1.1 This policy sets out how Emprevo Ltd ABN 62 168 062 020 and its related entities (we, us or our) collects, uses, manages, and stores personal information in connection with the Emprevo Platform (Emprevo Platform).
1.2 In this Policy:
(a) personal information means any information or opinion about a natural person (whether or not true) which is reasonably identifiable;
(b) sensitive information means information about an individual’s race, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preference, criminal record, or health, genetic or biometric information;
(c) “you” and “your” means a user of the Emprevo Platform whose personal information we have knowingly collected.
2. The personal information we collect
2.1 The personal information that we may collect or hold will depend on the context in which we collect it, and may include:
(a) name and contact information;
(b) employment information (including company name and position);
(c) location (e.g. postal address);
(d) telephone or mobile phone numbers;
(e) email addresses and any other personal information you submit to us, as well as any other information that we consider is necessary to perform our services.
2.2 Where personal information is provided by a customer (e.g. information relating to a customer’s employee or representative), we rely on the customer to ensure that the individuals whose information is being provided have been informed about our role in collecting personal information and, where necessary, informed about this Policy.
2.3 The performance of our services may from time to time involve the temporary collection of personal information from data being analysed by our service (such as when included in data that passes through or are processed by the Emprevo Platform).
3. Purpose of collection, use and disclosure of personal information
3.1 We collect personal information in a number of ways, including:
(a) where you or your employer provide information directly to us through the Emprevo Platform or on a hardcopy form;
(b) where you submit your details to open an account with us;
(c) where you interact directly with our employees and such other persons acting for us or on our behalf, such as our customer service team, including from electronic queries sent to us;
(d) where you provide information directly to us during a recruitment process;
(e) from third parties, such as our service providers;
(f) through other customers (for example from your employer);
(g) through marketing and business development events;
(h) where you provide feedback to us;
(i) from related entities in our corporate group; and
(j) from publicly available sources of information.
3.2 We do not generally collect sensitive information about individuals. If we do collect, use or disclose sensitive information about you, we will only do so where it is reasonably necessary to conduct our business and where we have obtained your consent or where it is permitted by law.
(a) in our ability to provide you services using the Emprevo Platform;
(b) in our ability to keep you informed of company updates and services information;
(c in our ability to properly conduct our operations;
(d) in our ability to communicate messages or notifications to you or from you; and
(e) in our ability to respond to your inquiry or request.
4. How personal information is collected
4.1 We collect, use and disclose personal information for the primary purpose of conducting our business, which includes:
(a) verifying your identity;
(b) providing the services you require including access to the Emprevo Platform;
(c) managing and administering those services;
(d) monitoring network use, quality and performance;
(e) operating, maintaining, developing, testing and upgrading the Emprevo Platform;
(f) allowing users to communicate with other users to the extent enabled by the Emprevo Platform;
(g) contacting you in any way (including mail, email, phone, text, multimedia messages or notifications) about products and services offered by us;
(h) informing you of ways the services provided to you could be improved;
(i) fraud checking and quality control;
(j) researching and developing our services;
(k) responding to enquiries or requests;
(l) sending direct marketing to you (see 9 below);
(m) where you otherwise provide your consent, whether express or implied; and
(n) where otherwise required by law.
4.2 In general, the primary principle is that we will not use any personal information other than for the purpose for which it was collected, except with the individual’s permission or as otherwise permitted by law. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
4.3 In conducting our operations, we may share some of your personal information with third parties such as outsourced service providers and contractors. Unless you have agreed, these parties are not allowed to use your personal information for any other purpose except to assist in conducting our business. In particular, we may disclose your personal information to:
(a) your employer;
(b) our business partners;
(c) third party technology providers;
(d) any other third parties incidental to us carrying out our functions;
(e) other service providers or referral partners in order to provide our services to you, or to assist our functions or activities (such as law firms);
(f) where you otherwise provide your consent, whether express or implied; and
(g) where otherwise required by law.
4.4 We will retain personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
4.5 Except to the extent foreshadowed under this Policy, we will not disclose or sell an individual’s personal information to unrelated third parties under any circumstances.
5. Overseas disclosure
5.1 We will not disclose your personal information overseas. In the event that personal information must be disclosed overseas, we will endeavour to obtain consent from you.
6.1 When you access our website or the Emprevo Platform from a computer, mobile phone, or other device, we may make a record of your visit and logs for statistical and business purposes and we may collect information including: the user’s server address, the user’s domain name, IP address, the date and time of visit, the pages accessed and documents downloaded, the previous site visited, the operating system used and the type of browser used. We may also track some of the actions you take on our website or customer portal such as when you provide information or content to us.
6.2 We may use “cookies” (small pieces of data we store for an extended period of time on your computer, mobile phone, or other device) to make our website or our services easier to use. We also use them to know when you are interacting on our website. You can remove or block cookies using the settings in your browser, but in some cases that may impact your ability to use some areas on our website.
6.3 If you access our website or the Emprevo Platform from outside Australia, you accept responsibility for ensuring or confirming compliance with all laws in that jurisdiction that apply to you as a result of that access or any consequent transactions or dealings with us, the website or other users.
7. Storage and security of personal information
7.1 Where we hold your personal information, we will take reasonable steps to ensure that the information is secure and may only be accessed by authorised persons. Where we store your personal information electronically on our database, we use secure servers and there are restrictions as to who has access to that information through password protection.
7.2 Although we take all reasonable measures, we are not responsible for third party circumvention of security measures on our electronic databases or at any of our premises. Please note that third party recipients of personal information may have their own privacy policies and we are not responsible for their actions, including their handling of personal information.
7.3 We cannot control the actions of other users with whom you share your information. Further, we cannot guarantee that only authorised persons will access your personal information. Please notify us immediately if you believe there has been any unauthorised access to your information.
7.4 If any personal information that we hold is no longer required for the purpose for which it was collected and no applicable law requires us to retain that information, we will take reasonable steps to de-identify or destroy the information.
8. How to access and/or update person information
8.1 We will use reasonable steps to ensure the personal information we hold is complete, up to date and accurate, so far as it is practicable for us to do so.
8.2 You may request access to the personal information we hold about you by contacting our Privacy Officer. We may, at our discretion, provide you with access to your personal information and we reserve the right to charge you a reasonable fee for giving access.
8.3 Subject to paragraph 8.4, if personal information we hold about you is incorrect, we will, on your request to correct it or where we are satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading, take such steps as are reasonable in the circumstances to ensure that the information is corrected.
8.4 If you request us to correct personal information that we hold about you and we refuse to do so, we will, to the extent reasonable, provide you a written response as to our reasons.
9. Direct marketing
9.1 From time to time, we may use your personal information for direct marketing purposes (for an indefinite period). This includes sending you updates about new opportunities. When we contact you, it may be by mail, telephone, email or SMS. Where we use or disclose your personal information for the purpose of direct marketing, we will:
(a) allow you to ‘opt out’ or in other words, allow you to request not to receive direct marketing communications; and
(b) comply with a request by you to ‘opt-out’ of receiving further communications within a reasonable time frame.
10. Complaints and disputes
10.1 If an individual has a complaint about our handling of their personal information, they should address their complaint in writing to the details below.
10.2 The Privacy Officer will co-ordinate the investigation of any complaint and any potential resolution of a complaint. We will aim to resolve all complaints as soon as practicable for us to do so.