Effective Date December 2020
Upside.Digital Pty Ltd
ACN: 139 669 248
ABN: 65 139 669 248
Our Commitment to Protecting your Privacy
Upside.Digital Pty Ltd respects your privacy and is committed to protecting it.
We will treat your personal information in accordance with our obligations under the Australian Privacy Principles (APPs), the Privacy Act 1988 (Cth) and related Australia laws. We refer to these collectively as “the Privacy Law”.
“Personal information” has a specific meaning set out in the Privacy Law, but includes any information we hold which is about you or is reasonably identifiable as being about you.
What Type of Personal Information Do We Collect?
We only collect personal information where necessary and relevant so that we can provide you with access to information or other services. This may include, for example, when you request to receive further information from an advertiser.
The extent and type of personal information collected will vary depending on how you interact with us, but will usually include:
- data about you, your interests, and products/services you select to receive communications about;
- contact details such as your name, address, phone number and email address;
- other information such as your year of birth, gender, family size including children and pets, your type of mobile phone, personal income, employment situation, online shopping habits and personal interests.
How Do We Collect Your Personal Information?
How Do We Use Your Personal Information?
We use and disclose personal information to fulfil the purpose for which it is collected or else for related purposes. This includes, for example, providing you with information, updates and services.
We may make you aware of new and additional products, services and opportunities available to you. We may also use your personal information to improve our products and services and better understand your needs.
We may contact you by a variety of measures including, but not limited to telephone, email, SMS (text message) or mail.
We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Upside.digital Pty Ltd, http://UpsideDigital.com.au, our customers or third parties.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
If we need to disclose your personal information to an overseas recipient such as an advertiser or data warehouse who is not in Australia, we will take reasonable steps to ensure that the recipient adheres to the Privacy Law in relation to your personal information.
We may also provide your information directly to third-party service providers for the purposes of servicing your requests or enquiries. These providers have their own obligations under the Privacy Law and will have their own privacy policies. Your interactions with those providers will be governed by those separate policies, and by using our Services you are consenting to the disclosure of your personal information on that basis.
How Do We Hold and Disclose Your Personal Information?
We hold your personal information on secure servers located in Australia and the United States.
How Do We Keep Information Secure?
We are committed to ensuring the security of the information we hold about you. We will always try to ensure that we take all reasonable steps to protect your information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
If we no longer need any information, we will take reasonable steps to destroy and/or de-identify the information, unless this is required to be retained to comply with any of our legal requirements.
We have no control over information that may be transmitted over the internet, so therefore cannot guarantee its safety whilst in transit.
What Happens if There is a Data Breach?
If a suspected data breach occurs, we will determine the extent of the breach. A data breach may occur if your personal information is lost or subjected to unauthorised access or disclosure.
If we believe that the suspected data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as soon as practicable and as required by the Privacy Law. This notification will set out a description of the data breach, the kinds of information concerned, and recommendations about the steps you should take in response to the data breach.
What Additional Data Do We Collect via Our Websites?
When you come to our websites (e.g. http://UpsideDigital.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.
This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
Our web server will also collect the following information:
- Your Internet service provider’s address;
- The number of users who visit the website;
- The date and time of each visit;
- The pages accessed;
Data collected from our websites remain the property of Upside.digital Pty Ltd.
A cookie is a small piece of computer code which remains on your computer and contains information which helps us identify your browser and previous information viewed in relation to our services. When you visit our websites, the cookie records certain details including the date, time and advertising content. None of the information in the cookie contains personally identifiable information about you.
By using our websites you consent to us sharing a hashed, anonymous, readable version of your email with our partner Service Providers who will drop a cookie on your browser for the purpose of improving the relevance of online advertising and content by third parties that are unaffiliated with our websites.
Third party sites
Our websites may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our websites, to read the privacy statements of each and every website that collects personal identifiable information.
How do you contact Us to Amend, Delete, Unsubscribe or Access Your Personal Information?
We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date.
Under the Privacy Law, you have the right to obtain access to any personal information which we hold about you, and to advise of any inaccuracy, if it is out of date, incomplete, irrelevant or misleading. There are some exceptions to this right set out in the Privacy Law.
If you want to correct data about you as you believe the data we hold is incorrect or you want to request the deletion of your personal information from our database or you simply require access to any personal information that we hold about you, then you should inform us and we will make every reasonable efforts to provide it and, if required, correct it.
If you would like to unsubscribe at any time you may simply click the hyperlink located at the bottom of all our branded mailings.
Any enquiries or requests should be in writing to: Privacy Officer, Upside.Digital, Level 5, 501/22 Central Avenue, Manly, NSW, 2095, Australia.