Personal Information is any information about you where your identity is apparent, or can reasonably be ascertained, from the information (Personal Information).
1. What this policy is about
This policy explains the measures we have taken to implement the requirements of the Privacy Act 1998. It aims to answer the questions you might have about how we collect, use and disclose the information we collect from you, including your Personal Information.
If you have any questions about the Company’ privacy practices, please contact us at firstname.lastname@example.org
2. What information we do not collect from you
We do not collect, store or use financial information (such as credit card numbers). Our Services are sold, and your payments are processed, by third-party distributors such as Apple, Google, Windows or Amazon in accordance with their own terms and conditions and privacy policies. Those third parties do not share your financial information with us.
We do not knowingly collect, store or use any Personal Information about users aged under 14. If you believe we may have collected, stored or used Personal Information about a user aged under 14, please contact us immediately at email@example.com and we will permanently destroy that information.
3. What information we may collect from you
We collect information that you have provided to us about yourself directly to us through the Services, including by email or phone, or via Third Party Sites.
We also collect information about your use of the Services and Third Party Sites.
The information we collect may include:
- information provided in registering for the Services and Third Party Sites – for example, your name and contact details;
- information disclosed by you as a participant on the Services and Third Party Sites, in, for example, blogs, forums or any other spaces where you are able to make comments;
- information provided indirectly by you as a result of your use of the Services and Third Party Sites – for example, the frequency with which and the times at which you use the Services and Third Party Sites and information about your preferences and interests.
We wish to provide the Services’ users with a positive user experience. To assist us in doing this, we also collect visitor information related to browser and operating systems.
‘Cookies’ are alphanumeric identifiers that are stored by your web browser on your computer’s hard-drive that enable our system to recognise you when you visit the Services. This helps the Company to track basic visitor information so we can better tailor the Services to our visitors’ needs.
Most web browsers automatically accept cookies but you can disable this function by changing your browser settings if you so wish.
3. What we do with this information
We collect information about you to provide you with the Services, including displaying your name (or screen name) and photo to identify you on the Services. We also collect information to improve and expand the content of the Services and to better engage with our Services’ users.
We may also use information we collect about you and your Personal Information for related purposes such as:
- communicating with you;
- if you so choose, linking your Services to your Third Party Site accounts and to display updates about your use of the Services on your Third Party Sites;
- to record information about your usage, preferences and behaviour in relation to the Services and Third Party Sites, as well as any feedback you share with us;
- to perform statistical analyses of user behaviour;
- maintaining our relationship with you, including responding to your questions;
- helping us to identify and inform you about other products or services that are likely to be of interest to you;
- providing targeted third-party advertising to you on the Services;
- internal accounting and administration, including sharing information with our related bodies corporate for reporting purposes;
- protecting you and the Company from fraud; and
- any other use for which we obtain your permission.
4. How long we will keep your Personal Information
We will keep your Personal Information for as long as it is required to provide you with our Services and to comply with legal requirements.
If we no longer require your Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify your Personal Information.
5. Sharing your information with others
The Company recognises the trust you place in us when you give us your Personal Information. Other than disclosure to service providers (explained below) or as required by law (for example, disclosure to various Government departments or to courts), we do not give your Personal Information to other organisations except for in accordance with this policy.
We may share your Personal Information with third parties service providers such as the providers of the electronic systems we use to collect and store your Personal Information; the service providers who provide our servers; and other service providers we use to help us run aspects of our business efficiently.
Occasionally the Company might also use your Personal Information for other purposes or share your information with another organisation because:
- we believe it is necessary to provide you with a service which you have requested;
- we believe it is necessary to protect the rights, property or personal safety of another Services user;
- we believe it is necessary to do so to prevent or help detect fraud or serious credit infringements – for example, we may share information with law enforcement agencies and fraud prevention units;
- we believe it is necessary to protect the interests of the Company – for example, disclosure to a court in the event of legal action to which the Company is a party; or
- the assets and operations of the Company’s business are being transferred to another party as a going concern.
6. Accessing information we keep about you
You can access the Personal Information we hold about you at any time. Simply contact us to make your request at firstname.lastname@example.org
We will always endeavour to meet your request for access. However, in some circumstances we may decline a request for access. This includes the following circumstances:
- we no longer hold or use the information;
- providing access would have an unreasonable impact on the privacy of other persons;
- the request is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
- providing access would be unlawful;
- providing access would be likely to prejudice the detection, prevention, investigation and prosecution of possible unlawful activity; and
- the information would reveal our commercially sensitive decision-making processes.
If we decline your request for access, we will give you reasons for our decision when we respond to your request.
We reserve the right to charge you a reasonable fee for access to some types of information. These charges will be limited to the cost of recouping our expenses for providing you with information, such as document retrieval, photocopying, labour and delivery.
7. Changing or deleting the information
To provide you with the best possible service, we will take reasonable steps to ensure that your Personal Information is accurate, complete and up-to-date at the time of collecting, using or disclosing the information.
If you believe that any information we hold about you is inaccurate, incomplete or out-of-date, you should notify us. We will do our best to correct it or delete it, unless we need to keep if for legal reasons.
The Company endeavours to take all reasonable steps to keep your Personal Information secure. We store this information on secure servers. Once it is stored on our servers, only authorised users can access your Personal Information, and access is only for approved purposes.
The Company is not responsible for any third-party access to your Personal Information as a result of:
- interception while it is in transit over the internet;
- spyware or viruses on the device (such as a computer or phone) from which you access the Services, nor
- as a result of your failure to adequately protect your account details or password;
nor for any losses, expenses, damages and costs, including legal fees, resulting from such access.
9. Providing information on other Sites
Please note that your access to and use of the Services may be subject to certain third-party terms and conditions and privacy policies, including on-line gaming platforms and social networking services. You recognise and agree that the Company is not liable for any such third-party terms and conditions nor any third party’s use of your Personal Information.
If you bought or otherwise accessed the Services through a Third Party Distributor, or if you paid for the Services via a third-party gateway such as PayPal, that company may collect and store your Personal Information. Please review their privacy policies to see how it handles your information.
These Third Party Distributors and gateways do not share any financial information (such as your credit card number) with us.
1. What to do if you have a problem, question or complaint