifying data;
- general preferences and interests;
- billing and credit card information;
- other information required to provide a service or information you have requested from us;
- information collected by Cookies, Web Beacons and other technologies; and
- any additional information relating to you that you provide to us directly.
How do we collect Personal Information
We collect Personal Information:
- directly from you (when you provide that information to us, we contact you, when you contact us, when you use our services, when you engage with us or when we engage with you);
- when conducting and/or providing our Services and Products;
- when you participate in our marketing activities;
- from third parties who you have authorised to provide us with information; and
- from publicly available sources such as the internet and social media.
How do we hold and secure your Personal Information?
We store your Personal Information digitally (unless legally required to retain in hard copy format). All hard copy material is secured onsite at Turner Software’s premises. All digital material is secured using password protected computers and databases. Any digital transfer of Personal Information is via secure channels like HTTPS where possible and user passwords are encrypted using a one-way hash. All confidential documents are securely shredded after storage is no longer necessary.
Turner Software primarily uses data storage providers located inside Australia. However some data may potentially be stored overseas, most likely the United States, due to the use of third party services from businesses that originate in the United States. Where appropriate, Turner Software has agreements with its storage providers to keep all Personal Information they store secure, using reasonable and appropriate security methods.
We conduct regular audits of our compliance with this Policy and the Act to ensure that our privacy framework is in line with industry best-practice.
Why do we collect, hold, use and disclose Personal Information?
Turner Software may collect Personal Information for a number of reasons, including:
- verifying your identity;
- displaying aggregated data in a centralised location;
- providing you or a third party with our Services and Products;
- providing you with information about our Services and Products;
- sending communications you request or contacting you and responding to your enquiries;
- providing third parties with information about you and your activities;
- communicating with you and providing you with information about your account with us and our Services and Products;
- ensuring consistency of service across our business and other internal business purposes;
- developing or refining our Services and Products;
- notifying you about changes to our website or Services and Products we offer or provide via our website;
- internal business purposes;
- providing you with marketing material;
- contacting you in relation to our business activities;
- tailoring our Services and Products;
- publishing testimonials you provide us; and
- corporate governance, auditing and record keeping.
Our use of Personal Information may extend beyond these uses, but will be restricted to purposes that we consider to be related to our functions and activities.
What do we do with your Personal Information?
If we collect Personal Information, we may:
- use that information for the purposes stated in this Policy;
- store that information in accordance with this Policy;
- pass that information amongst entities we work with;
- pass that information to third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, and other service providers);
- provide that information to third parties as required or allowed by law.
Do you use my information for Direct Marketing?
We may use your Personal Information to communicate directly with you to promote our Services and products. We use direct marketing to provide you with information about our Services and Products that we believe you may be interested in. If you receive direct marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods stated in this Policy, asking to be removed from all future direct marketing programs. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable.
What about Cookies, pixels and analytics?
When you access our website, and/or use our Services and Products, we may receive information about you via automated methods, including (but not limited to) use of a ‘cookie’, a ‘pixel’ or from analytics software.
These are tools that our web server may direct your traffic to, send to your computer, or embed on a website, when you visit our website. These tools help us provide Services and Products to you, and to recognise when you re-visit the website, serve you customised content and to optimize your experience. We generally don’t collect Personal Information through the use of these tools, though we may be able to access your IP address and information about what your computer technology is when using analytical software.
You may be able to change the settings of your browser so that Cookies are not accepted generally or that you are provided with options to accept or reject them as they are sent to your browser.
Do we ever send your information overseas?
Based in Australia, Turner Software is a global company. Our data may be stored in the cloud in Australia or the United States.
We may upload images and/or footage to our social media accounts from time to time. The social media accounts may be hosted on an overseas server. Where applicable, in the event that your information is sent overseas, we will use our best endeavours to ensure that any overseas supplier will keep all Personal Information secure.
Can you access your Personal Information or request it be corrected?
- You may request access to the Personal Information that we hold about you by contacting us.
- Upon receiving an access request we may request further details from you to verify your identity. We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction.
- An administrative fee may be charged to cover our costs in providing you with access to your Personal Information. This fee will be explained to you before it has been incurred.
We will respond to your access request within a reasonable period of time by:
- providing you with access to your Personal Information (including in a structured electronic format if you are a resident of the European Union);
- rejecting your access request, and providing you reasons for this rejection.
Access requests may be denied where:
- we believe your request is frivolous or vexatious;
- we are entitled to reject a request by law;
- we are unable to verify your identity; or
- you have not paid the administrative fee (if any).
- If you believe that the Personal Information that we hold is inaccurate or otherwise requires correction, you may send us a correction request by contacting us. We will review your Personal Information and respond to the request within a reasonable period of time.
What happens if you want to deal with us anonymously or using a pseudonym?
When contacting us, you can do so either anonymously or by using a pseudonym. If you do so, we may not be able to provide you with accurate or useful information, and you may not be able to access a full range of our operations and services. Further, we may not be able to investigate incidents or complaints you have made.
Does this Policy ever change?
What about the General Data Protection Regulation (GDPR)?
The GDPR is the European Union (EU) data protection law. Australian-based organisations that offer goods or services to persons in the EU or target or monitor the behaviour of persons in the EU may be required to comply with the GDPR regulatory regime.
We are an Australian based organisation providing products and services within Australia. From time to time, we may capture or collect Personal Information that passes through the EU. This might occur, for example, if a person in the EU accesses our website and we collect analytical data about them, if a person in the EU signs up for a newsletter, enquiries about our services from the EU, or if one of our customers gives us information about a person in the EU. If this occurs, we will treat the Personal Information received in accordance with this Policy.
Where data is processed or monitored in the EU, you may have additional rights, such as:
- The right to request that we delete your Personal Information (unless we require that information to comply with a legal obligation, or need it to bring or defend a legal claim); and
- The right to restrict our processing of your Personal Information (where it is inaccurate, would be unlawful to process, or where it has not been deleted due to us needing it to meet a legal obligation).
What happens if you have a question or complaint about how we have handled your Personal Information?
If you have a question or complaint, you can raise it with us by emailing [email protected]
We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious or if we are unable to verify your identity. If you aren’t satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at http://oaic.gov.au.