WOOBOARD PRIVACY POLICY AND COLLECTION NOTICE

COLLECTION NOTICE

This Collection Notice is given to you by WooBoard Pty Ltd (ABN 67 152 557 081) (a REFFIND Limited company) (WooBoard, us, we) in circumstances where we are collecting your personal information for the purposes of your access to and use of any WooBoard website, services, platform, applications and software (Services).

By providing your personal information to us, you accept this Collection Notice consent to us collecting, holding, using, processing, disclosing, retaining and protecting your personal information in accordance with our Privacy Policy, Cookie Policy, User Terms and Security Policy.

If you do not provide us with your personal information your access and use of the Services may be prevented or limited.

We note that our Privacy Policy contains information about our contact details, how you may access and correct your personal information held by us and how you may complain about a breach of your privacy.

As noted in our Privacy Policy and Security Policy, the nature of our Services means that your personal information may be disclosed and held overseas, such as by others in your WooBoard account or feed, us in Australia, and our external cloud computing infrastructure services provider detailed in our Security Policy.

PRIVACY POLICY

1. OUR COMMITMENT TO PRIVACY

We are committed to managing your personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other relevant privacy laws that apply to us (collectively, the Privacy Laws). The Privacy Laws place strict requirements on us to treat certain information collected as confidential, to store your information securely and to allow you easy access to check and correct your information.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, terms defined in the Collection Notice above will take the same meaning.

2. CONSENT

By using our Services, you agree to this Privacy Policy and consent to the collection and use of your personal information by us in accordance with this Privacy Policy.
We may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

3. HOW AND WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

At times, we collect personal information for the purpose of providing you with and permitted access for you to our Services to our you. We may use your personal information to:
• respond to requests for information and other general inquiries;
• provide you with products and Services that you have requested from us;
• manage, plan and administer our Services;
• research, develop and expand our facilities and Services;
• communicate with you about our products, activities, events and Services; and
• respond to enquires and complaints.

We collect personal information that is reasonably necessary for our business functions. We generally collect personal information directly from you – over the phone, by email, over the internet, or in person. We may also collect personal information about you from other sources, for example:

• our affiliated and related companies; and
• third-party suppliers and contractors who assist us to operate our business, such as providers of web server hosting services.

4. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

Users and prospective users
When you enquire about our services or when you become a user or account holder of WooBoard, a record is made which includes your personal information. Personal information may be collected from you when you sign up to WooBoard, or when you post on a WooBoard Feed.
The type of personal information that we may collect will typically include:

• your name;
• your email address;
• your birthdate;
• your job title; and
• any additional personal information you provide to us, or authorise us to collect, as part of your interaction with WooBoard.

Other individuals

We may collect personal information about other individuals who are not users or account holders of WooBoard. This includes individual service providers and contractors to WooBoard; and other individuals who interact with WooBoard on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with WooBoard. Generally, it would include:

• your name;
• your contact details; and
• information regarding our interactions and transactions with you.

You can always decline to give us any personal information we request, but that may mean we cannot provide you with some or all of the Services you have requested.

5. COOKIES

Please refer to our Cookie Policy.

6. ANONYMITY

Generally, it is not practicable for us to provide you with the option of dealing with us anonymously or using a pseudonym because:
• fundamental to the utility and security of our Services is use by identifiable individuals;
• we need to verify the identity of individuals authorising electronic payments to us; and
• we need to verify the identity of individuals who are nominated as authorised users, account holders and account administrators of our Services.

7. SECURITY

We understand the importance of your personal information and have appropriate procedures in place to safeguard and secure the information we collect to prevent unauthorised access or disclosure and maintain data accuracy.

We also take measures in respect of destroying or de-identifying personal information when required by Privacy Laws.

We have outlined the security measures that form part of our Services in our Security Policy.

We have also developed internal procedures in relation to responding to any data breach, or any suspected data breach, in compliance with requirements under the Australian Privacy Laws.

8. EMAIL COMMUNICATIONS

From time to time, we may use your personal information for the purpose of informing you about our Services. You may receive email notifications regarding WooBoard feed and account activity and emails regarding essential information, such as verification of your account password. Communications are limited to information related to your WooBoard feed and account. We will not send you any third-party advertising or communications.

9. USE AND DISCLOSURE OF PERSONAL INFORMATION

Disclosure to WooBoard users

Your WooBoard feed can be viewed by all users on that particular WooBoard account. Your own personal user account and settings are not public on the WooBoard feed or to other users on that WooBoard account and remain private, except they are disclosed to us and your WooBoard account administrator.

Disclosure to contractors and other service providers

We may disclose your personal information to third parties we engage in order to provide our Services, including contractors and service providers used for:
• information technology services and support;
• website server hosting;
• website maintenance/development;
• customer surveys;
• archiving; and
• mail-outs.

These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas. We use products and services maintained in various countries worldwide. We do not sell or trade your personal information to third parties for marketing purposes.

Overseas data storage

Your personal information may be stored in overseas facilities operated by us (or by third parties on our behalf). Unless we have your consent, or an exception under the the Privacy Laws applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Privacy Laws in relation to your personal information.

Other uses and disclosures

We will also disclose information to a law enforcement agency if we are requested to do so by that agency in relation to suspected unlawful activity.
We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

10. ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

You are entitled to access your personal information held by WooBoard on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that your personal information which we collect, use or disclose is accurate, complete and up-to-date. If you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Privacy Laws. If we do refuse your request, we will provide you with a reason for our decision.

11. COMPLIANCE WITH EUROPEAN UNION REGULATIONS

We have developed internal procedures and plans to provide guidance in complying with the data handling practices contained in European Union General Data Protection Regulation 2016/679.

12. PRIVACY COMPLAINTS

You may contact WooBoard at any time if you have any questions or concerns about our Privacy Policy or about the way in which your personal information has been handled.

Please contact our Privacy Officer at the contact details set out below. All enquiries or complaints will be taken seriously and handled with impartiality and discretion.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within 7 days.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within 14 days and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

At all times, we will endeavour to respond to you promptly and to offer a practical solution which is consistent with our legal obligations.

If you are not satisfied with our response to your complaint, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

Online: http://www.oaic.gov.au/privacy/making-a-privacy-complaint

13. CONTACT DETAILS

The contact details for WooBoard are:

WooBoard Privacy and Data Protection Officer
Email: support@wooboard.com

This Privacy Policy was updated in May 2018.