This Policy describes how your Personal Information is collected, protected and used. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between you ("User", "you" or "your") and SiNAB Pty Ltd ("SiNAB”", "we", "us" or "our"). By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Agreement.
This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
The protection of your personal data (“Personal Information”) is of high importance to us. Because your Personal Information is private to you and may include data which can identify you, we take all reasonable care to ensure that your Personal Information is processed safely.
We are committed to protecting the privacy of our contacts, customers, suppliers and employees and complying with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act) as well as international privacy laws.
What Personal Information do we collect from you?
The Personal Information we collect from you includes:
Website log data when you use the Website, including your IP address, the address of the web page you visited within the Website, your browser type and settings, the date and time of your access, and how you used this Website.
Information about the device you are using to access this Website. Depending on the device you are using and its settings, this information may include the type of device, the device operating system, device settings, and unique device identifiers.
Information you voluntarily provide via contact forms, registration forms and surveys, including (first and last) name, email address, telephone number and preferences and subscriptions to our newsletters.
How is your Personal Information Collected?
You may share your Personal Information with us either voluntarily through your interaction with various features of our website https://www.sinab.net (“Website”), or through your engagement with us in relation to our products and services (“Services”). You may also share certain Personal Information involuntarily by virtue of the automatic collection of certain information while you are browsing the Website.
Automatic collection of information
When you open the Website, our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
Collection of Personal Information voluntarily provided
You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Website, you may be asked to provide certain Personal Information (for example, your name, e-mail address and details about you or your business). We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any online forms on the Website. When required, this information may include the following:
- Personal details such as name, country of residence, etc.
- Contact information such as email address, address, etc.
- Account details such as user name, unique user ID, password, etc.
- Business information such as name, address, business details, etc.
- Payment information such as credit card details, bank details, etc.
The provision of your Personal Information is optional. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website and we may not be able to provide you with any of our Services. Users who are uncertain about what information is mandatory are welcome to contact us.
What is your Personal Information used and processed for?
In order to make our Website and Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of the information we collect is collected directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources. We collect Personal Information from you for the following purposes:
- to create and manage user accounts;
- to fulfill and manage orders;
- to deliver products or services;
- to establish business partnerships;
- to improve products and services;
- to send administrative information;
- to send marketing and promotional communications;
- to respond to inquiries and offer support;
- to request user feedback;
- to improve user experience;
- to post customer testimonials;
- to deliver targeted advertising;
- to enforce terms and conditions and policies;
- to protect from abuse and malicious users;
- to respond to legal requests and prevent harm;
- to run and operate the Website and Services.
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies:
you have given your consent for one or more specific purposes (Note: this does not apply whenever the processing of Personal Information is subject to the California Consumer Privacy Act or European data protection laws);
provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which you are subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; and
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal bases that apply to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
What is the legal basis for the collection and processing of your Personal Information?
In order for us to carry out the collection and processing activities stated in this Policy, we rely on:
our legitimate interest consisting of proper communication and exchange of information between you and SiNAB;
your consent to our collection and processing of your Personal Information related to certain marketing, profiling and Services-related activities, which you can withdraw at any time without affecting the legality of our collection and processing of your Personal Information before your withdrawal.
Who are the recipients of your Personal Information?
The recipients of all or part of your Personal Information will be the personnel of SiNAB and our affiliates who are responsible for communications, marketing and delivering our Services, as well as personnel of third parties we have engaged to host and maintain our Website.
Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may contract with other companies and share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and delivery of Services available to you. We do not share Personal Information with unaffiliated third parties.
Third party service providers are not authorised to use or disclose your Personal Information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information.
These third parties are given only Personal Information they need for them to perform their designated functions, and we do not authorise them to use or disclose Personal Information for their own marketing or other business-related or other purposes.
We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of our assets, your user account and associated Personal Information will likely be among the assets transferred as part of such transition. We will notify you if such a business transition is to occur, and you will be given the option of withholding your consent to the transfer of your Personal Information.
We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Policy. You can request information relating to our affiliates at any time by contacting us.
How long do we keep your Personal Information?
We will retain and use your Personal Information for the period necessary for the purposes for which your Personal Information was collected, and to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, your Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
Cross-border transfer of Personal Information
Depending on your location, data transfers may involve transferring to and storing your Personal Information in a country other than your own.
For all Personal Information held by us:
Before transferring Personal Information to an overseas recipient, we will take all reasonable steps to ensure that the overseas recipient will handle the Personal Information in accordance with the APPs and other applicable privacy laws.
We will only disclose Personal Information held by us for the primary purpose for which it was collected
You are entitled to learn about the legal basis of information transfers to a country outside of your own or to any international organisation governed by public international law or set up by two or more countries, such as the United Nations, and about the security measures taken by us to safeguard your Personal Information under such circumstances.
In relation to cross-border transfers, you can find out more by checking the relevant sections of this Policy or contact us using the information provided in the contact section.
What are your rights related to your Personal Information?
You may exercise certain rights regarding your Personal Information processed by us. In particular, you have the right to do the following:
you have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information ;
you have the right to object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent;
you have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Information undergoing processing;
you have the right to verify the accuracy of your Personal Information and ask for it to be updated or corrected;
you have the right, under certain circumstances, to restrict the processing of your Personal Information, in which case, we will not process your Personal Information for any purpose other than storing it;
you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us;
you have the right to receive your Personal Information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
Your right to object to processing
Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
You must know, however, that should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.
Data protection rights under General Data Protection Regulation (GDPR) of the European Union
If you are a resident of the European Economic Area (EEA), we will take all reasonable steps to ensure you can exercise your data protection rights under the GDPR, including to allow you to correct, amend, delete, or limit the use of your Personal Information.
If you wish to be informed as to what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
Under the GDPR, you have the following data protection rights:
You have the right to request access to your Personal Information that we store and have the ability to access your Personal Information.
You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the Personal Information you believe is incomplete.
You have the right to request the erase your Personal Information under certain conditions of this Policy.
You have the right to object to our processing of your Personal Information.
You have the right to seek restrictions on the processing of your Personal Information. When you restrict the processing of your Personal Information, we may store it but will not process it further.
You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
You also have the right to withdraw your consent at any time where SINAB Pty Ltd relied on your consent to process your Personal Information.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
California privacy rights
In addition to the rights as explained in this Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses.
If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.
How to exercise your rights
Any requests to exercise your rights in relation to Personal Information can be directed to us through the contact details provided in this Policy. Please note that we may ask you to verify your identity before responding to such requests.
Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services.
We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).
To learn more about cookies and how to manage them, visit www.internetcookies.org.
Do Not Track Signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website.
For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.
We may display online advertisements on our Website and we may share aggregated and non-identifying information about our customers that we or our advertisers collect through your use of the Website and Services. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.
We may also permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might place cookies and otherwise track user behaviour.
We may offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the US CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
Links to other resources
The Website and Services may contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody.
However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that:
there are security and privacy limitations of the Internet which are beyond our control;
the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and
any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
In the event we become aware that the security of the Website and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.
In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.
Changes and amendments
We reserve the right to modify this Policy or its terms relating to the Website and Services from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information.
When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified.
Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the Website and Services.
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form or send an email to firstname.lastname@example.org
This document was last updated on 15 September, 2020.