Privacy Policy – ConnectCloser Pty Ltd

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means ConnectCloser Pty Ltd (ACN 632 992 815). We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information. 

By providing Personal Information to us, you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our Application. We encourage you to check our Application periodically to ensure that you are aware of our current Privacy Policy.

1. Definitions

1.1 In this Privacy Policy, the following capitalised terms have the following meanings:

Application means ConnectCloser and any Services offered under the name “ConnectCloser”.

Challenge means any challenge, activity, quiz-style question, game and other content on the Application.

Partner means an individual, at least 18 years old, with whom you jointly subscribe to the Services.

Personal Information means any information or an opinion about an individual which can be used to identify an individual, and described in detail in clause 2. 

Privacy Act means the Privacy Act 1998 (Cth).

Services means any services offered on the Application, including any Challenge assigned to you.

Spam Act means the Spam Act 2003 (Cth).

User means any person using or registering on the Application whatsoever.

You, you or your mean you and any User of the Application.

3. what personal information do we collect?

2.1 We may collect the following types of Personal Information:

(a) your name;

(b) mailing or street address;

(c) email address

(d) telephone number and other contact details

(e) gender, age or date of birth

(f) credit card information

(g) name, gender, email address and other information about your Partner;

(h) your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from any of our sites or applications, ad data, IP address and standard web log information;

(i) details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries;

(j) any additional information relating to you that you provide to us directly through our Application, email and telephone or indirectly through your use of our Application or online presence or through other websites or accounts from which you permit us to collect information;

(k) information you provide to us through customer surveys or form submission; or

(l) any other Personal Information that may be required in order to facilitate your dealings with us.

We may collect these types of Personal Information either directly from you, or from third parties. We may collect this information when you:

(a) register on the Application

(b) communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;

(c) interact with the Application, Services, content and advertising; or

(d) invest in our business or enquire as to a potential purchase in our business.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

By sharing Personal Information about your Partner with us, you represent that you have obtained the consent of your Partner and are entitled to share Personal Information about them with us.

3. why do we collect, use and disclose personal information?

3.1 We may collect, hold, use and disclose your Personal Information for the following purposes:

(a) to enable you to access and use our Application, subscribe to the Services and interact with Users;

(b) to operate, protect, improve and optimise our Application and our Services, business and our Users’ experience, such as to perform analytics, conduct research and for advertising and marketing;

(c) to send you Service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

(d) to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;

(e) to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

(f) to comply with our legal obligations, resolve any disputes that we may have with any of our Users, and enforce our agreements with third parties; and

(g) to consider your employment application.

We may also disclose your Personal Information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the Services that you receive.

4. Do we use your personal information for direct marketing?

4.1 We and/or our carefully selected business partners may send you direct marketing communications and information about the Services offered on our Application. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us  via hello@connectcloser.com , or by using the opt-out facilities provided (e.g. an unsubscribe link).

5. to whom do we disclose your personal information?

5.1 We may disclose Personal Information for the purposes described in this Privacy Policy to:

(a) our employees and related bodies corporate;

(b) third-party suppliers and service providers (including providers for the operation of our Application and/or our business or in connection with providing our Services to you);

(c) professional advisers, dealers and agents;

(d) payment systems operators (e.g. merchants receiving card payments);

(e) our existing or potential agents, business partners or partners;

(f) our sponsors or promoters of any competition that we conduct via our Services;

(g) anyone to whom our assets or businesses (or any part of them) are transferred;

(h) specific third-parties authorised by you to receive information held by us; and/or

(i) other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

6. using our application and cookies

6.1 We may collect Personal Information about you when you use and access our Application. While we do not use browsing information to identify you personally, we may record certain information about your use of the Application, such as the time and date of your visit and the internet protocol address assigned to your device.

6.2 We may also use ‘cookies’ or other similar tracking technologies on our Application that help us track your usage of the Application and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions.

6.3 We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.

7. security

7.1 We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.

8. retention

8.1 We may retain your Personal Information as long as you are registered to the Application as a User. You may close your account by contacting us. However, we may retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

9. exclusions

9.1 Links: Our Application may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

9.2 Personal Information provided to others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Application or through any other means, or information posted by you to any public areas of the Application. 

10. accessing or correcting your personal information

10.1 You can access the Personal Information we hold about you by contacting us at hello@connectcloser.com . Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.

10.2 If you think that any Personal Information we hold about you is inaccurate, please let us know at hello@connectcloser.com and we will take reasonable steps to ensure that it is corrected.

10.3 We will consider and respond to all requests in accordance with all applicable laws.

11. making a complaint

11.1 If you think we have breached the Privacy Act or any other relevant privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us at hello@connectcloser.com. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

12. contact us

12.1 For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us at hello@connectcloser.com

Effective: 19th December 2020