This version is current as at 1 August 2020
In this document, we refer to ourselves Spotee Pty Ltd ABN 55 637 623 940, as We, Us or Our, and to our clients and others from whom we collect personal information as You.
At Spotee, and at our parent entity Daylight Financial Group Pty Ltd, we are committed to preserving and respecting your privacy and complying with the Privacy Act 1988 in respect of the collection, management and disclosure of your personal information.
1. Information we collect about you
We collect personal information about our clients which generally is any information that identifies you as an individual. This includes information such as your name, address, contact number, credit card and other personal details. If the information we collect personally identifies you, or we can reasonably identify you from the information you have submitted, then that information is considered to be personal information. We collect this information for the purposes set out below (see item 4).
We also collect personal information (such as contact details) about persons who are not our clients, including about our former or potential clients, people who enter our premises or apply for a job with us. We collect this information for the following purposes:
- In the case of former clients, we collect and hold personal information to comply with our financial services obligations.
- In the case of potential clients, we collect personal information to assist with promotional activities, marketing research and product development.
- In the case of people who enter our premises, we collect personal information for workplace health and safety reasons and to contact those who’ve provided services to us.
- In the case of people applying for jobs with us, we collect personal information to assist with assessing their applications.
Usually, we collect information directly from you. We may collect such personal information from you over the telephone, via email, when you complete an application form or from other sources during providing our services to you. However, sometimes we also collect your personal information after receiving information via a sponsorship agreement that we have entered with a particular party.
2. Website Cookies and the use of personal information
We make use of “cookies” technology to improve the functionality of our website. A cookie is a small string of information that a website transfers to your browser for identification purposes.
If you provide personal information via our website (e.g. by completing an online form), cookies may be used to match your web browser to that personal information. This may be done for the following purposes:
- to monitor your usage of, and browsing behaviour on, our website;
- to identify information or services that may be of interest to you (based on your usage of, and browsing behaviour on, our website);
- and related marketing purposes.
Internet browsers typically permit settings to be adjusted to manage or block cookies. However, if you disable the cookies feature, you may not be able to access all the functionality of our website.
3. What happens if you choose not to provide the information?
You do not have to give us your personal information. However, if you choose not to, we may be unable to provide you with all our products and services.
4. How we use your personal information
We use your personal information to:
- enable us to provide our products and services (and to provide information about those products and services) to you;
- administer the provision of our products and services (such as make bookings, send you bills and collect amounts owed from you);
- improve the products and services we provide to you and inform you about any improvements or changes in those products and services;
- market products and services that we or third parties offer (you can opt out of receiving such marketing information at any time); and
- enable us to meet our financial services obligations.
5. How we disclose your personal information
We try to minimise the instances in which we disclose your personal information to third parties. (In particular, we will not sell your personal information to third persons.) However, there are times when we need to disclose your personal information to third parties (mainly to enable us to provide our products and services to you) or as required by courts, tribunals, government regulatory agencies or the police.
Some of these service providers, to whom we make regular disclosures, are located overseas, mainly in the United States of America. These external service providers are only authorised to use this personal information for the purposes for which Spotee supplied it. Spotee will also seek to ensure that the recipient of the personal information has systems and procedures in place to prevent loss or misuse or any unauthorised disclosure in line with Australian laws and standards.
We may also disclose personal information to our related entity, Daylight Financial Group Pty Limited ABN 77 633 984 773, for the purposes of meeting our financial services obligations (for example, dispute resolution obligations).
6. You can access and correct information
We will take all reasonable steps to ensure that your personal information which we collect, use or disclose is accurate, complete, relevant, not misleading and up-to-date. We encourage you to contact us about changes to your personal details. You can also access the personal information we hold about you, except in certain limited circumstances. If you wish to do so, please send an email to our Privacy Compliance Officer (see contact details below) and we will respond to you within 30 days.
You can also request that information we hold about you be corrected or deleted, and we will take such steps as are reasonable in the circumstances to ensure this is done. If you wish to do so, please email our Privacy Compliance Officer (see contact details below).
7. How we hold and secure your personal information
We take all reasonable steps to protect the security of the personal information that we hold from misuse, loss, unauthorised access, modification or disclosure. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy. You should be aware that the Internet is not a secure environment. If you use the Internet to send us information, including your email address, it is sent at your own risk.
It is your responsibility to keep your password safe.
8. Data Breach
Should any unforeseeable event occur which results in the loss, or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will investigate the matter and notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable pursuant to our obligations under the Privacy Act 1988.
9. Updating our privacy statement
We may revise or update this document occasionally. The current version will be posted on our website. You should check back to our website from time to time to view the most recent version of our privacy statement. You can also obtain a copy of this privacy statement from the Privacy Compliance Officer (see contact details below).
10. Complaints and further information
If you have any complaints about our privacy practices, please:
- contact our Privacy Compliance Officer by email at firstname.lastname@example.org
We will endeavour to resolve any complaint or query as soon as possible.
If you’re not satisfied with our resolution, you may also complain to the Office of the OAIC. The contact details for the OAIC are GPO Box 2999, Canberra ACT 2601 or GPOB 5218 Sydney NSW 2001 or phone 1300 363 992. Alternatively, email the OAIC at email@example.com.
11. Contact details for our Privacy Officer
Contact our Privacy Officer by email at firstname.lastname@example.org