Adslot Technologies Pty Ltd ACN 123 931 804 (We, us, our) understands the importance of protecting the privacy of an individual’s personal information.
What kinds of personal information do we collect?
For the purposes of the Privacy Act, personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
We generally collect and hold the following kinds of information:
(a) contact details such as your name, address, telephone number and email address;
(b) payment details, such as bank and credit card details (as provided by you);
(c) details regarding the transactions you undertake or authorise using our websites, services and platforms; and
(d) aggregated statistical data, which is information relating to your use of our websites, services and products, including access to any online platforms available via those websites, such as traffic flow and demographics. We will not normally be able to identify you from such aggregated statistical data.
How do we collect and hold personal information?
During the provision of our services, including us providing you with access to our websites and any online platforms available via those websites, we may collect your personal information.
For example, when you register to use our websites, online platforms or other services we will generally collect personal information from you.
We will also generally collect personal information when you transact on our websites, online platforms or other services or otherwise interact with us. For example when you sell or purchase advertising inventory using our online platforms we will collect personal information (including payment information) from you so that we can process that transaction.
Wherever possible we will collect personal information directly from you.
There may however be occasions when we collect your personal information from other sources, such as from an information or data services provider or publicly maintained records.
We may also collect statistical information when you access and use our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser, including cookies and pixel tags. These features and technologies however do not specifically identify you unless you expressly provide to us personally identifiable information. You may also elect to turn off the internet browser features which allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you.
We will normally hold personal information in electronic form and may also, in some circumstances, hold personal information in hard copy.
We will take all reasonable steps to ensure that the personal information we hold is protected against misuse, loss, unauthorised access, modification or disclosure. Personal information is held by us on secure servers or in storage located in controlled, access restricted environments.
Personal information may also, in certain circumstances, be held on our behalf in electronic or hard copy forms by our service providers (such as electronic data storage providers or offsite document storage providers). We enter into agreements with such service providers which impose confidentiality and privacy obligations on the service provider.
We take steps reasonable in the circumstances to destroy or permanently de-identify any personal information held in circumstances where it is no longer required, unless the retention of the personal information is otherwise required or authorised by law.
Why do we need your personal information?
We collect, hold, use and disclose your personal information for the purposes of providing you our products and services, including access to any online platforms available on our websites or our other online services.
Where applicable, we may collect, hold and use your personal information:
- to enable you register for, access and use our websites, online platforms or services;
- to process transactions you submit using our websites, online platforms or services (such as transactions to buy or sell advertising inventory using our websites, online platforms or services);
- to administer or manage our relationship with you, including to communicate with you regarding your use of our websites or online platforms or services;
- to undertake customer surveys and analysis;
- for accounting, billing and other internal administrative purposes;
- to respond to any enquiry you submit to us from time to time;
- to identify and inform you of products and services that may be of interest to you;
- to fulfil any of our legal requirements; and
- for other purposes permitted or referred to under any terms and conditions you enter into or otherwise agree to with respect to the use of our websites, online platforms, products or services.
Generally we will only disclose your personal information to others for the purposes set out above. This may include disclosing your personal information to:
- our related companies, such as Adslot Limited (Australia), Adslot Limited (UK) and Adslot Inc (USA);
- third parties engaged to perform administrative or other services for us; and
- other service providers and business partners such as our administration, technology, auditing, mailing, printing, and professional service providers.
We may also disclose your personal information for other purposes with your consent or for any purposes if the disclosure is required or authorised by law. You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide our services to you, may not be able to process transactions involving you via our websites, online platforms and services or may be limited in the features or functions of our websites, online platforms and services we are able to provide you with access to.
In relation to the statistical information collected by us, we collect this information for the purposes of:
- tracking return visits to our websites;
- accumulating and reporting anonymous, aggregate (data collected in mass) and statistical information on website usage, use of our online platforms or the results or other outcomes achieved;
- assessing the results of the use of our websites, platforms, products or services;
- determining the web pages and features most utilized on our websites; and
- displaying online advertisements which may be of interest to you.
We may also collect, hold, use and disclose your personal information for direct marketing purposes, including to inform you of products, services or offers of us, our related companies or business partners that may be of interest to you.
This may include us disclosing your personal information to our related companies or business partners so that the related company or business partner can contact you regarding offers or information (which may include offers or information about the products or services of the related company or business partner).
We may disclose personal information to overseas recipients, for example to data storage providers located overseas or to our related bodies corporate located overseas.
While it is not practicable to list every country in which such recipients may be located, recipients of such disclosures are likely to be located in the USA and the United Kingdom.
Can you access the personal information that we hold about you?
Under the Privacy Act, you have a right to request access to and correction of your personal information that is collected and held by us.
If at any time you would like to request access to or correction of the personal information that we hold about you, or you would like more information on our approach to privacy, please contact our Privacy Compliance Officer.
To obtain access to or correction of your personal information, you may have to provide us proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected.
We will take all reasonable steps to respond to a request for access to or correction of your personal information within 30 days from your request. In less complex cases, we will try to provide information within 14 days.
If we refuse a request for access to or correction of personal information, written reasons for the refusal and details of complaint mechanisms available to you will be provided.
If providing you with access requires a detailed retrieval of your personal information, a fee may be charged for the cost of retrieval and supply of information. This fee will not exceed the cost to us of retrieving and supplying the information and we will provide you with prior notice of the likely amount of the relevant fee.
If you believe that we have not dealt with your personal information in a manner that complies with the Privacy Act or the APPs, you can make a privacy complaint to us by submitting details of your complaint to our Privacy Compliance Officer using the contact details set out below. You will generally be required to put your complaint to our Privacy Compliance Officer in writing.
Privacy complaints you make to us will:
- be taken seriously;
- be dealt with promptly;
- be dealt with in a confidential manner; and
- not affect existing obligations or the commercial arrangements between you and us.
We will commence an investigation into your complaint and inform you of the outcome of the complaint following completion of the investigation. We will respond to privacy complaints and notify you of the outcome of the complaint within a reasonable time of you submitting the complaint (which is normally no longer than 30 days).
In the event you are dissatisfied with the outcome of the complaint, you may refer your complaint to the Office of the Australian Information Commissioner.
How to contact us
For further information or enquiries regarding your personal information (including to request access to or correction of your personal information or to make a privacy complaint), please contact our Privacy Compliance Officer at:
- Email: email@example.com
- Telephone: 03 8695 9100
- Postal address: Level 2, 85 Coventry St, South Melbourne Vic 3205