3SIXTY1 PRIVACY & COOKIE POLICY
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3SIXTY1 PRIVACY POLICY
Last updated 1 October 2018
Version 2.1
We at 3Sixty1 Pty Ltd (an Australian company, ACN 617 898 469) (“we”, “our”, “us” or “3Sixty1”) know privacy and data protection is important to you (“you” or “your”) and we take your privacy seriously. We deal with personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”). The APPs govern how we can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information. A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner (OAIC) at http://www.oaic.gov.au.
3Sixty1 provides data analysis and consulting services to businesses to assist them with discovering the value in their data and making use of such data to address business problems and create insights and opportunities (“Services”). When you engage us to provide the Services to you, we will enter into a Data Services Agreement (DSA) with you which governs the terms and conditions of our provision of the Services.
By visiting or using the website located at http://www.3Sixty1.com.au (the “Site”), or engaging us to provide the Services, you agree to the practices and policies set forth in this Privacy Policy, and you hereby acknowledge and consent to 3Sixty1 collecting, using, holding and disclosing your personal information in accordance with this Privacy Policy.
1. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy sets out how we manage your personal information that we collect or you provide to us when you access or use the Site. It also sets out your rights regarding your personal information.
2. WHAT INFORMATION DO WE COLLECT?
We collect the personal information that you have provided to us when you:
· communicate with us in relation to engaging our Services including during discussions relating to the DSA; and/or
· during the course of 3Sixty1 providing Services to you.
We also collect and hold personal information in accordance with the terms of the DSA and the performance of our Services.
The types of personal information we collect include contact details, including name, email address, residential address, telephone number, profile information, age, date of birth, gender, occupation, title, usernames and other contact information. Given the nature of our Services there may be other personal information that we collect or that you provide to us in respect of your employees and other individuals associated with your business including your clients and/or customers, suppliers and other third parties.
2.1 Personal information of a third party
When you engage us to provide the Services under the DSA, you may provide us with personal information. You must only provide us with personal information relating to another person (including your employees) if you have first obtained the prior written consent of that person to collect their personal information and provide it to us. As that information may be disclosed by us to an intended third party as part of the normal processes of using our Services, we are entitled to assume that you have explained to the person how we may use their information. However, we may request that you provide us with a record of the consent of individuals where you are providing us with the personal information of those individuals. We may also request that you only provide information to us in de-identified form or we may refuse to receive personal information, de-identified information and/or provide the Services to you at our absolute discretion if we are not satisfied that the consent of individuals has been obtained or recorded by you or that information has been properly de-identified.
2.2 Information collected automatically
Whenever you interact with our Site, we automatically receive and record information on our server logs from your browser, including your Internet Protocol (IP) address, “cookie” information, and the pages you requested.
Tracking technologies, cookies and web beacons.
We use cookies and web beacons to improve the functionality of our Site.
“Cookies” are small text files that we transfer to your browser or device that allow us to recognise your browser or device and tell us how and when pages in our Site are visited and by how many users. You can change the preferences on your browser or device to stop your browser or device accepting cookies, but doing so may prevent some of our Site’s features from functioning.
For more information about how we use cookies and other tracking technologies please see our Cookie Policy below.
3. E-MAIL AND OTHER COMMUNICATIONS
With your consent, we may contact you, by email or other means. For example, if you have opted in to receiving email communications from us we may send you information about us, our Services and our promotional offers. We may also communicate with you by email about your use of the Site and/or the Services.
Also, we may receive a confirmation when you open an email from us.
4. HOW DO WE USE YOUR PERSONAL INFORMATION
We use, hold and disclose your personal information so that we can provide our Services and so that we can receive and respond to your requests in relation to our Services, communicate with you in relation to our Services and as otherwise set forth in this Privacy Policy.
We may also disclose your personal information to third parties (for the purposes as described in this Section and in Section 5 below).
5. HOW DO WE DISCLOSE YOUR PERSONAL INFORMATION?
Except as set forth in this Privacy Policy, or as permitted under the DSA with you, we will always seek your consent to disclose your personal information to third parties. Such third parties may include those who are identified by you or those whom we may engage in relation to the provision of our Services (such as for maintenance services and/or database management). These third parties engaged by us have access to personal information only to perform these tasks and we will ordinarily require them not to use or disclose the personal information for any other purpose.
We may also disclose personal information to comply with legislative or regulatory requirements for example to respond to a court order or notify the OAIC about a data breach or report a matter for investigation.
We may choose to buy or sell business assets. In these types of transactions, personal information of our customers is one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or we take on investors, or if we go out of business or enter liquidation, personal information would be one of the business assets transferred to or acquired by a purchaser as result of the sale of these business assets.
Other than as specified in this Privacy Policy, no personal information will be provided to a third party without your consent. However, 3Sixty1 cannot control, and will not be liable for, any use of your personal information by any third party to whom personal information is sent with your consent or permission or as part of the normal processes of using our Services. We will not provide personal information to any third party outside Australia without your consent.
6. OVERSEAS DISCLOSURE
In order to provide you with access to the Site and to provide you with the Services, 3Sixty1 may disclose your personal information to companies associated with us who are located overseas including in USA, United Kingdom, Ireland and Germany We take reasonable steps to ensure that the recipient complies with the APPs in relation to that information.
7. IS PERSONAL INFORMATION ABOUT ME SECURE?
We take reasonable care to protect personal information that we collect and hold from misuse, loss, unauthorised access, unauthorised modification or unauthorised disclosure. We seek to protect personal information by implementing reasonable and up to date security measures as well as policies, practices and procedures to govern the protection of personal information.
8. WHAT ARE MY RIGHTS?
You can always elect not to disclose personal information to us. However, please keep in mind that we may need some personal information to allow us to communicate with you, respond to your requests and provide our Services to you, and if you choose not to provide that information, your ability to use our Site and Services may be limited.
8.1 Right to access your personal information
You have the right to access your personal information that we hold. Please contact us using the contact information in section 12 below if you would like to access to your personal information. In some circumstances we may charge a fee for providing you with your personal information, in which case we will inform you of the fee in advance of providing the information.
8.2 Request updates and corrections to your personal information
If you believe that your personal information that we hold is inaccurate or incomplete, you can contact us to request that we change, amend, update, correct or delete your personal information. If you have any questions about viewing or updating information we have on file about you, please contact us using the contact information in section 12 below.
When you request that we update or delete personal information that we hold there may be some latency in our systems and it may take some time for the changes to be reflected across all of our systems and in all of the copies of your personal information that we hold.
8.3 Opting out of communications
If you do not want to receive email or other communications from us, you can choose to opt out of receiving email correspondence from us by following the instructions to opt-out in our emails or by contacting us using the contact information in section 12 below.
9. HOW DOES 3SIXTY1 RETAIN YOUR PERSONAL INFORMATION?
We will retain your personal information only for as long as needed to provide the Services to you. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements in connection with the Services and Site.
10. EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (EU GDPR)
If you are located in the European Union (EU), the EU GDPR may apply to our processing of your personal data.
As well as the other matters covered in this Privacy Policy, the following matters in this section 10 may apply.
10.1 Data protection officer
Our data protection officer can be contacted at privacy@3sixty1.com
10.2 Lawful purpose for processing
Our processing (including collection, storage, use and disclosure) of your personal data is justified on the following lawful basis as:
the processing is necessary in order for us to perform our contract with you and/or provide our Services to you, or for us to take steps to enter into a contract with you and at your request;
the processing is necessary for us to be able to comply with our legal obligations; or
you have provided your consent to the processing of your personal data.
10.3 Rights under EU GDPR
If you are located in the EU, and if the EU GDPR applies to our processing of your personal data, you have the right to request the following:
access to your personal data that we hold;
that we correct or rectify inaccurate personal data that we hold;
that we erase all copies of your personal information that we hold;
that we restrict the way that we process your personal data; and
to receive your personal data provided to us, or request that this data be provided to another controller.
You can contact us at any time you wish to withdraw your consent to our processing of your personal information.
Please contact is if you believe the EU GDPR applies to you and you would like to exercise your rights under the EU GDPR. We will respond to your request within 30 days.
You have the right to make a complaint to data protection supervisory authorities about how we have processed your personal data. You can access a list of data protection authorities by EU member state here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
The European Data Protection Supervisor
Postal address: Rue Wiertz 60, B-1047 Brussels
Office address: Rue Montoyer 30, B-1000 Brussels
Telephone: +32 2 283 19 00
Email: edps@edps.europa.eu
Website: www.edps.europa.eu
10.4 Transfers of personal data
Where we are in receipt of personal data of EU residents, the transfer of this personal data is subject to an adequate level of data protection. These transfers are made under contracts that contain EU standard contractual clauses governing the transfer of personal data to processors established in third countries.
11. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use your personal information, we will notify you by posting an announcement on our Site or contacting you directly via email or other means. You are bound by any changes to the Privacy Policy when you use the Site after such changes have been first posted.
12. QUESTIONS OR CONCERNS
If you have any questions or concerns regarding our privacy policy or how we have handled your personal information, or if you would like to make a complaint, please contact us using the contact details in section 13 below. We will endeavour to respond to you within 30 days.
If you believe that we have not adequately dealt with your enquiry or complaint you can contact the regulator in your jurisdiction. If you would like any further information about your rights to privacy, please contact or visit the regulator in your jurisdiction:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
Web: www.oaic.gov.au
13. CONTACT US
3Sixty1 Pty Ltd
134 Buckhurst Street, South Melbourne VIC 3205
Email: privacy@3Sixty1.com.au
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3SIXTY1 COOKIE POLICY
Last updated 1 October 2018
Version 2.1
This Cookie Policy sets out how 3Sixty1Pty Ltd (an Australian company, ACN 617 898 469) (“we”, “our”, “us” or “3Sixty1”) uses cookies and other similar technologies on our website located at https:// www.3sixty1.com, our mobile applications, and any other services that we offer from time to time in connection with any of the foregoing (collectively, the “Site”).
To the extent that information collected through our use of cookies and similar technologies constitutes personal information, the provisions of our Privacy Policy apply to that information. You can access our Privacy Policy above (https://www.3sixty1.com.au/privacy-and-cookie-policy/)
We are committed to being transparent in relation to how we collect and otherwise handle your personal information.
We want our Site to be as informative, user-friendly and personal as possible. Our use of cookies and similar technologies as described in this Cookie Policy helps us achieve this goal.
Whenever you interact with our Site, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested.
When you visit our Site we will seek your consent to our use of cookies.
Cookies and types, we use
Cookies allow our Site to deliver a more personalised user experience including by enabling targeted advertising. Cookies also allow our Site to remember your settings and your preferences to enable a more user-friendly experience.
Cookies are small text files sent to your browser and stored by your browser on your computer or other device by an email that you open or the websites you visit. These cookies are anonymous, and they collect information that on its own will not identify you.
Cookies save data such as your Internet Protocol (IP) address, the geographic location associated with your IP, the date and time you visited our Site, pages or advertisements you viewed, the URL of the website you viewed prior to visiting our website and the type of browser you use.
There are several different types of cookies that may be used on our websites.
• Strictly Necessary Cookies are essential to enable navigation around our Site and use its features. Without these, we would be unable to provide you with certain features.
• Functionality Cookies allow our Site to remember choices you have made and helps to provide an enhanced, more personal experience of our Site.
• Performance Cookies help us to improve our Site and our online services. These cookies gather information about how our Website is used, including which pages you visit most often. These cookies are anonymous, which means that they won’t collect information which identifies you.
• Targeting and Advertising Cookies are used to help us better understand our advertising campaigns and how we can make these more relevant to you. These cookies will not collect information which personally identifies you.
We may also use web tracking and analytics tools on our Site to generate detailed statistics about traffic to our Site and the pages that users access.
What we use cookies for
We use cookies and similar technologies to:
• enhance your experience on our Site by remembering your preferences;
• support the functioning of our Site (including secure services for online transactions);
• track how users use our Site and interact with our advertisements;
• understand how our Site is functioning and inform us of improvements to our Site; and
• gather data that helps us deliver advertising content relevant to your interests.
When we collect usage information (such as the number and frequency of visitors to our Site and to which pages within the Site), we only use such data in aggregate form and in a manner that assures your anonymity. We may provide this aggregate usage information to our partners who may use this information to understand how often and in what ways users access and use our Site, so that our partners can endeavour to provide users with a better online experience. For example, we may place a cookie on your device or browser that records what products have been accessed on our Site by your browser or device, and then we may provide that information, in de-identified form, to a third party website, to allow that website to serve ads to your browser or device for similar products that are available from us or from third parties.
Third parties such as our advertising partners may also transmit cookies to your computer or device when you click on ads that appear on our Site (“Third Party Cookies”). This Cookie Policy does not cover Third Party Cookies.
Web beacon
We may also deliver a file to your browser or device (known as a “web beacon”) through the Site from an advertising network we have contracted with. Web beacons allow advertising networks to provide anonymised, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to your browser or device when your browser or device visits other websites. These web beacons may, for example, log that you have viewed a certain product on our Site using your browser or device, and then show you an ad for similar products when you browse to another website. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can set, view or edit their own cookies, just as if your browser or device had requested a web page from their site. Many ad networks participate in the Network Advertising Initiative (“NAI”), a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards, and such NAI members may allow you to opt-out of cookies or web beacons they deliver. Again, we do not control the policies of any third parties, including advertising networks.
We do not honour “do-not-track” signals from internet browsers or other consumer choice mechanisms regarding the collection of behavioural tracking data.
Managing cookies
You can manage cookies on your computer or device through your browser settings. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies but doing so may prevent you from taking advantage of our Site’s best features or accessing part or all of the Site.
You can delete cookies stored on your computer or change your privacy settings at any time via your browser settings. Please refer to your browser’s “help” or “support” site for more information on how to delete saved cookies and allow or block cookies.
We have no control over Third Party Cookies. If you are concerned about Third Party Cookies generated by advertisers, your browser may allow you to block Third Party Cookies. Please review your browser settings to block Third Party Cookies. If you block Third Party Cookies you may no longer receive targeted advertising.
Changes to our Cookie Policy
We may update our Cookie Policy from time to time. If we make changes to our Cookie Policy, we will notify you by posting an announcement on our Site or contacting you directly via email or other means.
Contact us
If you have any questions or concerns regarding our Cookie Policy, please contact us by email to privacy@3sixty1.com.
We will make every effort to resolve your concerns.