GrowthOps Limited (ACN 621 067 678)
1. WHAT IS “PERSONAL INFORMATION”?
“Personal Information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
2. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
GrowthOps collects and holds Personal Information such as your name, gender, date of birth, age, contact details (including your address, phone number and email, whether personal or for work), financial information, payment details, bank account details, national identity card number, passport number, tax file number and/or products and services information and preferences and any other data that you provide voluntarily.
3. WHY DO WE COLLECT PERSONAL INFORMATION?
GrowthOps collects Personal Information from customers, officers, employees, contractors, consultants, service providers, agents, shareholders and other individuals that is reasonably necessary for one or more of our functions or services, including in order to allow us to conduct our business functions, to market and sell our products and services, to conduct officer, employee, contractor, consultant, service provider, agent or shareholder related activities and to conduct product and market research related activities, and for such reasonable purposes as set out in Clause 6 hereinbelow.
If you choose not to provide your Personal Information to GrowthOps, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.
4. WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?
GrowthOps collects Personal Information when you: become an officer, employee, contractor, consultant, service provider or agent of GrowthOps, visit our Website, supply, use, or buy products or services, request information about us or our products or services, provide feedback, contract with us, become or apply to become a shareholder, fill in a form on our Website, fill in one of our surveys, or contact us by telephone, facsimile, email, post or in person.
By submitting your information to us, you hereby give your consent to the collection and processing of your Personal Information for the purposes set out herein. You hereby warrant and represent to us that (a) Personal Information which you disclose to us is accurate and complete; and (b) where you volunteer Personal Information of another person to us, that you are authorized by such other person to disclose such Personal Information to us, and that such Personal Information is accurate and complete.
Our Website and our related services are not intended for those under 18, and we do not knowingly collect information from those under the age of 18. Those under 18 should not submit any personal information without the permission of their parents or guardians. By using the Website and our related services, you are representing that you are at least 18 years old.
GrowthOps may also collect Personal Information about you via third parties including our suppliers, merchants, survey providers or marketers.
In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act or any other applicable data protection laws. If we retain any Personal Information we have not requested, we will treat it in accordance with this Policy.
You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.
5. INFORMATION COLLECTED VIA OUR WEBSITE
GrowthOps will not collect any Personal Information about users of our Website except when they knowingly provide it or as otherwise described below. For example, GrowthOps may collect Personal Information from users when they:
complete an online form on our Website; and/or
complete one or more of our surveys; and/or
otherwise correspond with GrowthOps.
Click Stream Data
When you visit and browse our Website, our Website host may collect Personal Information for statistical, reporting and maintenance purposes. Subject to clause 4, the Personal Information collected by our Website host will not be used to identify you. The information may include:
the number of users visiting our Website and the number of pages viewed;
the date, time and duration of a visit;
the IP address of your computer; or
the path taken through our Website.
GrowthOps’ Website host uses this information to administer and improve the performance of our Website.
In operating this Website, we may monitor the use of our Website through the use a technology called "cookies”. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns.
If you access our Website, a cookie is downloaded onto your computer’s hard drive when you first log on to our Website. You can adjust your internet browser to disable cookies, however GrowthOps may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.
If you do not accept our Cookies, you may experience some inconvenience in your use of the Website and some features may not function properly.
For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
For the Safari web browser, please visit this page from Apple: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
For any other web browser, please visit your web browser's official web pages.
Web beacons are images that originate from a third party site to track visitor activities. GrowthOps may use web beacons to collect aggregate data and provides this information to our Website host to administer and improve the performance of our Website.
6. HOW GROWTHOPS USES THE PERSONAL INFORMATION IT COLLECTS ABOUT YOU
GrowthOps uses the Personal Information it collects about you for our business functions and activities, which may include the following purposes:
to provide you with information, products or services you have requested; to promote and market our products and services to you; to personalise and customise your experiences on our Website; to help GrowthOps research the needs of its customers; to conduct research for the purposes of improving existing products or services or creating new products or services; to provide you with ongoing information about GrowthOps and its activities; to allow us to provide third party information and offers in which we believe you may be interested; to comply with regulatory or other legal requirements; for purposes related to the employment of our personnel and providing internal services to our staff; if you are a shareholder or apply to become a shareholder, to process your application, service your needs as a shareholder, provide facilities or services that you request, and administer your shareholding; and for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent. GrowthOps may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes in this clause, if we have your consent or if otherwise provided for under the applicable data law.
You are hereby informed that GrowthOps may use your Personal Information to provide you with direct, targeted, or other marketing materials on an ongoing basis. GrowthOps may provide you with these materials by telephone, electronic messages (e.g. email), our digital services and other means. GrowthOps will only provide you with direct marketing materials where you would reasonably expect us to, or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing communications may include promotional material about GrowthOps or may relate to the products and services of GrowthOps, and our related entities, provide and other products and services which may be of interest to you.
You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 13. Generally, we will only collect and use your Personal Information in accordance with this Policy. In the event that we collect or use Personal Information in ways other than as stated in this Policy, we will ensure that we do so in accordance with the Privacy Act or any applicable data protection laws.
7. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
Depending on the nature of your engagement with GrowthOps, we may disclose your Personal Information to shareholders, officers, employees, contractors, consultants, agents of GrowthOps, third parties that provide products and services to or through GrowthOps or our Website, directly to you (at your request), suppliers and other third parties, or otherwise as required by law.
GrowthOps may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.
8. TRANSFER OR DISCLOSURE OF YOUR PERSONAL INFORMATION OVERSEAS
Your Personal Information may be disclosed outside of your country to a GO entity in a foreign country, including entities in which GrowthOps has an ownership interest or to a service provider in the business of providing data storage and processing services (which commonly involve diverse geographic locations which change from time to time, which means it is not practical for us to notify you of which country your Personal Information may be located in). It is possible that entities with whom we share your information outside your country may be subject to foreign laws that do not provide the same level of protection of Personal Information as in your country. We will however ensure that any party to whom we transfer your Personal Information outside your country provides to such personal data a standard of protection at least comparable to the protection under the data protection laws of your country.
By providing your Personal Information, you acknowledge that you understand the risks associated with the disclosure of your Personal Information overseas and expressly consent to the disclosure of your Personal Information to an overseas entity.
9. STORAGE AND SECURITY OF PERSONAL INFORMATION HELD BY GROWTHOPS
GrowthOps views the protection of privacy as a serious matter. GrowthOps will take reasonable steps by implementing generally accepted standards of technology and operational security to protect your Personal Information from misuse, interference and loss and from unauthorised access, modification or disclosure.
GrowthOps aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act (or any other applicable data protection laws) in relation to any Personal Information that we handle, including information which is held on GrowthOps’ computer systems. Personal Information that is held by GrowthOps in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Policy. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website or that hackers or unauthorised personnel will not gain access to your Personal Information despite our efforts. You should note that in using the Website and our related services, this information will travel through third party infrastructures which are not under our control. Hence, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control and you acknowledge that any transmission of data to our Website is done at your own risk.
All GrowthOps personnel follow a strict internal security policy. Only authorised GrowthOps personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.
10. HOW LONG WILL GROWTHOPS KEEP YOUR PERSONAL INFORMATION?
We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by any applicable law.
Where we no longer need to keep your Personal Information, we will take reasonable steps to destroy or de-identify your Personal Information. If you wish to have your Personal Information destroyed or de-identified, please let us know by contacting GrowthOps in any of the ways specified in clause 13 and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).
11. UPDATING AND CORRECTING YOUR PERSONAL INFORMATION
We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up- to-date and complete. You have a right to request your Personal Information to be corrected. You can update your Personal Information at any time by contacting GrowthOps in any of the ways specified in clause 13. GrowthOps welcomes any changes to your Personal Information so as to keep our records up to date.
12. FINDING OUT WHAT PERSONAL INFORMATION GROWTHOPS HOLDS ABOUT YOU
You are entitled to access Personal Information that GrowthOps holds about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted at law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal. Subject to the provisions of the applicable data protection laws, we may charge for a request for access. In the event a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
A request for access can be made by contacting GrowthOps in any of the ways specified in clause 13.
13. HOW TO CONTACT OUR DATA PROTECTION OFFICER
If you have concerns, comments, further queries, problems, complaints or communication in relation to this Policy, please contact our Data Protection Officer in any of the following ways:
Write to: GrowthOps Limited Level 11, 31 Queen Street, Melbourne VIC 3000
As stated hereinabove, you may contact our Data Protection Officer for any of the following reasons:
you wish to access your own Personal Information;
you wish to update or correct your own Personal Information;
you wish to withdraw consent in respect of our collection, use or disclosure of your Personal Information; and
for any other reason listed hereinabove.
GrowthOps will review and respond to your complaint as soon as possible, generally within 30 days of receiving it. If our Data Protection Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Data Protection Officer will inform you that your complaint may be referred to the relevant Privacy or Data Commissioner for further investigation and will provide you with the Commissioner’s contact details.
14. WHAT ARE YOUR DATA PROTECTION RIGHTS
GrowthOps undertakes to respect your Personal Information and we would like to make sure that you are fully aware of all your data protection rights. You have the right under this Policy, and by law to:
Right to access. You have the right to request for copies of your Personal Information. As mentioned above, we may charge a small fee for this service.
Right to correct or rectification. You have the right to request that we correct or update any information that you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
Right to erasure. You have the right to request that we erase your Personal Information under certain conditions.
Right to restrict processing or object to processing. You have the right to object to, and/or request that we restrict, the processing of your Personal Information under certain conditions.
Right to data portability. You have the right to request that we transfer the data we have collected from you to another organisation, or directly to you, under certain conditions.
In no event will GrowthOps, its related entities, partnerships or corporations, or the partners, agents, officers or employees thereof be liable to you or anyone else for any consequential, special, punitive, indirect, incidental or similar damages, or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, even if advised of the possibility of such damages, as a result of unauthorised or unintended use, access or disclosure of your Personal Information.
Last updated: 27 October 2021